COMMISSION STAFF WORKING DOCUMENT Mid-term evaluation of the Recovery and Resilience Facility Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Mid-Term Evaluation of the Recovery and Resilience Facility: Strengthening the EU through ambitious reforms and investments
Date: 2024-02-21
Institutions: European Commission, Secretariat-General
Subjects: EU Member State, EU energy policy, EU financial instrument, EU financing arrangements, economic recovery, economic reform, innovation, investment, reduction of gas emissions, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 21.2.2024  SWD(2024) 70 final  COMMISSION STAFF WORKING DOCUMENT Mid-term evaluation of the Recovery and Resilience Facility Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Mid-Term Evaluation of the Recovery and Resilience Facility: Strengthening the EU through ambitious reforms and investments {COM(2024) 82 final}  
 
 
Table of contents 

1. 

INTRODUCTION .................................................................................................................. 2 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ........................ 5 

2.1.  Description of the intervention and its objectives ........................................................... 5 

2.2. 

Point(s) of comparison .................................................................................................. 12 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ........ 17 

3.1. Economic developments since the start of the RRF ........................................................... 18 

3.2. State of play of the RRF implementation ........................................................................... 18 

3.3. Improvements in RRF implementation over the evaluation period ................................... 25 

3.4. Inter-institutional scrutiny .................................................................................................. 27 

4.  EVALUATION FINDINGS (ANALYTICAL PART) ........................................................ 29 

To what extent was the intervention successful and why? ........................................................ 29 

4.1. Effectiveness ...................................................................................................................... 29 

4.2. Efficiency ........................................................................................................................... 57 

4.3. Coherence ........................................................................................................................... 61 

How did the EU intervention make a difference and to whom? ................................................ 66 

4.4. EU added value .................................................................................................................. 66 

Is the intervention still relevant? ............................................................................................... 72 

4.5. Relevance ........................................................................................................................... 72 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? .................................. 75 

5.1. Conclusions ........................................................................................................................ 75 

5.2. Lessons learned .................................................................................................................. 78 

ANNEX I: PROCEDURAL INFORMATION ............................................................................. 85 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ................................... 88 

ANNEX III. EVALUATION MATRIX AND DETAILS ON ANSWERS TO THE 

EVALUATION QUESTIONS ........................................................................................... 142 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS .......................................................... 200 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ............................ 202 

ANNEX VI. ADDITIONAL DATA AND ANALYSIS ............................................................ 217 

 
 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

ALMP 

CID 

CSR 

DNSH 

ECA 

EFC 

EPC 

ERDF 

FTE 

GDP 

IPCEI 

ISG 

NGEU 

ROI 

RRF 

RRP 

SoA 

SMEs 

STEP 

SDGs 

S.M.A.R.T. 

SWD 

TSI 

Active Labour Market Policies 

Council Implementing Decision 

Country-specific recommendation 

Do no significant harm 

European Court of Auditors 

Economic and Financial Committee 

Economic Policy Committee 

European Regional Development Fund 

Full-time equivalent 

Gross domestic product 

Important Projects of Common European Interest 

Inter-service steering group 

NextGenerationEU 

Return on investment 

Recovery and Resilience Facility 

Recovery and resilience plans 

Statement of assurance 

Small and medium-sized enterprises 

Strategic Technologies for Europe Platform 

Sustainable Development Goals 

Specific, measurable, assignable, realistic, and time-
related 

Staff Working Document 

Technical Support Instrument 

 
 
1. 

INTRODUCTION 

The Recovery and Resilience Facility (‘RRF’) was established in February 2021 by 
Regulation (EU) 2021/2411 (hereafter referred to as ‘RRF Regulation’) to help the Union 
recover from the COVID-19 crisis and is time-bound until 2026. The Facility was set up 
as  a  new,  innovative,  demand-driven  performance-based  instrument,  providing  direct 
financial support to Member States against the implementation of a combination of reforms 
and investments. Unlike other EU instruments (such as CRII2, REACT-EU3 or SURE4) that 
were  set  up  for  crisis-management  purposes,  the  RRF  was  created  to  address  the 
unprecedent impact of the COVID-19 crisis and make the Union more resilient and better 
prepared for the future. With an envelope of EUR 724 billion5 (in current prices), the scale 
of financial support is unprecedented in the Union’s history. 

As required by the RRF Regulation, the purpose of this evaluation is to provide, at 
the  half-way  point,  a  mid-term  assessment  of  how  the  RRF  is  delivering  on  its 
objectives, in particular to which extent the Facility has been providing financial support 
to  Member  States  against  the  implementation  of  pre-agreed  reforms  and  investments 
(specific  objective)  that  promote  the  Union’s  economic,  social  and  territorial  cohesion 
(general objective). In line with the RRF Regulation (Article 32), it will assess in particular 
“to  which  extent  the  objectives  have  been  achieved,  the  efficiency  of  the  use  of  the 
resources  and  the  European  added  value”,  as  well  as  “the  continued  relevance  of  all 
objectives and actions” and “the implementation of the REPowerEU chapters and their 
contributions to the REPowerEU objectives”.  

This  mid-term  evaluation  covers  the  evaluation  requirements  set  out  in  the  RRF 
Regulation  (Article  32(2))  and  the  five  evaluation  criteria  set  out  in  the  European 
Commission’s  Better  Regulation  Guidelines  and  the  Inter-institutional  Agreement  on 
Better Law-Making6. In particular, it seeks to assess: (i) to which extent the objectives of 
the  RRF  have  been  achieved  or  progress  has  been  made  since  the  start  of  the 
implementation period (i.e. effectiveness); (ii) how do the costs and benefits of the Facility 
compare,  including  an  assessment  of  potential  unnecessary  administrative  burden  and 
complexity (i.e. efficiency); (iii) to what extent the RRF is and continues to be relevant in 
view  of  its  objectives,  needs  and  new  emerging  challenges  (i.e.  relevance);  (iv)  the 
interplay between the RRF and other Union’s policies and instruments (i.e. coherence); 

1   Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing the 

Recovery and Resilience Facility, available at: https://eur-lex.europa.eu/eli/reg/2021/241/oj/eng.  
2   The Coronavirus Investment Initiative (CRII) and the Coronavirus Investment Initiative plus (CRII+). 
3   Recovery Assistance for Cohesion and the Territories of Europe (REACT-EU).  
4   The European instrument for temporary Support to mitigate Unemployment Risks in an Emergency (‘SURE’). 
5   EUR 338 billion in non-repayable support and EUR 385 billion in loans. 
6   European Commission Better Regulation Guidelines (2021), available at: 
https://commission.europa.eu/system/files/2021-11/swd2021_305_en.pdf.  

2 

 
 
 
and (v) whether the RRF yield results that go beyond what could be expected by individual 
actions of Member States (i.e. EU-added value). 

The scope of this mid-term evaluation covers the design of the recovery and resilience 
plans (‘RRPs’) and the ongoing implementation of the Facility in all Member States 
until  1  February  20247.  It  covers  the  full  scope  of  the  Facility  specified  in  the  RRF 
Regulation, i.e. the following six pillars structuring the policy areas of European relevance: 
(i) green transition, (ii) digital transformation, (iii) smart, sustainable and inclusive growth, 
(iv) social and territorial cohesion, (v) health, economic, social, and institutional resilience, 
(vi)  policies  for  the  next  generation.  The  adopted  REPowerEU  chapters  and  their 
contributions  to  the  REPowerEU  objectives  are  also  in  the  scope  of  this  mid-term 
evaluation. The funding strategy to finance the RRF, and NextGenerationEU (‘NGEU’) 
more generally, is outside the scope of this evaluation.  

It is important to acknowledge that the nature and timing of this report comes too 
early for the report to be able to deliver a fully-fledged impact evaluation. The mid-
term evaluation can only report and assess the implementation of the RRF until 1 February 
2024. Given that most measures, particularly investments, have not yet reached the level 
of full implementation, it is not feasible at this point to provide a systematic assessment of 
results and impacts of the Facility. This impact analysis will be included in the 2028 ‘ex-
post  evaluation’,  when  the  measures  supported  by  the  RRF  will  have  been  fully 
implemented. The ex-post evaluation will provide a “global assessment of the Facility and 
its impact in the long term”, as specified by the RRF Regulation (Article 32(4)). 

This report therefore takes stock of the progress in the implementation of the Facility 
halfway  through  its  implementation  and  evaluates  its  impact  where  possible.  It 
presents the progress made to date in reaching the RRF’s specific objective (i.e. to provide 
Member States with financial support in order to achieve specific milestones and targets 
that represent steps in the implementation of reforms and investments). It also illustrates 
how the achievement of milestones and targets has, in some cases, already translated into 
the implementation of reforms and investments by Member States. This in turn contributes 
to achieving the RRF’s general objective, i.e. to promote the Union’s economic, social and 
territorial cohesion.  

Two innovative features of the RRF are of particular interest in the context of this 
mid-term evaluation. First, the RRF combines financial support for both investments and 
reforms. It provides financial incentives for the delivery of key reforms, as identified in 

7   The information provided in this Staff Working Document is based on the content of the adopted plans, as assessed 
by the Commission, on the data reported by Member States until October 2023 as part of their bi-annual reporting 
obligations, on data from the Recovery and Resilience Scoreboard as of 1 February 2024 and on developments in 
the implementation of the Facility until 1 February 2024, unless otherwise specified. The data reflects the latest 
recovery  and  resilience  plans  for  Estonia,  France,  Luxembourg,  and  Slovakia  and  the  plans  following  the  first 
revisions for Germany (adopted on 14/02/2023), Ireland (adopted on 14/07/2023), Italy (adopted 19/09/2023), and 
Finland  (adopted  on  14/03/2023).  It  does  not  reflect  the  latest  plans  for  Belgium,  Bulgaria,  Czechia,  Denmark, 
Germany  (following  the  second revision),  Ireland (following  the  second  revision),  Greece,  Spain, Croatia,  Italy 
(following  the  second  revision),  Cyprus,  Latvia,  Lithuania,  Hungary,  Malta,  the  Netherlands,  Austria,  Poland, 
Portugal, Romania, Slovenia, Finland (following the second revision) and Sweden as data for these Member States 
was not yet fully available.  

3 

 
 
the  context  of  the  European  Semester.  A  second  innovation  concerns  the  fact  that 
disbursements  to  Member  States  are  related  to  the  achievement  of  ‘milestones  and 
targets’8. This evaluation pays particular attention to assessing this so-called ‘performance-
based’ approach, which is defined in the literature as “aiming to improve the efficiency and 
effectiveness of public expenditure by linking the funding of public sector organisations to 
the  results  they  deliver,  making  systematic  use  of  performance  information”9.  The 
‘performance-based’ approach of the RRF differs from the ‘cost-based’ approach generally 
applied  for  the  European  Structural  and  Investment  Funds.  As  a  performance-based 
instrument, the RRF disburses funds against the achievement of  milestones and targets, 
which measure the progress towards the achievement of  concrete results, which are the 
delivery of the agreed reforms and investments in each national RRP. 

As  is  the  case  with  a  mid-term  evaluation  of  any  instrument,  more  information  is 
available  at  this  stage  on  outputs  than  on  results  and  impacts.  This  is  particularly 
relevant for the RRF since measures are usually covered in the RRPs by more than one 
milestone and/or target, and the final deadline for milestones and targets to be completed 
is 31 August 2026. Particularly for investments, the milestones and targets that have been 
achieved at the mid-term point often cover initial steps, such as a launch of calls for tender, 
or  signing  of  procurement  contracts;  whilst  the  final  milestones  and  targets  due  in  the 
second half of the Facility’s lifetime will increasingly cover final investment outputs. 

The results of the evaluation will serve two aims. First, they can help identify possible 
improvements  in  implementing  the  RRF  over  the  remaining  period  (until  end  2026)10. 
Second, the early assessment of the novel performance-based nature of the Facility will be 
a pertinent reference point to inform discussions on EU funding instruments in view of the 
next EU Multi-annual Financial Framework starting in 2028. 

This Staff Working Document (‘SWD’) presents the Commission staff’s views on the 
mid-term  evaluation  of  the  RRF,  building  on  multiple  sources.  The  assessment  is 
primarily based  on  an independent  external  evaluation report (hereinafter  referred to  as 
‘supporting  study’)  contracted  by  the  Commission  and  prepared  by  a  consortium 
comprising CEPS, ECORYS, NIESR, CSIL and Wavestone (for further information see 
the Annex to this SWD). The supporting study was concluded in November 2023 and is 
published together with this SWD. Given the unprecedented scale and scope of the RRF, 
the study takes a comprehensive approach and is complemented by eight case studies11 that 
provide  an  in-depth  assessment  of  selected  policy  areas.  Moreover,  the  Commission 
organised  a  call  for  evidence  and  an  open  public  consultation,  with  a  limited  response 

8   Disbursements of RRF funds are conditional on the satisfactory fulfilment of milestones and targets proposed by 
the  Member  States  for  the  implementation  of  the  measures  in  their  national  recovery  and  resilience  plans  and 
approved by the Council. 
IMF  Working  Paper  Series,  Volume  2009:  Issue  084,  “Accrual  Budgeting  and  Fiscal  Policy”,  available  at 
https://www.elibrary.imf.org/view/journals/001/2009/084/001.2009.issue-084-en.xml?Tabs=toc-102773. 

9  

10   Article 32 (3) of the RRF Regulation provides that “where appropriate, the evaluation shall be accompanied by a 

proposal for amendments to this Regulation”. 

11   The topics of the eight case studies are: (a) Energy efficiency in buildings; (b) digitalisation of healthcare; (c) support 
to SMEs; (d) active labour market policies; (e) rule of law reforms; (f) early childhood education and care; (g) cross-
border projects; (h) interaction between the RRF and other EU funds. 

4 

 
 
rate12. The reports of the European Economic and Social Committee13 and of the European 
Committee of the Regions14 feed into this evaluation as well. 

Overall,  the  evaluation  process  went  as  planned,  and  the  data  gathered  are 
considered  reliable.  No  significant  difficulties  were  encountered  in  reaching  key 
stakeholders involved in the design and implementation of the RRF. An appropriate and 
diverse range of tools was used, with different sources of evidence enabling triangulation 
of findings and converging sufficiently to support the assessments made. Therefore, even 
with the limitations linked to the early state in the RRF’s implementation, the conclusions 
and lessons learned can be considered sufficiently robust for a mid-term evaluation. 

To ensure the quality of the evaluation, a Commission inter-service steering group 
(‘ISG’) oversaw the evaluation process. The ISG provided information, expertise and 
quality assurance in line with evaluation standards and provided a useful steer to both the 
external  study  and  this  SWD.  The  members  of  the  ISG  came  from  a  broad  range  of 
Commission services15 that are responsible for EU-policies relevant to the RRF. 

This  SWD is  organised as follows:  Section 2 summarises the objectives and expected 
outcomes of the RRF, whilst Section 3 describes how the situation has evolved since the 
inception of the RRF in 2021. Section 4 presents the main findings of the evaluation by 
criteria  and  the  final  Section  5  provides  conclusions  and  lessons  learned.  The  annexes 
provide additional information about the methodology and analytical models used, about 
the stakeholder consultation  conducted,  and  about the procedure  followed for this  mid-
term evaluation. 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1. Description of the intervention and its objectives 

2.1.1. Context of the intervention 

The RRF is at the core of the EU’s answer to the unprecedented crisis resulting from 
the COVID-19 outbreak in early  2020. The pandemic fundamentally transformed  the 
European  and  global  economic,  social  and  budgetary  situation.  Economic  activity  in 
Europe and around the world suffered a series of severe shocks in 2020 as lockdowns and 
public health measures  were introduced  to  limit the spread of the COVID-19 virus and 
manage  the  severe  health  emergency.  The  EU  was  pushed  into  recession,  with  output 

12  See Annexes II and V for further information on the open public consultation. 
13   European Economic and Social Committee (2023), Mid-term evaluation of the Recovery and Resilience Facility, 
available at: https://www.eesc.europa.eu/en/our-work/opinions-information-reports/information-reports/mid-term-
evaluation-recovery-and-resilience-facility.  

14   European Committee of the Regions (2023), Review Report on the Implementation of the Recovery and Resilience 
Facility, available at: https://cor.europa.eu/en/our-work/Pages/OpinionTimeline.aspx?opId=CDR-4212-2022. 
15   The ISSG is composed of representatives of DG AGRI, BUDG, CLIMA, CNECT, COMM, COMP, DEFIS, DIGIT, 
EAC, EMPL, ENER, ENV, FISMA, GROW, HOME, JRC, JUST, LS, MOVE, OLAF, REFORM, REGIO, RTD, 
SANTE, TAXUD and TRADE. 

5 

 
 
falling by 5.6% in real terms in 2020 as a whole16. This drop was even larger than the one 
recorded in 2009 during the Great Financial Crisis (-4.3%). The economic recovery hinged 
upon  the  successful  implementation  of  vaccination  campaigns  allowing  for  the  gradual 
lifting of restrictions, and the ability to structurally recover while avoiding long‑term scars. 

The  EU  considered  that  a  rapid,  coordinated  and  large  public  intervention  was 
needed to maintain confidence and ensure a balanced economic recovery17. Member 
States needed significant fiscal space to mitigate the social and economic impact of the 
crisis,  and to  foster the resilience of their  economies and social structures.  Coordinated 
action  at  EU  level  was  necessary  to  prevent  a  lasting  loss  in  productive  capacity  and 
employment (“hysteresis” effects), financial fragmentation within the Union, as well as a 
distortion of the level playing field of the Single Market. Previous crisis experiences had 
shown that a lack of resilience can lead to negative spill-over effects across Member States, 
and that investments are drastically cut. It was clear that such reductions in public spending 
would drag on the economic and social recovery, and that investment efforts should be 
accompanied  by  complementary  reforms  responding  to  pre-existing  and  emerging 
challenges in the Member States. At the same time, the recovery strategies put in place by 
the Member States needed to be consistent with the Union’s common priorities, including 
as regards the green and digital transitions, by fostering ambitious investments and reforms 
in these areas. 

2.1.2. Objectives of the intervention 

The  RRF,  established  by  Regulation  (EU)  2021/241  of  12  February  2021,  is  the 
centrepiece of NGEU, the EU response to mitigate the economic and social impact of 
the pandemic and to emerge stronger from the crisis. The Facility was set up to offer 
large-scale financial support for a combination of public investments and of reforms that 
would make Member States economies more resilient and better prepared for the future. It 
was designed to help Member States address existing economic and social challenges that 
had been exacerbated by  the  crisis in  various areas, such  as social,  employment, skills, 
education, research and innovation, health issues, but also issues related to the business 
environment, including public administration and the financial sector. The combination of 
reforms and investments is a key innovative feature of the RRF. Importantly, the Facility 
was  also  designed  to  ensure  that  these  investments  and  reforms  address  the  challenges 
identified in the relevant country-specific recommendations (‘CSRs’) issued in the context 
of  the  European  Semester,  as  well  as  the  challenges  and  investment  needs  related  to 
common  EU  priorities,  including  the  green  and  digital  transitions,  thereby  ensuring  a 
sustainable  recovery  and  helping  to  make  the  Union  more  resilient,  including  by 
diversifying key supply chains and strengthening the strategic autonomy of the Union.  

16   See European Economic Forecast – Autumn 2023, available at: https://economy-finance.ec.europa.eu/economic-

forecast-and-surveys/economic-forecasts/autumn-2023-economic-forecast-modest-recovery-ahead-after-
challenging-year_en. 

17   More details in Commission Staff Working Document (SWD(2020) 98 final/2) on identifying Europe's recovery 
needs, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020SC0098(01).  

6 

 
 
The general objective18 of the RRF is to promote the Union’s economic, social and 
territorial cohesion, by: “[…] improving the resilience, crisis preparedness, adjustment 
capacity and growth potential of the Member States, by mitigating the social and economic 
impact of that crisis, in particular on women, by contributing to the implementation of the 
European Pillar of Social Rights, by supporting the green transition, by contributing to the 
achievement of the Union’s 2030 climate targets [...], by complying with the objective of 
EU  climate  neutrality  by  2050  and  of  the  digital  transition,  and  by  increasing  the 
resilience, security and sustainability of the Union’s energy system through the necessary 
reduction in  dependence on fossil fuels and diversification of  energy supplies at  Union 
level, including by means of an increase in the uptake of renewables, in energy efficiency 
and in energy storage capacity, thereby contributing to the upward economic and social 
convergence,  restoring  and  promoting  sustainable  growth  and  the  integration  of  the 
economies of the Union, fostering high quality employment creation, and contributing to 
the strategic autonomy of the Union alongside an open economy and generating European 
added value.” 

To achieve this general objective, the specific objective19 of the Facility is “to provide 
Member States with financial support with a view to achieving the milestones and targets 
of reforms and investments as set out in their recovery and resilience plans […] in close 
and transparent cooperation with the Member States concerned”.  

The RRF Regulation also establishes six pillars that define the scope of the Facility, 
namely:  (i)  green  transition;  (ii)  digital  transformation;  (iii)  smart,  sustainable  and 
inclusive  growth,  including  economic  cohesion,  jobs,  productivity,  competitiveness, 
research, development and innovation, and a well-functioning internal market with strong 
small and medium enterprises (‘SMEs’); (iv) social and territorial cohesion; (v) health, and 
economic, social and institutional resilience with the aim of, inter alia, increasing crisis 
preparedness  and  crisis  response  capacity;  and  (vi)  policies  for  the  next  generation, 
children and the youth, such as education and skills.  

Green  and  digital  policy  efforts  are  mainstreamed  in  the  RRF.  This  reflects  the 
importance of tackling climate change, in line with the EU’s commitments to implement 
the Paris Agreement and the UN Sustainable Development Goals. Beyond the mandatory 
compliance with the “do no significant harm” principle (except for a targeted derogation 
under REPowerEU), the Regulation established that measures accounting for at least 37 % 
of the total allocation of Member States’ RRPs should contribute to the green transition, 
including  biodiversity  or  addressing  the  resulting  challenges,  based  on  an  agreed 
methodology  for  climate  tracking.  Similarly,  the  Regulation  establishes  that  measures 
contributing to the digital objectives of the Regulation should account for an amount that 
represents at least 20% of the RRPs total allocation.  

18   As defined in Article 4 of the RRF Regulation. 
19   As defined in Article 4 of the RRF Regulation. 

7 

 
 
The  RRF  Regulation  defines  a  specific  allocation  key  for  the  Facility20,  in  order  to 
ensure a meaningful financial contribution  for each Member State commensurate to the 
actual  needs.  The  allocation  key  was  a  tailored  solution  to  consider  the  specific  crisis 
circumstances and the uncertainty related to the effects of the pandemic. It was first applied 
to  70%  of  the  EUR  338  billion  in  non-repayable  support,  based  on  the  population,  the 
inverse of GDP per capita of 2019 and the relative average unemployment rate of each 
Member State. An adjusted allocation key was later applied to 30% of the non-repayable 
support, also taking into account the change in real GDP in 2020 and 2021. This was to 
ensure the allocation of resources was well aligned with the objective of the Facility. Non-
repayable  support  would  be  particularly  beneficial  to  Member  States  with  a  lower  per 
capita income and with a high unemployment rate, reflecting the high economic and social 
challenges that the pandemic aggravated. The RRF Regulation, also provided for an update 
of the maximum financial contribution available to each Member State in June 2022, to 
reflect the actual depth of the economic crisis across the Member States and the aggregated 
impact on real GDP during the period 2020-2021. 

The  RRF  also  provides  loans  that  complement  non-repayable  support  and  cover 
additional financing needs linked to reforms and investments. RRF loans of maximum 
EUR 386 billion are characterised by long maturities and favourable interest rates. They 
are of particular interest and benefit to Member States that faced higher borrowing costs. 
The total amount of loans on offer to each Member State is determined by the assessment 
of  its  loan  request  and  should  ordinarily  not  exceed  6.8%  of  its  2019  gross  national 
income21.  

With its wide scope and anchor in the European Semester, the RRF is expected to 
contribute to all Sustainable Development Goals (‘SDGs’). The SDGs are an integral 
part of the analysis conducted under the European Semester for the Country Reports and 
the identification of key challenges. On a country-specific basis, this analysis feeds in the 
CSRs. Since all or a significant subset of the CSRs need to be tackled in the RRPs, RRPs 
are expected to contribute to achieving the SDGs.  

2.1.3. Functioning of the Facility 

National Recovery and Resilience Plans (‘RRPs’) 

To access financial support under the Facility, Member States had to prepare RRPs 
setting  out  a  national  agenda  of  reforms  and  investments  to  be  implemented 
gradually until 31 August 2026. The Commission assessed each plan with a view to 11 
criteria set out in Article 19(3) of the RRF Regulation. Notably, the Commission assessed 
whether  the  plans  contributed  appropriately  to  the  six  pillars  defining  the  scope  of  the 
Facility, whether they met the minimum green and digital targets (respectively 37% and 
20% of the total’s allocation contributing to the green and digital transitions), whether they 
contributed to addressing all or a significant subset of challenges identified in the relevant 

20   See Annex I, II and III of the RRF Regulation. 
21   There is however a possibility to go beyond the 6.8% threshold in exceptional circumstances subject to available 

resources. 

8 

 
 
CSRs issued in the context of the European Semester, whether they ensure that no measure 
does  significant  harm  to  environmental  objectives,  and  whether  they  provide  for  an 
effective  and  efficient  control  system  for  the  protection  of  the  financial  interests  of  the 
Union. Once a RRP is approved by the Council upon proposal by the Commission, the 
plan’s  content  becomes  a  legally  binding  act22  that  includes  the  milestones  and  targets 
against the fulfilment of which payments should be made.  

Payment requests and disbursement process  

The RRF is a performance-based instrument where disbursements are made against 
the satisfactory fulfilment of milestones and targets. Once a Member State has fulfilled 
the milestones and targets of the relevant instalment, as detailed in the respective Council 
Implementing  Decision  (‘CID’),  it  submits  a  duly  justified  payment  request  to  the 
Commission. The Commission then has two months to assess the satisfactory fulfilment 
of the relevant milestones and targets. The Commission’s preliminary assessment is then 
subject to a committee consultation23 followed by a Commission Implementing Decision 
to disburse.  

Reporting framework on the implementation of the RRPs  

With its comprehensive set of milestones and targets, the RRF provides a solid tool 
to monitor outputs and results. The Facility’s monitoring framework corresponds to its 
approach, which links disbursements to the satisfactory fulfilment of concrete milestones 
and targets, as set out in the CIDs. In the context of the European Semester, Member States 
report twice a year on the implementation of milestones and targets to measure the progress 
towards the achievement of reforms and investments.  

The  monitoring  framework  of  the  RRF  also  includes  14  common  indicators  to  be 
reported upon by Member States to track the progress of the Facility24. The common 
indicators were agreed in a delegated act to help monitoring the progress made with the 
implementation  of  the  RRF.  While  bearing  in  mind  the  additional  data  collection  and 
reporting obligations for Member States, the common indicators were chosen to offer a 
condensed  picture  of  the  different  national  RRPs  across  the  six  pillars  of  the  Facility. 
According to the RRF Regulation, the common indicators (described in Box 1) are meant 
to monitor and evaluate the Facility towards the achievement of the general and specific 
objectives.  They  measure  outputs  and  results  (but  not  impacts)  to  the  extent  possible. 

22   Once the Commission concluded a positive assessment of a RRP, it made a proposal for a Council Implementing 
Decision  (‘CID’)  approving  that  assessment.  The  CIDs  include  the  milestones  and  targets  to  be  fulfilled  for 
payments, accompanied by a SWD analysing the content of the respective plan. The Council then endorsed the 
CIDs. 

23   The Economic and Financial Committee (‘EFC’), with the support of the Economic Policy Committee (‘EPC'), 
subsequently provides its opinion on the Commission’s preliminary assessment. The Commission takes the EFC 
opinion into account for the preparation of its implementing decision approving Member States’ payment requests, 
which, as provided for in Article 35 of the RRF Regulation, are adopted under a comitology procedure with the 
involvement of an RRF Committee (composed of representatives of all Member States). 

24   See Commission Delegated Regulation (EU) 2021/2106 of 28 September 2021 on supplementing Regulation (EU) 
2021/241 of the European Parliament and of the Council establishing the Recovery and Resilience Facility by setting 
out  the  common  indicators  and  the  detailed  elements  of  the  recovery  and  resilience  scoreboard,  available  at: 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?toc=OJ%3AL%3A2021%3A429%3ATOC&uri=uriserv%3AOJ.L_.2021.429.01.0083.01.ENG.  

9 

 
 
Unlike  key  performance  indicators  that  are  usually  linked  to  specific  and  measurable 
targets, the RRF common indicators are used for reporting on the progress of the Facility 
as a whole, and most of them are relevant for more than one pillar.  

Box 1: The 14 common indicators under the RRF 

1.  Savings in annual primary energy consumption (pillar 1 and 3) 

2.  Additional operational capacity installed for renewable energy (pillar 1 and 3) 

3.  Alternative fuels infrastructure (refuelling/recharging points) (pillar 1 and 3) 

4.  Population benefiting from protection measures against floods, wildfires, and other climate 

related natural disasters (pillar 1 and 4) 

5.  Additional dwellings with internet access provided via very high-capacity networks (pillar 

2 and 4) 

6.  Enterprises  supported  to  develop  or  adopt  digital  products,  services  and  application 

processes (pillar 2 and 3) 

7.  Users of new and upgraded public digital services, products and processes (pillar 2 and 5) 

8.  Researchers working in supported research facilities (pillar 3) 

9.  Enterprises supported (of which small – including micro, medium, large) (pillar 3) 

10. Number of participants in education or training (pillar 2, 4, 6) 

11. Number of people in employment or engaged in job searching activities (pillar 3 and 4) 

12. Capacity of new or modernised health care facilities (pillar 4 and 5) 

13. Classroom capacity of new or modernised childcare and education facilities (pillar 4 and 6) 
14. Number of young people aged 15-29 years receiving support (pillar 6) 

The Commission publishes a wide array of data on the implementation of the RRPs 
on  the  Recovery  and  Resilience  Scoreboard25.  The  Scoreboard  provides  up-to-date 
information on the disbursements and progress made by Member States, including on the 
fulfilment of milestones and targets disaggregated by Member State and by RRF pillar. It 
also  includes  thematic  analyses  on  the  status  of  the  implementation  of  the  RRF  and 
information on the 100 final recipients receiving the highest amount of RRF funds in each 
of the 27 Member States26.  

2.1.4. Intervention Logic 

The RRF intervention logic frames the purpose, actions, and expected outcomes of 
the Facility. It is presented below in Figure 1 and captures the consecutive steps of the 
RRF from the initial needs to be addressed to the ultimate goals to be achieved. Individual 
Member States’ RRPs comprise measures with a varying thematic focus, in a wide range 
of policy areas, designed to cater for Member States’ specific needs within the common 

25   See https://ec.europa.eu/economy_finance/recovery-and-resilience-scoreboard/index.html.  
26   The Commission also publishes ‘annual reports’ on the implementation of the Facility. Moreover, an interactive 
map on the RRF website displays examples of projects supported by the Facility in the different EU Member 
States, see https://commission.europa.eu/business-economy-euro/economic-recovery/recovery-and-resilience-
facility_en#map. 

10 

 
 
 
overall  frame  of  the  Facility’s  six  pillars.  Given  its  broad  scope  and  large  financial 
envelope, the RRF’s general and specific objectives are defined in broad terms. They do 
not provide the kind of specific and measurable objectives that are typically assigned to 
smaller and  more targeted  programmes within the EU’s budget.  Moreover, they do not 
fulfil the S.M.A.R.T. criteria27. 

The intervention logic of the RRF corresponds to its design: the delivery of financial 
support against the implementation of reforms and investments. The RRF is designed 
to support reforms and investments in the Member States. Progress made on reforms and 
investments is demonstrated by the achievement of milestones and targets of the plans. To 
assess the progress  achieved to  date  in  concrete  and measurable terms, it is  possible to 
precisely assess the financial support disbursed, the number and type of milestones and 
targets fulfilled (which track the implementation progress of the reforms and investments 
supported  by  the  RRF),  and  the  common  indicators  (that  monitor  progress  towards  the 
achievement of the RRF’s general and specific objectives). 

Figure 1: Intervention logic for the RRF mid-term evaluation 

Source: European Commission 

The intervention logic, as outlined in Figure 1, comprises the following elements: 

1)  Needs as described in the RRF Regulation (e.g. recital 6). The extent to which the 

RRF is addressing the needs is assessed under the relevance criterion. 

2)  Objectives as stated in Article 4 of the RRF Regulation. The extent of the RRF’s 
contribution to these objectives is assessed under the effectiveness criterion, while 
the  relation  of  the  RRF  objectives/measures  to  other  instruments  (e.g.  Cohesion 

27   They cannot be considered as specific, measurable, assignable, realistic, and time-related (‘S.M.A.R.T.’). 

11 

 
 
Policy  financing  and  national  instruments)  is  reviewed  under  the  coherence 
criterion. 

3)  Inputs refer to the financial inputs (non-repayable financial support and loans) as 
well as the human resources and administrative processed needed to manage and 
implement  the  RRF.  Issues  related  to  the  disbursements  are  included  in  the 
effectiveness  analysis,  while  cost  and  administrative  issues  are  covered  in  the 
efficiency analysis. 

4)  Outputs  are  defined  as  the  disbursements  performed  and  the  achievements  of 
milestones  and  targets.  These  are  the  first  elements  that  are  assessed  under 
effectiveness. 

5)  Results are emanating from the reforms and investments implemented by Member 
States,  in  accordance  with  the  plans  and  the  objectives  of  the  RRF.  They  are 
discussed in the analysis of effectiveness and coherence (e.g. on the reinforcement 
of investments and reforms). 

6)  Impacts  of the RRF are expected to  be  as wide  as the identified objectives and 
the 
needs.  Given 
implementation  of  the  RRF,  impacts  cannot  be  expected  to  have  significantly 
materialised  yet.  The  analysis  on  effectiveness  includes  considerations  on  the 
contribution of the RRF to the expected impacts. 

this  mid-term  evaluation 

is  performed  early 

that 

in 

7)  External  factors  have  also  affected  the  implementation  of  the  RRF  and  are 

captured in this mid-term evaluation. 

2.2.Point(s) of comparison  

Without decisive and coordinated policy action, the EU economy was facing serious 
risks  of  a  long-lasting  severe  contraction  after  the  COVID-19  outbreak,  risks  of 
investment  being  drastically  cut,  risks  of  a  lasting  loss  in  productive  capacity  and 
employment, risks of financial fragmentation, as well as risks of a distortion of the level 
playing  field  of  the  Single  Market,  which  could  have  led  to  increasing  economic 
divergences  in  the  Union  and  aggravated  Europe’s  long-term  growth  challenges.  The 
financial support needs identified at the time, stemming from investment gaps and equity 
losses, were very large28. 

The  RRF  aimed  at  addressing  these  risks  and  needs  through  a  strategic  and 
coordinated  policy  response  that  provided  large-scale  financial  support  for  public 
investments and reforms. The fact that this response came swiftly and was designed as a 
common EU initiative was significantly different from the more gradual and fragmented 
response to the euro area crisis of 2010. This time, a clear political agreement was reached 
to  react  in  a  decisive  and  coordinated  manner,  to  avoid  a  severe  contraction  of  the  EU 
economy and mitigate the associated risks.  

28   More details in Commission Staff Working Document (SWD(2020) 98 final/2) on identifying Europe's recovery 

needs, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020SC0098(01). 

12 

 
 
As  a  first  possible  point  of  comparison,  EU  Cohesion  Policy  is  being  considered. 
Cohesion Policy is the EU investment tool that is the most comparable in terms of the size 
of its financial support (EUR 543 billion over 2021-2027 period). In addition, Cohesion 
Policy  also  finances  investments  that  support  the  EU’s  economic,  social  and  territorial 
cohesion and links support of investment to an agenda of enabling reforms (previous ‘ex 
ante  conditionalities’  or  ‘enabling  conditions’).  At  the  same  time,  the  Cohesion  Policy 
Instruments are not comparable to the design and management of the RRF. Key novelties 
of  the  RRF  are  the  performance-based  approach,  where  payments  are  made  upon  the 
fulfilment of milestones and targets, and the strong incentives to implement long-standing 
CSRs in the context of the European Semester. 

Hence,  the  main  point  of  comparison  to  assess  the  implementation  and  expected 
impact  of  the  RRF  relates  to  the  counterfactual  situation  of  what  would  have 
happened in its absence. The milestones and targets as well as the related disbursements 
embedded in the RRF’s design provide one point of comparison against which to assess 
its implementation.  

The macro-economic simulations conducted as part of this evaluation aim to illustrate 
ex-ante  the  expected  impact  of  the  RRF  compared  to  a  baseline  or  counterfactual 
characterised by the absence of the RRF or NGEU. The models consider the impact on 
EU  GDP  that  can  be  attributed  to  the  investments  financed  by  the  RRF,  as  well  as  the 
consequences of reduced interest rate spreads on sovereign bonds.  

Integrating up-to-date information on loan requests, inflation, and expected spending 
profiles,  the  simulations  with  the  Commission’s  QUEST29  model  suggest  sizable 
macroeconomic effects of NGEU investment30. The model’s results show that NGEU31 
has  the  potential  to  increase  EU  real  GDP  by  up  to  1.4%  in  2026  above  a  no-NGEU 
scenario (Figure 2a)32 According to the simulations, the peak GDP effect for the EU would 
materialise in 2026. The model simulations also suggest a sizeable, short-run increase in 

29   QUEST is the global macroeconomic model that the Directorate General for Economic and Financial Affairs (DG 
ECFIN) uses for macroeconomic policy analysis and research. It is a structural macro-model in the New-Keynesian 
tradition  with  rigorous  microeconomic  foundations  derived  from  utility  and  profit  optimisation  and  including 
frictions in goods, labour and financial markets. For further information on DG ECFIN’s QUEST model, see Annex 
II for further information or see https://economy-finance.ec.europa.eu/economic-research-and-databases/economic-
research/macroeconomic-models/quest-macroeconomic-model_en. 

30   To  estimate  the  macroeconomic  impact  of  the  RRF,  the  European  Commission  has  produced  stylised  ex-ante 
assessments  of  the  macroeconomic  impact  of  NGEU  investment.  These  model  simulations  are  not  an  ex-post 
evaluation of the actual impact, but rather an ex-ante model prediction based on stylised assumptions. Nonetheless, 
the simulations presented here integrate up-to-date information on loan requests, inflation, and expected spending 
profiles. They focus on investments as the macroeconomic effects of structural reforms is much more challenging 
to  model.  For  further  information,  see  in  particular,  Pfeiffer  P.,  J.  Varga  and  J.  in  't  Veld  (2023)  Quantifying 
spillovers of coordinated investment stimulus in the EU, Macroeconomic Dynamics (27), p. 1843–1865. See also 
the  ECFN  Discussion  Paper  (2021):  https://economy-finance.ec.europa.eu/publications/quantifying-spillovers-
next-generation-eu-investment_en. 

31   The  QUEST  model  results  have  been  computed  based  on  NGEU  and  not  RRF  investments.  However,  the 
investments (loans and non-repayable support) based on the RRF make up for around 90% of NGEU investments. 

32   Please see Annex II for a detailed discussion of the assumptions and model specifications. 

13 

 
 
EU employment (by up to 0.8%). Moreover, the results yield persistently higher real wages 
in the medium term, reflecting potential productivity gains of productive investment33.  

The  estimated  results  of  the  NiGEM34  model  used  in  the  evaluation  study  broadly 
confirm these findings, albeit with some differences due to a different model design. 
Overall,  both  modelling  approaches  find  a  substantially  positive  economic  impact  of 
NGEU/RRF. The NiGEM analysis additionally assesses the effects of a reduction spreads 
and government borrowing costs, which is a further benefit of the RRF. At the same time, 
the productivity gains of public investment appear to be lower in the NiGEM model (partly 
due to the model’s assumptions) and below those reported by Ramey (2021)35.  

Quantitatively, the results of the NiGEM model suggest that, as a result of the RRF 
disbursements, EU GDP was 0.4 per cent higher in 2022 than it would have been in 
the absence of RRF spending. RRF disbursements had stronger effects in the Southern 
and Eastern Member States than in the Northern and Western ones with relatively higher 
levels of GDP. The initial disbursements lowered unemployment in the European Union 
by around 0.2 percentage points relative to what it would have been in the absence of the 
RRF.  

The importance of positive cross-country spillovers  and reductions in interest rate 
spreads  are  central  to  these  overall  findings.  The  simultaneous  implementation  of 
investment  by  all  Member  States  generates  an  added  value  for  the  EU  that  amounts  to 
between one-fourth and one-third of the total impact of the RRF (hereafter referred to as 
spillovers). These positive spillover effects have shown in the QUEST assessments and are 
also  relevant  in  the  NiGEM  simulations.  Moreover,  the  NiGEM  estimations  yield  that 
reducing spreads has been an important positive side effect, which helped mitigate risks of 
financial  fragmentation  at  the  time  of  the  COVID  shock  (for  details,  see  section  4.4.3. 
regarding the impact on spreads). 

33   Note that because the simulations focus on public investment (without accompanying labour-market reforms), the 
employment  effects  are  relatively  short-lived  and  real  wage  increases  reflect  most  medium  and  long-run  labour 
market benefits in the simulations. By contrast, reforms targeting labour markets and increasing participation, which 
are included in numerous RRPs, can lead to large employment gains in the medium and long run. 

34   The National Institute Global Econometric Model (or ‘NiGEM’) is a global macroeconomic model developed and 
maintained  by  the  National  Institute  of  Economic  and  Social  Research.  For  further  information,  see 
https://www.niesr.ac.uk/nigem-macroeconomic-model.  

35   As acknowledged in the evaluation report, the long-run GDP gains from government investment multipliers appear 
to be below the QUEST estimates, partly because government investment is “treated as ‘consumption’ and so does 
not add to the economy’s capital stock, which is the main way that government investment raises GDP in the long 
run” (see page 21 of the supporting study). On the multiplier effects of government investment, see also Ramey, V. 
(2021) ‘The Macroeconomic Consequences of Infrastructure Investment’ in Glaeser, E.L., and Poterba, J.M. (Eds.), 
Economic Analysis and Infrastructure Investment, pp. 219-268. 

14 

 
 
 
 
 
 
Figure 2: GDP effects (in % of a no-NGEU scenario), QUEST model scenarios 

a. EU GDP Dynamics, % of GDP 

b. Peak GDP effects, % of GDP 

Notes: All results are expressed in per cent deviation from a no-NGEU scenario. In the left panel (a), the blue line reports 
real EU GDP effects in the benchmark scenario, while the red line depicts the low-productivity scenario. The right panel 
(b) depicts the respective peak GDP effects for each country. Blue (red) bars report GDP effects in the benchmark (low-
productivity) scenario.  
Source: European Commission 

With  its  allocation  key,  the  RRF  was  designed  to  support  lower-income  and more 
vulnerable Member States, which had also been hit the hardest by the pandemic. The 
RRF’s  allocation  of  funding  thus  helps  counteract  economic  divergence,  fostering 
economic  stability  and  growth  where  it  is  most  needed.  Given  the  allocation  key,  the 
QUEST simulations indicate that Member States with below-average GDP per capita are 
expected  to  experience  the  largest  boost  to  GDP  levels  because  of  the  significant  RRF 
investments (see Figure 2b). For the benchmark (high productivity) model calibration, the 
increase in output reaches almost 4.5% in Greece, more than 4% in Croatia, and around 
3.5% in Spain and Bulgaria compared to the EU average impact of 1.4%. The model-based 
analysis does not explicitly cover reforms, which are expected to have a long-term positive 
impact and can further lay the groundwork for long-term economic convergence within 
the EU36. 

The  ex-ante  macroeconomic  simulations  also  predict  that  the  simultaneous 
implementation of the RRF by all Member States generates sizeable positive spillover 
effects, leads to economic convergence and is helping to reduce unemployment. In line 
with  the  estimates  based  on  QUEST37,  the  absence  of  joint  and  coordinated  action 
(counterfactual) would have substantially reduced the average GDP impact (see Figure 3). 
While  all  Member  States  are  estimated  to  benefit  from  sizable  cross-border  spillover 
effects because of rising demand across the integrated EU economy, the joint investment 
impulse from the RRF is also supporting the upward economic convergence in the EU. 
The results predict that Member States with below-average GDP specifically gain from 

36   See Pfeiffer, P., Varga, J, and in ‘t Veld, J. (2023) Unleashing Potential: Model-Based Reform Benchmarking for 
EU  Member  States,  available  at:  https://economy-finance.ec.europa.eu/publications/unleashing-potential-model-
based-reform-benchmarking-eu-member-states_en. 

37   See Pfeiffer, P., Varga, J, and in ‘t Veld, J. (2023) Unleashing Potential: Model-Based Reform Benchmarking for 
EU  Member  States,  available  at:  https://economy-finance.ec.europa.eu/publications/unleashing-potential-model-
based-reform-benchmarking-eu-member-states_en. 

15 

 
 
 
 
these spillover effects, as they spur enhanced economic activity and cross-border trade. 
This  analysis  is  reinforced  by  the  simulations  undertaken  using  the  NiGEM  model.  It 
shows that the collective effect on EU GDP is greater than the sum of the direct effects of 
RRF spending if each Member State (counterfactually) implemented the investments on 
its  own.  The  NiGEM  simulations  also  suggest  that  the  initial  disbursements  lowered 
unemployment in the European Union by around 0.2 percentage points relative to what it 
would have been in the absence of the RRF.  

Figure 3: GDP effects (in % from a no-NGEU scenario), spillover effects 

a. High productivity scenario, % of GDP 

b. Low productivity scenario, % of GDP 

Notes: All results are expressed in per cent deviation from a no-NGEU scenario. Blue bars show simulation results from 
unilateral  plans  (counterfactually  assuming  that  only  one  Member  State  implements  the  investment  plan  at  a  time). 
Spillover (red) is defined as the difference of the coordinated simultaneous NGEU stimulus in all Member States and the 
standalone simulations of the national plans. The left (a) and right (b) panels depict the benchmark and low-productivity 
scenarios, respectively. 
Source: European Commission 

RRF loans, if used to finance additional projects, are estimated to contribute to the 
positive  real  GDP  impact.  These  gains  are  largest  for  Member  States  with  significant 
amendments to loan requests (as of 2023), while all Member States can benefit from other 
Member States’ investment through spillover effects. 

The RRF’s cumulated long-run impact on GDP can be expected to exceed the total 
disbursed  RRF  funds.  According  to  DG  ECFIN’s  model-based  macroeconomic 
simulations38, the (undiscounted) cumulative impact on EU GDP of NGEU budget39 can be 
about three to six times as large in the long run, depending on the productivity effects of 
RRF investment. The long-run benefits of the RRF are confirmed by the supporting study, 
whose NiGEM analysis suggests that the cumulative impact on EU GDP by 2041 of the 
RRF funds disbursed up to end July 2023 is almost twice as large as the value of these 
disbursed funds. The study further suggests that  the cumulative impact  on EU GDP by 

38   Pfeiffer, P., Varga, J., in’t Veld, J. (2023) Quantifying spillovers of coordinated investment stimulus in the EU, 
https://www.cambridge.org/core/journals/macroeconomic-

at: 

Cambridge  University  Press, 
available 
dynamics/article/quantifying-spillovers-of-coordinated-investment-stimulus-in-the-
eu/FFCCAAA20BD98AC50A93A4F24562EAD4. 

39   NGEU budget considered in the simulations is around EUR 700 billion. 

16 

 
 
 
 
2041 of the entire RRF package of non-repayable support and loans is expected to exceed 
twice the total RRF funds40. 

It  is  important  to  note  that  the  overall  macroeconomic  impact  calculated  by  the 
simulations depends on the assumptions on the productivity effects and additionality 
of  the  financed  investment  projects.  Notably,  the  macroeconomic  impact  could  be 
considerably smaller if investment projects yielded lower productivity gains. In the low-
productivity scenario of the QUEST model, the simulated EU-wide GDP gains are smaller 
(see Figure 3b). While sizeable growth effects remain, the changes across assumptions are 
noteworthy (as reflected in the estimated multipliers shown in Annex II). For the purposes 
of modelling and as a stylised simplification, the simulations assume that Member States 
utilise  all  non-repayable  support  (100%)  and  half  of  loans  (50%)  for  additional  public 
investment. The assumption of reduced loan additionality reflects a conservative approach 
taken in the analysis (for details, please see Annex II). Similarly, the GDP effects could 
also be smaller in case of lower additionality of non-repayable support since, in this case, 
not all resources would be used for additional public investment41.  

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

While  the  RRF  was  established  during  the  COVID-19  pandemic  to  help  Member 
States recover faster and become more resilient, its implementation is taking place in 
a constantly evolving context. Nearly a year after the entry into force of the RRF, the 
international context experienced another radical change following Russia’s illegal war of 
aggression against Ukraine. This caused renewed pressures on supply chains as well as on 
global energy and food markets, which to a large extent resulted in high levels of inflation, 
with the European Union being particularly affected. These external factors have had an 
impact on the implementation of the RRF, both as concerns implementation speed and the 
need to use the Facility to tackle emerging challenges. The REPowerEU Plan, presented 
by the Commission in May 2022 as the EU’s response to the energy crisis, paved the way 
for an amendment of the RRF Regulation less than two years after its entry into force. The 
RRF became a key financial tool to deliver on the REPowerEU objectives. It increased the 
amount of EU funds made available to the Member States through the RRF, and enabled 
Member States to adjust their RRPs by putting forward additional reforms and investments 
to  rapidly  phase-out  the  EU’s  dependence  on  Russian  fossil  fuels,  accelerate  the  clean 
energy transition, support the reskilling of the workforce, and address energy poverty.  

This  section  describes  how  the  European  economy  and  the  RRF  implementation  have 
evolved over the evaluation period and presents the state of play to date.  

40   See page 215 of the supporting study. 
41   QUEST  ex-ante  simulations  estimate  that  the  impact  on  EU  GDP  is  roughly  proportional  to  the  assumed 
additionality. The additional investment stimulated by the RRF could be lower than assumed due to the short period 
allocated  for  implementation  and  the  overlap  with  projects  fundable  by  Cohesion  Policy  instruments.  In  an 
alternative  scenario  where  only  25%  (Northern  and  Western  Europe)  and  60%  (other  Member  States)  of  non-
repayable support and loans were spent on additional investment, the GDP gains would be reduced by a little over 
a quarter (based on simulations with NiGEM). This alternative scenario is presented and discussed in the supporting 
study. 

17 

 
 
3.1. Economic developments since the start of the RRF 

As the RRF’s general objective is to promote the Union’s economic, social and territorial 
cohesion, the way in which the EU economy developed since the COVID-19 pandemic 
crisis provides an important context for the evaluation.  

Following a steep fall in economic activity in the first half of 2020 due to pandemic-
related  restrictions,  a  vigorous  and  synchronised  economic  rebound  started  in  the 
second half of 2020. The robust rebound in economic activity brought the EU economy 
back to its pre-pandemic output level (fourth quarter of 2019) in the third quarter of 2021. 
By the end of 2022, the volume of EU output was 3.2% higher compared to pre-pandemic 
levels, while the EU’s aggregate public investment-to-GDP ratio is expected to increase 
from 3.0% in 2019 to 3.3% in 202342. In contrast with previous macroeconomic shocks, 
public investment hence remained robust during the COVID-19 pandemic and the energy 
crisis. 

The resilience of the EU economy was tested again following Russia’s unprovoked 
aggression against Ukraine. Russia’s aggression against Ukraine exacerbated the supply-
side disruptions that had started to push up global commodity prices in 2021. Due to its 
geographical proximity to the war and heavy reliance on gas imports from Russia, the EU 
economy was expected to fall into a recession in winter 2022-2023. While this recession 
was avoided by a margin, the economic momentum slowed down significantly since the 
end of 2022. Based on the Commission's Winter 2024 interim Forecast, the conditions for 
a gradual pick-up in economic activity are still in place43. 

3.2. State of play of the RRF implementation 

3.2.1. Adoption of RRPs and operational documentation 

At the half-way point, the implementation of the Facility is under way in all Member 
States. The RRF Regulation entered into force on 12 February 2021. In 2021 and 2022, 
the Commission supported Member States to put forward ambitious plans with clear and 
realistic milestones and targets to monitor their progress during the implementation and 
was in close contact with them to conduct a comprehensive assessment of each plan. The 
Commission assessed each plan in a consistent and transparent manner, following the 11 
criteria  set  out  in  Article  19(3)  of  the  RRF  Regulation.  With  this  assessment,  the 
Commission has ensured that the measures included in Member States’ RRPs contribute 
to meeting the objectives of the Facility44.  

42   See  European  Economic  Forecast 

https://economy-
finance.ec.europa.eu/economic-forecast-and-surveys/economic-forecasts/winter-2024-economic-forecast-delayed-
rebound-growth-amid-faster-easing-inflation_en.  

–  Winter 

available 

interim, 

2024 

at: 

43   See  European  Economic  Forecast 

https://economy-
finance.ec.europa.eu/economic-forecast-and-surveys/economic-forecasts/winter-2024-economic-forecast-delayed-
rebound-growth-amid-faster-easing-inflation_en.  

–  Winter 

available 

interim, 

2024 

at: 

44   For  further  information,  see  Report  from  the  Commission  to  the  European  Parliament  and  the  Council  on  the 
final),  available  at: 

the  Recovery  and  Resilience  Facility 

implementation  of 
https://commission.europa.eu/system/files/2022-03/com_2022_75_1_en.pdf.  

(COM(2022)  75 

18 

 
 
By December 2022, the positive assessment of all 27 Member States’ initial RRPs had 
been proposed by the Commission and adopted by the Council. The adoption timeline 
varied  across  Member  States,  with  the  first  CID  adopted  in  July  2021  and  the  last  in 
December  2022.  The  median  duration  between  the  submission  of  original  RRPs  by 
Member States and the adoption of CIDs by the Council was 70 calendar days, although 
the assessment for the plans submitted by Bulgaria, Hungary, Poland, and Sweden took 
significantly longer. Information on the dates of submission of RRPs and adoption of CIDs 
of each Member State is provided in Annex VI. 

Financing  agreements,  (where  relevant) 
loan  agreements,  and  operational 
arrangements also needed to be concluded with each Member State. The financing and 
loan  agreements  define  the  rights  and  obligations  of  the  parties.  This  includes  the 
protection of the financial interests of the Union, requirements for Member States’ control 
systems  and  a  commitment  of  the  financial  contribution  and  of  the  loan  support.  The 
Commission also concluded operational  arrangements with most Member States, which 
further specify the modalities for monitoring and cooperation, as well as the verification 
mechanism for each milestone and target (discussions are still ongoing with two Member 
States45). The signing of operational arrangements is a pre-requisite for submitting a first 
payment request. 

3.2.2. REPowerEU and amendment of the RRF Regulation 

The amended RRF Regulation, integrating revisions related to REPowerEU, entered 
into force in March 2023. The amendments provide additional financial support for new 
or  scaled-up  reforms  and  investments  dedicated  to  diversifying  energy  supplies  (in 
particular gas imports), increasing energy savings, accelerating the clean energy transition 
and ultimately increasing the resilience, security and sustainability of the Union’s energy 
system. Corresponding REPowerEU objectives were also introduced46. 

The amendments to the RRF Regulation also strengthened transparency by requiring 
Member  States  to  publish  data  on  the  100  final  recipients47  receiving  the  highest 
amount of funding for the implementation of measures under the RRF. Further information 
is provided in Section 3.3.1. below. 

3.2.3. Revisions of RRPs and submission of REPowerEU chapters 

The external factors related to the war in Ukraine, energy crisis, high inflation and 
supply chain disruptions impacted the implementation of the RRPs. Faced with cost 
increases,  supply  chain  shortages,  uncertainty  and  the  need  to  divert  administrative 
resources  to  tackle  external  emergencies,  Member  States  found  that  they  could  not 
implement  some  of  the  measures  as  initially  planned  in  their  RRPs.  This  impacted  the 

45   By 1 February 2024, the Commission has concluded operational arrangements with all Member States but two (the 

Netherlands and Hungary). 

46   See Article 21c of the RRF Regulation. 
47  

In the context of the RRF, a final recipient is understood as the last entity receiving funds under the RRF that is not 
a contractor or a subcontractor, for example, citizens, regional or local authorities, or SMEs, and as such can be 
either a legal or a natural person. 

19 

 
 
speed  of  implementation  of  the  Facility  and  generated  a  need  to  introduce  targeted 
revisions to the RRPs (under Article 21 of the RRF Regulation). These revisions came on 
top of the revisions related to the updated maximum contribution (see Section 2).  

By 1 February 2024, all Member States had submitted a request to modify their RRPs 
and 23 had also submitted a REPowerEU chapter (Table 1). 31 modified RRPs, 23 of 
which  including  REPowerEU  chapters,  were  assessed  by  the  Commission  and  then 
adopted by the Council (Table 1). 

Table 1: State of play on the submission of modified RRPs and REPowerEU chapters by 1 
February 2024 

E
B

G
B

Z
C

K
D

E
D

E
E

E
I

L
E

S
E

R
F

R
H

T
I

Y
C

V
L

T
L

U
L

U
H

T
M

L
N

T
A

L
P

T
P

O
R

I
S

K
S

I
F

E
S

27 plans approved 
by the Commission 
and adopted by the 
Council 
31 revised plans 
submitted to the 
Commission 
23 revisions 
including a 
REPowerEU 
chapter 
31 revised plans 
assessed by the 
Commission 
31 revised plans 
adopted by 
Council 
Source: European Commission 

  2x 

  2x 

  2x 

  2x 

  2x 

  2x 

  2x 

  2x 

  2x 

  2x 

  2x 

  2x 

3.2.4. Submission and assessment of payment requests  

By 1 February 2024, the Commission received 54 payment requests from 24 Member 
States and disbursed close to EUR 225 billion. This figure includes EUR 157.2 billion 
disbursed  upon  the  submission  of  payment  requests  and  satisfactory  fulfilment  of 
milestones  and  targets,  EUR  56.6  billion  in  RRF  pre-financing  granted  to  21  Member 
States  until  31  December  2021,  and  EUR  10.4  billion  of  REPowerEU  pre-financing 
disbursed to 21 Member States between December 2023 and 1 February 2024 (see next 
paragraphs). EUR 144.0 billion of the total amount disbursed to Member States concern 
non-repayable support and EUR 80.2 billion concern loans. Table 2 provides an overview 
of the submission of payment requests by the Member States and the corresponding total 
disbursements  by  the  Commission,  covering  both  non-repayable  support  and  loans48, 

48   RRF loans were disbursed to Greece on 09/08/2021 (EUR 1.7 billion in pre-financing), on 08/04/2022 (EUR 1.8 
billion), on 19/01/2023 (EUR 1.8 billion) and on 28/12/2023 (EUR 1.9 billion); to Cyprus on 09/09/2021 (EUR 
26.0 million in pre-financing); to Italy on 13/08/2021 (EUR 15.9 billion in pre-financing), on 13/04/2022 (EUR 11 
billion), on 08/11/2023 (EUR 11 billion), on 09/10/2023 (EUR 8.5 billion), and on 28/12/2023 (EUR 14.5 billion); 
to Portugal on 03/08/2021 (EUR 350.9 million in pre-financing), on 09/05/2022 (EUR 609 million), on 08/02/2023 
(EUR 108.8 million), and on 28/12/2023 (EUR 585.2 million); to Romania on 13/01/2022 (EUR 1.9 billion in pre-
financing),  on  27/10/2022  (EUR  789.7  million)  and  on  29/09/2023  (EUR  893.3  million);  and  to  Slovenia  on 
28/12/2023 (EUR 310.0 million). In addition, loans were disbursed to the following Member States as part of pre-
financing relating to REPowerEU funds under the RRF: Belgium on 25/01/2024 (EUR 43.0 million), Croatia on 

20 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
following a positive assessment of the milestones and targets covered by the respective 
payment request. 

Pre-financing  for  the  initial  RRPs  was  disbursed  to  all  requesting  Member  States 
whose plans were adopted by the legal deadline of 31 December 2021. To ensure that 
the financial support provided by the RRF was frontloaded in the aftermath of the COVID-
19 crisis, Member States could request up to 13% of their total financial allocation as up-
front payment in the form of so-called ‘pre-financing’. This was however only possible 
where the relevant RRP was adopted by the Council before the deadline of 31 December 
2021,  as  set  in  the  RRF  Regulation49.  The  disbursement  of  this  pre-financing  was  not 
directly linked to the fulfilment of milestones and targets, unlike subsequent disbursements 
that are conditional upon the fulfilment of the relevant milestones and targets. The amounts 
disbursed under pre-financing are deducted over time from regular payments to Member 
States. Any potentially remaining amount can be recovered by the Commission at the end 
of the Facility’s lifetime, including if the Member State does not fulfil the requirements 
established in the CID. All Member States whose initial plans were adopted by end-2021, 
except Ireland, requested and received pre-financing, which amounted to EUR 56.6 billion 
(see Table 2 below). Pre-financing payments were executed within six business days after 
the signing of the Financing (and/or Loan) Agreements (where relevant), and well ahead 
of the 2-month period mentioned in the RRF Regulation50. Two Member States for which 
no  payment  request  has  been  processed  yet  (Belgium  and  Finland)  have  nonetheless 
received RRF funding, in the form of pre-financing. As the RRPs submitted by Bulgaria, 
Hungary, the Netherlands, Poland and Sweden were adopted after the legal deadline, those 
five Member States were unable to request pre-financing for their initial plans.  

By 1 February 2024, EUR 10.4 billion was disbursed as REPowerEU pre-financing 
to the 21 Member States that requested it (see Table 2 below). In the same spirit as the 
2021 round of pre-financing and to ensure that financial support is frontloaded to better 
respond  to  the  energy  crisis,  Member  States  that  modified  their  RRPs  to  include  a 
REPowerEU chapter  had the possibility to  request  up to  20%  of the additional funding 
requested to finance their REPowerEU measures until the end of 202351. 21 Member States 
requested  and  received  REPowerEU  pre-financing.  Bulgaria,  Germany,  Ireland  and 
Luxembourg  are  not  eligible  for  REPowerEU  pre-financing  since  their  REPowerEU 
chapters  were  not  adopted  by  the  Council  by  end-2023  –  as  they  were  still  under 
preparation. The Netherlands and Sweden did not request any REPowerEU pre-financing. 

Progress  in  RRF  implementation  is  underway  in  all  Member  States,  but  with 
differences.  While  some  Member  States  are  progressing  fast  with  the  roll-out  of  their 
payment  requests,  others  are  facing  diverse  challenges.  Hungary,  the  Netherlands,  and 

25/01/2024 (EUR 529.9 million), Spain on 25/01/2024 (EUR 340.0 million), Hungary on 28/12/2023 (EUR 779.5 
million), Lithuania on 28/12/2023 (EUR 109.8 million), and Poland on 28/12/2023 (EUR 4.5 billion). 

49   See Article 13 of the RRF Regulation. 
50   See European Commission (2022) Report from the Commission to the European Parliament and the Council on the 
implementation of the  RRF  (COM(2022) 75  final),  available  at:  https://commission.europa.eu/system/files/2022-
03/com_2022_75_1_en.pdf.  

51   See Article 21d of the RRF Regulation. 

21 

 
 
Sweden have not yet submitted a payment request to the Commission. For Hungary and 
Poland, the authorities need to take necessary steps to implement the milestones related to 
the protection of the financial interests of the Union – no regular payment under the RRF 
is possible without the fulfilment of these milestones. In contrast, eight52 Member States 
have submitted three or more payment requests. 

Table 2: State of play on implementation of RRF payment requests, by 1 February 2024  

E
B

G
B

Z
C

K
D

E
D

E
E

E
I

L
E

S
E

R
F

R
H

T
I

Y
C

V
L

T
L

U
L

U
H

T
M

L
N

T
A

L
P

T
P

O
R

I
S

K
S

I
F

E
S

  ▲ 

  ■ 

* 

  ● 

  ● 

  ● 

  ▲ 

  ▲ 

  ▲ 

  ▲ 

27 plans approved 
by the Commission 
and adopted by the 
Council 
21 pre-financing 
disbursed before 
31 December 2021 
and excluding 
REPowerEU pre-
financing (EUR 
56.6 billion) 
21 REPowerEU 
pre-financing 
disbursed (EUR 
10.4 billion) 
25 Operational 
Arrangements 
signed 
54 payment 
requests submitted 
to the 
Commission, 
including loans 
where relvant 
36 payments 
disbursed (EUR 
157.2 billion) 
Note: * No pre-financing was requested by Ireland. ▲ As prerequisite for pre-financing, the CID had to be adopted by 
31 December 2021. ● Bulgaria, Germany, Ireland, and Luxembourg have not submitted a REPowerEU chapter and are 
thus not eligible for REPowerEU pre-financing. ■ The Netherlands and Sweden did not request any REPowerEU pre-
financing. 
Source: European Commission 

  3x  4x  3x  4x  5x  2x  2x  2x 

  3x  3x  2x  3x  4x 

  3x  3x  2x  4x 

  3x  2x  2x  3x 

  2x  2x  2x 

  2x 

  2x 

  ● 

  ■ 

By 1 February 2024, 1,153 milestones and targets out of a total of 6,266 to be achieved 
by 2026 had been assessed as satisfactorily fulfilled and an additional 1,238 had been 
reported  by  Member  States  as  completed.  This  represents  a  progress  rate  of 
approximately 38% of the total number of milestones and targets under the RRF (with 18% 
of  all  milestones  and  targets  assessed  as  satisfactorily  fulfilled).  Around  75%  of  the 
milestones and targets planned to be achieved by end 2023  were either assessed by the 
Commission  as  satisfactorily  fulfilled  or  reported  as  completed  by  the  Member  States. 
Furthermore,  on  1  February  2024,  the  Commission  is  in  the  process  of  assessing  18 
payment  requests  that,  if  positively  assessed,  will  significantly  increase  the  amount  of 
milestones and targets satisfactorily fulfilled by Member States in the near future. Of the 
1,153 milestones and targets satisfactorily fulfilled, 632 contribute to reform-related RRF 
measures and 521 to investment-related measures. Italy, Spain, and Croatia have fulfilled 

52   The eight Member States are Greece, Spain, France, Croatia, Italy, Portugal, Romania and Slovakia. 

22 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
the highest amounts of milestones and targets, with 178 (out of a total of 527), 121 (out of 
416), and 104 (out of 372) fulfilled milestones and targets, respectively (Figure 4). As the 
Commission’s  assessment  is  still  ongoing  for  the  first  payment  requests  submitted  by 
Belgium, Ireland, Poland, and Finland, no information is available on fulfilled milestones 
and targets for these Member States yet. The number of milestones and targets fulfilled by 
Bulgaria,  Czechia,  Denmark,  Estonia,  Spain,  France,  Croatia,  Italy,  Cyprus,  Latvia, 
Lithuania, Malta, Romania and Slovakia does  not  yet  reflect  the milestones and targets 
under assessment on 1 February 2024, following the payment requests submitted by these 
Member States. No milestone or target initially assessed as satisfactorily fulfilled by the 
Commission has subsequently been reversed by a Member State so far. Further details on 
Member States’ progress in fulfilling milestones and targets for reforms and investments 
is provided in Figure 4, and a breakdown across all six policy areas is included in Annex 
VI.  

Figure 4: Number of fulfilled milestones and targets for reforms and investments, per 
Member State53  

Source: Recovery and Resilience Scoreboard 

53   The information provided in this Figure reflects the latest RRPs for Estonia, France, Luxembourg, and Slovakia and 
the RRPs following the first revisions for Germany (adopted on 14/02/2023), Ireland (adopted on 14/07/2023), Italy 
(adopted  on  19/09/2023),  and  Finland  (adopted  on  14/03/2023).  It  does  not  reflect  the  latest  plans  adopted  for 
Belgium,  Bulgaria,  Czechia,  Denmark,  Germany  (following the  second  revision),  Ireland  (following  the  second 
revision), Greece, Spain, Croatia, Italy (following the second revision), Cyprus, Latvia, Lithuania, Hungary, Malta, 
the Netherlands, Austria, Poland, Portugal, Romania, Slovenia, Finland (following the second revision) and Sweden 
as data for these Member States was not yet fully available. 

23 

0 0 00  02002 03003 0400Reforms: Number of milestones and targets in RRPsInvestments: Number of milestones and targets in RRPsReforms: Number of milestones and targets assessed by the Commission as fulfilledInvestments: Number of milestones and targets assessed by the Commission as fulfilled 
 
Member States report good progress in implementing their RRPs across all six pillars 
(Figure  5).  Self-reported  progress  by  Member  States,  which  takes  place  twice  a  year, 
indicates that the vast majority of milestones and targets due by October 2023 are either 
fulfilled or reported as completed (Figure 5). The progress of upcoming milestones and 
targets is also encouraging, with a significant number of milestones and targets reported as 
on track or already completed (Figure 5). When providing explanations in the bi-annual 
reporting  for  non-completion  or  delays,  Member  States  reported  difficulties  in  meeting 
deadlines for signatures of contracts and/or unexpected time lags in construction works. In 
general,  Member  States  did  not  consistently  provide  detailed  explanations  for  non-
completion or delays and did not generally consider these delays as substantial54. 

Figure 5: Progress of milestones and targets, per RRF pillar 

Note:  Milestones  and  targets  which  have  already  been  assessed  as  satisfactorily  fulfilled  by  the  Commission  in  the 
context of a payment request have the status  ‘fulfilled’. The progress status of each backward-looking milestone and 
target (i.e. those planned to be achieved up to the quarter before the reporting date) can be either ‘completed’ or ‘not 
completed’. The status of forward-looking milestones and targets (i.e. those planned to be achieved in the quarter of the 
reporting date and the three following quarters) milestones and targets can be ‘completed’, ‘on track’, or ‘delayed’. 
Source: European Commission. 

A detailed analysis on the speed of disbursements and on the progress in implementing 
milestones and targets by policy area is included in Section 4.1.  

54   See European Commission (2023) Recovery and Resilience Facility Annual Report 2023 (COM(2023) 545 final/2), 
available at: https://commission.europa.eu/publications/recovery-and-resilience-facility-annual-report-2023_en.  

24 

 0 0 3 32  9420 2 929 2 8 202 9     4  4 3 32  23028229 24  423 0 4823 4  88 04   2  9422 0 3 4820 33 4  9382  3 0 2 0  20   282433 3303 2 432    0 00200300400 00 00 00800900InvestmentsReformsInvestmentsReformsInvestmentsReformsInvestmentsReformsInvestmentsReformsInvestmentsReformsPolicies forthe nextgeneration ealth, andeconomic,social andinstitutionalresilienceSocial andterritorialcohesionSmart,sustainableand inclusivegrowthDigitaltransformationGreentransitionFulfilledCompleted (not assessed)Not completed n trackDelayed 
 
 
3.3. Improvements in RRF implementation over the evaluation period 

Since the adoption of the RRF Regulation, the Commission has been in close contact with 
Member States and also with other EU institutions, notably the European Parliament and 
European  Court  of  Auditors  (described  in  Section  3.4.),  to  discuss  implementation 
challenges as they emerged. Against the background of constant dialogue and feedback, 
the  Commission  has  taken  various  steps,  as  described  below,  to  improve  the 
implementation of the Facility within the mandate of the Regulation.  

3.3.1. Increasing transparency on the RRF implementation 

Since  the  establishment  of  the  RRF,  the  Commission  has  provided  a  range  of 
guidance  documents  to  help  Member  States  prepare  their  RRPs55  and  has  further 
clarified how it implements the RRF Regulation and which frameworks it uses to do 
so. In February 202356, the Commission published its framework to assess the fulfilment 
of milestones and targets as well as the methodology to be used to calculate the suspended 
amounts in case of non-fulfilment of a milestone or target. Stakeholders, notably Member 
States authorities, the European Parliament and the European Court of Auditors, broadly 
welcomed  this  step  that  increased  transparency  and  clarified  the  Commission’s 
methodology57.  In  September  202358,  the  Commission  also  published  its  framework  for 
dealing  with  potential  situations  where  milestones  and  targets  initially  assessed  as 
satisfactorily fulfilled by the Commission would subsequently be reversed by a Member 
State. 

Information  on  the  state  of  implementation  of  the  RRF  and  on  final  recipients  is 
continuously being made available. The Commission has set up a website dedicated to 
the RRF – which includes the individual RRPs in dedicated country pages – as well as the 
Recovery  and  Resilience  Scoreboard59  that  provides  real-time  information  on  the 
disbursements and progress made by Member States, as well as additional data, indicators 
and thematic analyses. To further increase the visibility and transparency of the RRF, the 
Commission has launched an interactive map60 of projects supported by the RRF in each 

55   See European Commission (2021) Guidance to Member States – Recovery and Resilience Plans (SWD(2021) 12 

final), available at: https://commission.europa.eu/system/files/2021-01/document_travail_service_part1_v2_en.pdf 
(Part (1/2) and https://commission.europa.eu/publications/guidance-member-states-recovery-and-resilience-plans-
part-2_en (Part 2/2); European Commission (2021) Technical guidance on the application of “do no significant 
harm” under the Recovery and Resilience Facility Regulation (C(2023) 6454 final), available at: 
https://commission.europa.eu/publications/dnsh-technical-guidance-amended-october-2023_en; and European 
Commission (2023) Guidance on Recovery and Resilience Plans in the context of REPowerEU (2023/C 80/01), 
available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52023XC0303%2801%29&qid=1677849385817. 

56   See European Commission (2023) Communication from the Commission to the European Parliament and the 

Council on the Recovery and Resilience Facility: Two years on (COM(2023) 99 final), available at 
https://commission.europa.eu/publications/communication-implementation-recovery-and-resilience-facility-0_en. 

57   See page 79 of the supporting study. 
58   See Report from the Commission to the European Parliament and the Council on the implementation of the 

Recovery and Resilience Facility: Moving forward (COM(2023) 545 final/2) available at 
https://commission.europa.eu/publications/recovery-and-resilience-facility-annual-report-2023_en. 

59   See https://ec.europa.eu/economy_finance/recovery-and-resilience-scoreboard/index.html.  
60   See https://commission.europa.eu/business-economy-euro/economic-recovery/recovery-and-resilience-

facility_en#map.  

25 

 
 
Member  State.  Furthermore,  following  the  entry  into  force  of  the  amended  RRF 
Regulation, the Commission has been publishing the data provided by the Member States 
on the 100 final recipients receiving the highest amount of funding on the Scoreboard. By 
1 February 2024, all Member States have provided corresponding data. 

A series of joint communication activities on  the RRF and 25 Annual RRF Events 
organised  by  22  different  Member  States  have  taken  place.  In  collaboration  with 
Member States, the Commission has organised communication and Annual Events to bring 
together  key  institutions,  stakeholders  (including  social  partners  and  civil  society 
representatives) and recipients of RRF support, among others, to discuss the progress in 
implementing the various projects proposed by Member States in their national RRPs. The 
European Parliament Liaison Offices in the Member States, the European Economic and 
Social  Committee  national  representatives  and  the  Committee  of  the  Regions  are  also 
invited to participate in these events.  

3.3.2. Strengthened robustness of the RRF control framework (audit and control) 

Since  the  inception  of  the  RRF,  the  Commission  has  further  strengthened  the 
robustness  of  the  RRF  control  framework,  including  its  ex-post  audit  work.  The 
Commission  has  notably  increased  the  pace  and  scope  of  system  audits  related  to  the 
protection of the financial interests of the Union. It now also verifies that Member States 
regularly check compliance of RRF funded expenditure within the framework of Public 
Procurement and State Aid rules. 

The RRF control framework61 is tailored to the unique nature of the RRF as an EU 
spending programme and is built upon two main pillars: on the one hand, the legality and 
regularity of transactions, which is the main responsibility of the Commission, and on the 
other hand the protection of the financial interests of the Union, which responsibility lies 
mainly  with  the  Member  States  but  on  which  the  Commission  also  carries  out  specific 
checks.  

Since  the  inception  of  the  RRF,  the  Commission  carried  out  both  ex-ante  controls 
before payments were made and ex-post audits thereafter. By 1 February 2024, the 
Commission  assessed  36  payment  requests  including  over  1,150  milestones  and  targets 
and concluded that all but seven62 milestones and targets had been satisfactorily fulfilled. 
In 2022-2023, the Commission also carried out 1763 risk-based ex-post audits on milestones 
and targets to obtain additional assurance that the information provided by the Member 

61   See  European  Commission 

(2022)  DG  ECFIN  Annual  Activity  Report  2022, 

available 

at: 

https://commission.europa.eu/system/files/2023-06/ECFIN_AAR_2022_en.pdf.  

62   See European Commission’s partially positive preliminary assessment of Lithuania's first payment request under 
the RRF, available at: https://ec.europa.eu/commission/presscorner/detail/en/IP_23_1286, European Commission’s 
partially  positive  preliminary  assessment  of  Romania's  second  payment  request  under  the  RRF,  available  at: 
https://ec.europa.eu/commission/presscorner/detail/en/ip_23_3496., and European Commission’s partially positive 
preliminary 
at: 
https://ec.europa.eu/commission/presscorner/detail/en/ip_23_6827. 
In 2022 and 2023, the Commission carried out ex-post audits on milestones and targets regarding payment requests 
submitted by Austria, Czechia, Denmark, Greece, Spain, France, Croatia, Italy, Luxembourg Portugal, Slovakia, 
and Romania.  

assessment  of  Portugal’s 

third  payment 

request  under 

the  RRF, 

available 

63  

26 

 
 
State was correct. Based on final audit reports issued, the Commission’s audits confirmed 
the  previous  positive  assessments  that  the  relevant  milestones  and  targets  had  been 
satisfactorily fulfilled. 

The Commission also conducted system audits that draw upon information available 
within the Commission as well as in audit summaries, management declarations and 
payment requests submitted by the Member States. In the context of the system audits, 
the Commission checks the procedures in place in Member States to prevent, detect and 
correct fraud, corruption, and conflict of interest, as well as ‘double-funding’ arising from 
the possible simultaneous funding of project-related costs by different EU programmes. In 
the period 2022-2023, the Commission audited all Member States at least once, issuing 
where relevant recommendations with strict implementation deadlines.  

3.4. Inter-institutional scrutiny 

European Parliament Working Groups 

Since the beginning of the RRF implementation, the Commission has closely engaged 
with the European Parliament and the Council. The Commission shares all RRPs and 
modified plans, as well as all preliminary assessments of payment requests, with both the 
European Parliament and the Council in full respect of its inter-institutional obligations. 
This ensures a transparent flow of information with a high level of engagement between 
the institutions throughout the implementation phase.  

The Commission holds regular exchanges to discuss horizontal topics concerning the 
RRF with the European Parliament. Since the setting-up of the RRF, the Executive Vice 
President responsible for an Economy that Works for People and the Commissioner for 
Economy  participated  by  5  February  2024  in  14  high-level  Recovery  and  Resilience 
Dialogues.  Moreover,  the  Commission  engages  regularly  with  the  standing  Working 
Group of the joint ECON-BUDG Committees and participated overall in 33 meetings. In 
addition,  the  Commission  is  invited  on  a  regular  basis  to  various  other  committees  to 
exchange  views  on  matters  related  to  the  RRF,  including  the  REGI,  CONT  and  ENVI 
committees.  

Council 

The  Council  is  involved  at  all  stages  of  the  Facility’s  implementation.  The  Council 
approves  the  ‘Council  Implementing  Decisions’  setting  out  the  reforms  and  investment 
projects to be implemented by the Member State, including the milestones and targets to 
be  fulfilled  for  each  payment  requests,  and  the  financial  contributions  –  based  on  a 
Commission proposal  reflecting the  RRP  of each Member State.  In the context of  each 
payment request, once the Commission has adopted its preliminary assessment regarding 
the  satisfactory  fulfilment  of  milestones  and  targets,  the  Economic  and  Financial 
Committee (‘EFC’), which is composed of senior officials from national administrations 

27 

 
and  central  banks,  subsequently  provides  its  opinion64.  The  Commission  also  provides 
regular updates on the Facility’s implementation to the ECOFIN Council. 

Informal expert group on the implementation of the RRF 

The Commission has also set up an informal expert group to exchange views and good 
practice with Member States on the implementation of the RRF. By 1 February 2024, 
24 meetings of the expert group had taken place. This group provides an important forum 
to discuss cross-cutting aspects on the RRF, among the experts from the Member States as 
well as the Commission. The Council and the European Parliament are invited to observe 
all these meetings. The topics discussed in this format show a great variety and range from 
financial matters to governance and audit and control, as well as issues related to specific 
policy areas. All relevant information from the meetings is published online65. 

Audits undertaken by the European Court of Auditors 

In addition to the audits carried out by the Commission itself, the RRF is scrutinised 
by the European Court of Auditors (‘ECA’), notably through Statement of Assurance 
(‘SoA’) audits, and Performance audits on a number of thematic areas. By 1 February 
2024, the ECA has finalised two SoA audits on the RRF, which aim to assess annually the 
legality and regularity of payments disbursed by the Commission to Member States upon 
satisfactory fulfilment of milestones and targets. The main findings are presented in the 
ECA annual reports of 202166 and 202267. In addition, three performance audits specifically 
dedicated  to  the  RRF  have  been  finalised  as  of  1  February  2024,  namely  on  the 
Commission’s assessment of RRPs, the design of the Commission’s control system for the 
RRF, and on the framework put in place by the Commission to monitor the performance 
of the RRF. Another eight68 ECA audits focusing on the RRF are ongoing and are expected 
to be finalised by end 2024, and while RRF-related matters are also considered in other 
reports. The ECA has also issued a comparative analysis on Cohesion Policy funds and the 
RRF. 

64  

If,  exceptionally,  one  or  more  Member  States  consider  that  there  are  serious  deviations  from  the  satisfactory 
fulfilment of the relevant milestones and targets, they may request the President of the European Council to refer 
the matter to the next European Council. 

65   See https://ec.europa.eu/transparency/expert-groups-register/screen/expert-

groups/consult?lang=en&groupId=3772&fromMeetings=true&meetingId=31814. 

66   Available at https://www.eca.europa.eu/en/publications/annualreports-2021.  
67   Available at https://www.eca.europa.eu/en/publications/AR-2022.  
68   As regards on-going performance audits, eight are currently focusing on the RRF and are expected to conclude in 
2024.  They  cover  inter  alia  the  green  transition  and  digital  transformation  dimensions  of  the  RRF,  the  RRF 
contribution to the rule of law, the absorption of RRF funds, labour market and, separately, business environment 
reforms included in the RRPs, the Member States’ control systems, and the prevention of double funding between 
the RRF, Cohesion Policy and Connecting Europe Facility. Other performance audits and reviews may also touch 
on  the  RRF  or  RRF  supported  measures.  All  ECA  special  reports  are  complemented  by  official  replies  of  the 
Commission, which are public and available on the website of the ECA.  

28 

 
 
4.  EVALUATION FINDINGS (ANALYTICAL PART) 

To what extent was the intervention successful and why?  

4.1. Effectiveness 

This  section presents an assessment of  how successful  the RRF has been, mid-way 
through its lifetime, in progressing towards its specific objective, which is “to provide 
Member States with financial support with a view to achieving the milestones and targets 
of reforms and investments as set out in their recovery and resilience plans”. The section 
then  also  illustrates,  with  the  results  of  specific  case  studies,  how  the  achievement  of 
milestones and targets feeds into the elements of the RRF high-level general objective. 

The  achievement  of  milestones  and  targets  in  and  of  itself  represents  progress 
towards  achieving both the RRF  specific as  well as general  objective, respectively. 
Milestones and targets represent concrete progress made towards the achievement of the 
reforms  and  investments  committed  to  by  Member  States  in  their  RRPs.  This  in  turn 
corresponds to progress towards the achievement of the RRF specific objective which has 
been  construed,  by  design  of  the  instrument,  to  deliver  on  the  RRF  high-level  general 
objective “to promote the Union’s economic, social and territorial cohesion”. Milestones 
and targets follow the different implementation steps of a measure. Each measure (reform 
or  investment)  included  in  Member  States’  RRPs  has  been  selected  on  the  basis  that  it 
fulfils all assessment criteria of the RRPs and is in line with the relevant EU priorities and 
the RRF general objective, while being tailored to Member States’ specific needs. 

Since this is a mid-term evaluation, it is too early to systematically assess the impact 
of the RRF. At the mid-term point of the Facility, and as per the set-up of the RRF, the 
milestones and targets that have been achieved so far often cover initial steps, such as a 
launch of calls for tender or signing of procurement contracts in particular for investments. 
Most  measures  have  not  yet  reached  the  last  milestone  or  target  (i.e.  their  completion) 
which would enable a first evaluation of the results, as defined in the intervention logic 
(i.e. the full  implementation  of the measures included in  the RRP). The milestones  and 
targets due in the second half of the Facility’s lifetime will increasingly cover final steps 
in reform implementation and investment outputs. It is the implementation of these reforms 
and investments, included in the RRPs, that will allow for an assessment of the full impact 
of the intervention.  

Accordingly,  it  is  too  early  to  conclude  on  the  extent  to  which  progress  towards 
milestones and targets has translated into reaching the general RRF objective. This 
section therefore presents the progress made to date in implementation rather than a fully-
fledged impact evaluation. The latter will be possible only ex-post, once the measures are 
fully  implemented  by  the  end  of  2026.  However,  some  telling  examples  of  completed 
reforms  or  investments  are  already  available  and  have  been  analysed  in  specific  case 
studies. It is therefore possible to illustrate how the achievement of milestones and targets 
translates into the implementation of reforms and investments by Member States (results 
in the intervention logic) that are delivering on the RRF general objective.  

29 

 
The most complete available information at this point in time relates to the financial 
support provided (i.e. amounts disbursed by the Commission) and to the achievement 
of milestones and targets (assessed as satisfactorily fulfilled by the Commission when 
assessing  payment  requests).  The  indicative  timeline  for  achieving  the  milestones  and 
targets  and  the  resulting  planned  disbursements  were  determined,  together  with  the 
Member States, in the annex to the Council Implementing Decision approving each plan 
and  in  the  “operational  arrangements”.  This  information  is  publicly  available  and 
referenced on the Recovery and Resilience Scoreboard69. 

4.1.1. Progress towards the RRF specific objective 

The  specific  objective  of  the  Facility  is  to  provide  Member  States  with  financial 
support for the achievement of milestones and targets of reforms and investments, as 
set  out  in  their  RRPs.  Both  the  achievement  of  milestones  and  targets  as  well  as  the 
disbursement of funds represent outputs in the intervention logic (Figure 1) used for the 
evaluation. 

A. Providing financial support to Member States 

i.  RRF disbursements to Member States  

This section presents the progress in disbursing RRF funds in the first three years of 
the Facility’s lifetime (2021-2023). Overall, the RRF has been effective in disbursing 
funds quickly post-crisis, notably thanks to pre-financing. By 1 February 2024, close 
to  EUR  225  billion  has  been  disbursed  under  the  RRF,  including  EUR  157.2  billion 
disbursed  upon  the  submission  of  payment  requests  and  satisfactory  fulfilment  of 
milestones  and  targets,  EUR  56.5  billion  in  RRF  pre-financing  granted  to  21  Member 
States  until  31  December  2021,  and  EUR  10.4  billion  of  REPowerEU  pre-financing 
granted to 21 Member States between December 2023 and 1 February 2024. EUR 144.0 
billion  of the total  amount  disbursed to  Member States concerns non-repayable support 
and EUR 80.2 billion concerns loans. Pre-financing provided fast direct support to Member 
States, playing a stabilising role in the aftermath of the unprecedented economic and social 
shock caused by the COVID-19 pandemic, thereby also helping to kick-start the recovery70. 
Compared  to  the  baseline  scenario  of  no-RRF,  the  RRF  provided  immediate  additional 
fiscal  space.  The  additional  pre-financing  agreed  by  co-legislators  in  the  context  of 
REPowerEU seeks to achieve the same goals. Many stakeholders, notably Member States 
authorities,  interviewed  consider  that  pre-financing  has  been  an  effective  feature  of  the 
RRF: it supports public finances and boosts the progress of the instrument71.  

69   All documents are available on: https://ec.europa.eu/economy_finance/recovery-and-resilience-

scoreboard/country_overview.html?lang=en.  

70   See page 268 of the supporting study. 
71   See pages 48 to 56 of the supporting study. 

30 

 
 
The speed of disbursement is considered as one of the most effective features of the 
RRF72, also in comparison with disbursements made under Structural Funds73. The validity 
of  comparing  disbursement  speed  under  Structural  Funds  with  that  under  the  RRF  is 
however limited. This is because of, first, the larger amount of pre-financing over the total 
allocation  under  the  RRF  to  date,  second,  the  different  disbursement  mechanisms  and, 
third, given that a larger share of reforms compared to investments has been implemented 
during the first years of the RRF implementation, which is therefore not  comparable to 
cohesion funding74. However, overall, the RRF features, with substantial pre-financing and 
payments also linked to preparatory and intermediate steps of measures implemented on 
the ground, have enabled quicker disbursement to Member States than instruments where 
payments have been linked to expenditure already incurred, including Structural Funds, 
and thus have been effective in creating fiscal space in Member States in the aftermath of 
the COVID-19 crisis.  

The speed of disbursement in the first two years of operation of the RRF has followed 
the  indicative  yearly  timetable  for  disbursements  shown  in  the  operational 
arrangements75. Approximately 27% of the RRF budget was paid out via pre-financing 
and  regular  payments  in  the  period  2021-2022,  which  is  almost  aligned  with  what  was 
foreseen at the time of adoption of the plans (28% of budget was planned for the same 
period)76.  Similarly,  Member  States  have  largely  adhered  to  the  planning  of  the  first 
payments  in  2021  and  2022,  requesting  their  payments  at  the  time  initially  foreseen, 
reinforcing close alignment between planned and disbursed financing in the first two years 
of the RRF.  

The revisions of the RRPs and the addition of REPowerEU chapters, in response to 
the war in Ukraine, have impacted the disbursement schedule of RRF funds in 2023, 
creating  delays  between  actual  disbursements  and  initially  planned  disbursements 
for 2023. The first half of the year 2023 has seen a slowdown in the submission of payment 
requests,  with  Member  States  focusing  their  efforts  on  the  revision  of  plans  and  the 
addition of REPowerEU chapters. As a result, many Member States with a payment request 
indicatively planned for the first part of 2023 have pushed back the indicative timing by 
one to three quarters. As detailed in Section 3, the revisions of the RRPs (not only to factor 
in the updated maximum contribution, but also the impact of inflation and supply chain 
disruptions) and the addition of REPowerEU chapters (as a response to the war in Ukraine 
and energy crisis) are the direct consequences of external factors, which have affected the 
implementation of the Facility.  

As  the  revisions  of  the  RRPs  advanced,  the  submission  of  payment  requests 
significantly picked up pace in the second half of 2023. Between May and December 

72   See page 268 of the supporting study. 
73   Zorell,  N.,  and  Tordoi,  S.  (2021)  Towards  an  effective  implementation  of  the  EU’s  recovery  package,  ECB 
https://www.ecb.europa.eu/pub/economic-
available 

Economic 
bulletin/focus/2021/html/ecb.ebbox202102_07~7050ed41dd.en.html.  

Bulletin, 

2/2021 

Issue 

at: 

74   See case study on the functioning of the RRF and other EU funds included in the supporting study. 
75   Evidence in this paragraph is sourced from pages 48 to 54 of the supporting study. 
76   According to the supporting study, see page 52. 

31 

 
 
2023, 26 payment requests were submitted and EUR 60.9 billion disbursed following the 
satisfactory  fulfilment  of  milestones  and  targets.  With  most  revised  RRPs  having  been 
adopted, this catching-up effect is expected to continue as Member States have continued 
to  implement  the measures of their RRP.  For  example,  18 payment requests  have been 
submitted  very  swiftly  after  the  plans’  revisions  and  were  being  assessed  by  the 
Commission in January 2024. It is therefore a challenging, but still an achievable task to 
catch up on the delays experienced in the first half of 2023 in the time available until the 
end-2026 deadline.  

Progress  has  been  made  towards  achieving  the  RRF  specific  objective  despite 
heterogeneous implementation of the RRF across Member States. Within the overall 
progress  in  the disbursement of RRF funds explained above, the situation varies across 
Member States. Notably, to date, three Member States have not yet submitted a payment 
request (Hungary, the Netherlands and Sweden). No pre-financing requests were received 
in 2021 from any of these three Member States, as a result of the late adoption of these 
Member States’ CIDs in 2022, after the legal deadline for pre-financing of 31 December 
2021. Hungary has  however received REPowerEU pre-financing  in  December 2023.  In 
contrast, eight Member States have already submitted three or more payment requests. In 
line with  the performance-based nature of the RRF,  payments can only  be made where 
concrete  progress  towards  the  achievement  of  reforms  and  investments,  and  thereby 
towards the RRF’s specific objective, has been made. 

ii.  Comparison  of  RRF  disbursements  and  RRF-related  Member  States’ 

expenditure 

As expected, in the first years of the RRF, disbursements do not translate immediately 
into actual RRF-related Member States’ expenditure. Figure 6 shows that the Member 
States’  expenditure  for  the  implementation  of  RRF  measures  is  slightly  lower  than  the 
amount disbursed to them under the RRF. The term ‘RRF-related expenditure’ refers to 
the  occurrence  of  all  types  of  costs  for  the  general  government,  for  the  financing  of 
measures  supported  by  RRF  non-repayable  support.  The  data  is  included  in  the 
Commission’s Autumn 2023 Forecast77, building on Member States’ reporting in national 
accounts, which is recorded on an accrual basis, i.e. when the actual expenditure (or other 
costs) takes place and impacts on economic activity78.  

77   Available  at:  https://economy-finance.ec.europa.eu/economic-forecast-and-surveys/economic-forecasts/autumn-

2023-economic-forecast-modest-recovery-ahead-after-challenging-year_en. 

78   This reporting ensures that, in the case of RRF non-repayable support, the recording of revenue follows the statistical 
principle of ‘neutrality on net lending/borrowing’, which is achieved by recording revenue in the same reporting 
period as the underlying expenditure. 

32 

 
 
Figure 6: RRF disbursements, remaining RRF allocation and RRF-related Member States’ 
expenditure in EU-27, in EUR billion 

Source: European Economic Forecast – Autumn 2023, available at: https://economy-finance.ec.europa.eu/economic-
forecast-and-surveys/economic-forecasts/autumn-2023-economic-forecast-modest-recovery-ahead-after-challenging-
year_en. 

The  first  RRF  disbursements  included  pre-financing  payments  that  created  fiscal 
space for Member States. Until 31 December 2021, Member States had the possibility to 
request pre-financing of up to 13% of their initial allocation, which was disbursed without 
any links to the fulfilment of milestones and targets, in order to kick-start the economy. 
Moreover, the performance-based nature of the RRF implies that  the amounts linked to 
instalments do not reflect the underlying costs of the implemented measures. This holds in 
particular  for  reforms  (with  lower  or  no  budgetary  cost)  and  the  preparatory  or 
intermediary  steps  for  both  reforms  and  investments,  such  as  feasibility  studies  and 
contracting/procurement steps, that tend to be concentrated in the earlier instalments of the 
RRPs. This implies that the RRF provided Member States with important fiscal space early 
on79 after the COVID-19 crisis. The expenditure of RRF support is expected to increase 
and  catch  up  with  disbursements  over  the  forecast  horizon.  For  the  EU  as  a  whole, 
expenditure of RRF non-repayable support is set to reach 0.4% of GDP in 2023 (from 0.2% 
in 2021 and 0.3% in 2022), and to stabilise at that level in 2024-2580. 

B. Achievement of milestones and targets  

To assess the progress  achieved in the implementation of reforms and  investments 
supported by the RRF, the analysis first considers milestones and targets.  

79  

In designing the payment profile for each Member State, the Commission ensured that financial incentives are kept 
until the end of the RRF lifetime to deliver on reforms and investments until the end of the period (2026). 
80   European Economic Forecast – Autumn 2023, available at: https://economy-finance.ec.europa.eu/economic-
forecast-and-surveys/economic-forecasts/autumn-2023-economic-forecast-modest-recovery-ahead-after-
challenging-year_en. 

33 

 
 
 
Data related to the progress with milestones and targets builds on (i) self-reported data by 
the Member States providing an indication of implementation progress, as well as on (ii) 
data  on  the  number  of  milestones  and  targets  assessed  as  satisfactorily  fulfilled  by  the 
Commission81. Member States report twice per year on the progress with milestones and 
targets. The Commission assesses the fulfilment of milestones and targets in the context of 
the relevant payment requests, whilst the implementation of milestones and targets covered 
in  subsequent  payment  requests  is  progressing  simultaneously.  To  assess  the  progress 
made  by  Member  States  in  fulfilling  milestones  and  targets,  the  analysis  therefore 
considers both datasets. 

Table 4 below provides an overview of the state of implementation of the milestones and 
targets, presenting, for each of the elements of the RRF’s general objective and their related 
pillars, the ‘progress rate’ of the milestones and targets – calculated by aggregating the 
milestones and targets assessed as “satisfactorily fulfilled” by the Commission or reported 
as “completed” by Member States. It shows that the implementation of the Facility has 
progressed steadily across the six pillars, with around a third of the milestones and targets 
contributing to each objective and pillar being ‘fulfilled’ or ‘completed’. More information 
per pillar is provided in the next section. 

Midway through implementation, it is too early to fully82 assess how far the progress 
with milestones and targets (i.e. output in the intervention logic) has translated into 
the actual implementation of reforms and investments (i.e. results in the intervention 
logic). As per the RRF’s design, implemented measures, in particular investments, are still 
in the early stages with milestones capturing first steps in the implementation. Investments 
included  in  the  RRPs  are  spread  over  the  RRF  timeline,  but  most  are  planned  to  be 
completed in 2025/2026. It is therefore too early to fully assess the RRF’s effectiveness 
towards  reaching  the  Facility’s  general  objective.  Examples  of  investments  or  reforms 
already implemented (outlined in section 4.1.2.B) are however available. They represent 
concrete results that have already been achieved and help illustrate the RRF’s intervention 
logic, from the achievement of milestones and targets to the impact on the ground, in line 
with the elements  of the RRF’s high  level  objective laid down in  Article 4  of the RRF 
Regulation. 

4.1.2. Progress towards the elements of the RRF general objective 

The  general  objective  of  the  Facility,  as  defined  under  Article  4  of  the  RRF 
Regulation, is “to promote the Union’s economic, social and territorial cohesion”,  

-  by  (i)  “improving  the  resilience,  crisis  preparedness,  adjustment  capacity  and 
growth potential of the Member States”, 

81   Data on satisfactorily fulfilled milestones and targets is published on the Recovery and Resilience Scoreboard and 

available at: https://ec.europa.eu/economy_finance/recovery-and-resilience-
scoreboard/milestones_and_targets.html?lang=en.  

82   This will be assessed in due time in the 2028 ex-post evaluation. 

34 

 
 
- by (ii) “mitigating the social and economic impact of that crisis, in particular on 
women,  by  contributing  to  the  implementation  of  the  European  Pillar  of  Social 
Rights”,  

- by (iii) “supporting the green transition” and (iv) “the digital transition”, 

“thereby  contributing  to  the  upward  economic  and  social  convergence,  restoring  and 
promoting sustainable growth and the integration of the economies of the Union, fostering 
high quality employment creation, and contributing to the strategic autonomy of the Union 
alongside an open economy and generating European added value”. 

This section first presents the results available to date on the common indicators, which 
were  agreed  by  co-legislators  to  report  on  the  progress  of  the  Facility  towards  the 
achievement of its objectives. It then presents, for each of the four elements of the RRF 
general objective laid down in Article 4 and described above, the progress achieved and 
the evidence available to date on the results that the measures supported by the RRF are 
having on the ground. 

A. Common indicators 

A first analysis of the data reported by Member States on the common indicators83 
sheds light on the overall progress made under the Facility. To date, the data of four 
reporting  rounds  have  been  reviewed  to  ensure  comparability84  and  published  on  the 
Recovery and Resilience Scoreboard85, covering the progress achieved in the period from 
February  2020  to  June  202386.  At  this  early  point  in  time,  the  common  indicators  data 
cannot  be complete. The picture will become clearer once the implementation  of RRPs 
progresses  further  and  in  particular  investments  become  operational,  allowing  Member 
States to report more advanced and mature data. 

Table 3: Common indicators – progress as of 06/2023, EU level 
Measurement 
Common indicator 
unit 

Contribution to RRF pillars 

Stock87 
or flow88 

Value as of 06/2023 

Reporting 
Member 
States 

83   The common indicators represent a set of 14 indicators that were established by Commission Delegated Regulation 
2021/2106 of 28 September 2021 on supplementing Regulation (EU) 2021/241 of the European Parliament and of 
the Council establishing the Recovery and Resilience Facility, to display the overall performance and progress of 
the Facility towards its objectives. The common indicators cover elements which are common to most RRPs, but 
they  are  not  designed  to  capture  all  aspects  of  the  plans,  in  view  of  their  significant  heterogeneity  and  limited 
number. Two caveats apply to the collection and statistical treatment of the common indicators data: (i) The data is 
provided and quality assured by the Member States, while the Commission only conducts some plausibility checks. 
Hence, there may be differences among Member States in how the data is selected, compiled, and processed. (ii) In 
cases where a direct observation of numbers is not possible, the data is based on estimations, which are also prepared 
by each Member State according to their own statistical processes. 

84   The Commission has no legal basis to audit or verify the quality of the data submitted by Member States nor to alter 

or refuse specific reporting by Member States. 

85   See https://ec.europa.eu/economy_finance/recovery-and-resilience-scoreboard/index.html. 
86   As per the delegated Regulation 2021/2106, Member States report by 28 February (covering the reporting period of 
July and December of the previous year) and by 31 August (covering the reporting period of January to June of the 
same year). 

87   A stock indicator, which means that numbers are added cumulatively, and its values can only increase over time. 
88   This indicator is a flow indicator, which means that reported numbers represent the current situation in the reporting 

round and its values can fluctuate over time. 

35 

 
 
1: Evolution of savings in 
annual  primary  energy 
consumption 

2: Additional  operational 
capacity 
for 
renewable energy 

installed 

of 
fuels 

Evolution 

3: 
Alternative 
infrastructure 
(refuelling/recharging 
points) 

Stock 

Stock 

Stock 

Pillar     (green  transition)  and 
pillar  3  (smart,  sustainable  and 
inclusive growth) 

Megawatt-
hour/Year 

28 282 262 

Pillar     (green  transition)  and 
pillar  3  (smart,  sustainable  and 
inclusive growth) 

Megawatt 

54 204 

 0 

Pillar     (green  transition)  and 
pillar  3  (smart,  sustainable  and 
inclusive growth) 

Refuelling/rech
arging points 

531 995 

4:  Population  benefiting 
from protection measures 
against  floods,  wildfires, 
and other climate related 
natural disasters 

Stock 

Pillar     (green  transition)  and 
pillar  4  (social  and  territorial 
cohesion) 

Population 

8 976 469 

5:  Additional  dwellings 
with 
access 
internet 
provided  via  very  high-
capacity networks 

Stock 

Pillar  2  (digital  transformation) 
and pillar  4  (social and  territorial 
cohesion) 

Dwellings 

5 605 735 

6:  Enterprises  supported 
to develop or adopt digital 
products,  services  and 
processes 

7:  Users  of  new  and 
upgraded  public  digital 
services,  products  and 
processes 

8: Researchers working in 
supported 
research 
facilities 

9:  Enterprises  supported 
(of  which: 
– 
including micro, medium, 
large)  

small 

Flow 

Flow 

Flow 

Flow 

Pillar  2  (digital  transformation) 
and pillar 3 (smart, sustainable and 
inclusive growth) 

Enterprises 

587 398 

Pillar  2  (digital  transformation) 
and pillar   (health, and economic, 
social and institutional resilience) 

Users 

308 728 697 

2  

Pillar  3  (smart,  sustainable  and 
inclusive growth) 

Researchers  (in 
FTEs) 

17 551 

Pillar 3 (smart growth, sustainable 
and inclusive growth) 

Enterprises 

1 959 338 

2  

10: 
of 
Number 
participants  in  education 
or training 

Flow 

Pillar  2  (digital  transformation), 
pillar  4  (social  and  territorial 
cohesion) and pillar   (policies for 
the next generation) 

11:  Number  of  people  in 
employment  or  engaged 
in job searching activities 

Flow 

Pillar  3  (smart,  sustainable  and 
inclusive  growth)  and  pillar  4 
(social and territorial cohesion) 

12:  Capacity  of  new  or 
modernised  health  care 
facilities 

Stock 

13: Classroom capacity of 
new 
or  modernised 
childcare  and  education 
facilities 

Stock 

14:  Number  of  young 
people 
15-29 
aged 
receiving support 

Flow 

Pillar  4  (social  and  territorial 
cohesion) and pillar   (health, and 
economic, social and institutional 
resilience) 

Pillar  4  (social  and  territorial 
cohesion) and pillar   (policies for 
the next generation) 

Participants 

8 701 973 

20 

People 

1 311 931 

Capacity 

45 788 233 

 3 

9 

Capacity 

246 037 

Pillar     (policies  for  the  next 
generation) 

Young people 

5 779 581 

 8 

Source: Recovery and Resilience Scoreboard 

Methodological  caveats  apply  to  the  common  indicators.  While  their  purpose  is  to 
report on the overall performance and progress of the Facility towards its objectives, they 
do  not  comprehensively  cover  all  investments  included  in  the  RRPs  and  do  not  fully 
capture  the  contribution  of  reforms,  which  is  difficult  to  measure  using  quantitative 

36 

 
   
 
   
  
  
   
   
  
indicators. The collection methodology of the common indicators’ underlying data makes 
it  at  times  impossible  to  disentangle  their  specific  origin  and  contribution  to  RRF 
objectives89, particularly as there is no comparison point (counterfactual in the absence of 
the RFF). Furthermore, the common indicators do not include final target values, which 
limits their use in the context of an evaluation and in determining RRF effectiveness90. This 
point  has  been  echoed  by  feedback  received  from  Member  States,  who  argue  that  the 
purpose and design of such type of common indicators should be discussed91. Because of 
these  limitations,  common  indicators’  data  is  only  used  in  this  mid-term  evaluation  to 
complement the information gathered on the fulfilment of milestones and targets presented 
above. 

B.  Progress  in  the  implementation  of  reforms  and  investments  supporting  the  RRF’s 
general objective 

The  following  section  presents,  for  each  element  of  the  RRF  general  objective, 
evidence  of  the  progress  achieved  to  date  and  first  available  results  providing 
indications of the impact on the ground of some reforms and investments supported 
by the RRF. The examples used stem from the dedicated case studies carried out in the 
context of the external support study. The purpose is to illustrate how the progress with 
achieving milestones and targets (output) has translated into the implementation of reforms 
and investments (results) that contribute to the RRF general objectives (impact). 

Table 4: Progress rate of milestones and targets per RRF objective and pillars92 

Objective 

Related pillars 

Progress rate of milestones and targets93 

A.  Improving  the  resilience,  crisis 
preparedness,  adjustment  capacity 
and growth potential of the Member 
States 

Smart, sustainable and 
inclusive growth (pillar 
3) 

Progress rate of 41% (approximately 21% 
assessed in payment requests), with 1,152 
of 2,780 milestones and targets completed 
or fulfilled. 

the 

B.  Mitigating 
social  and 
economic  impact  of  that  crisis,  in 
particular 
by 
contributing  to  the  implementation 
of  the  European  Pillar  of  Social 
Rights 

women, 

on 

Health, and economic, 
social and institutional 
resilience (pillar 5) 

Social and territorial 
cohesion (pillar 4) 

Progress rate of 42% (20% assessed in 
payment requests), with 962 of 2,317 
milestones and targets completed or 
fulfilled. 

Progress  rate  of  34%  (15%  assessed  in 
payment  requests),  with  876  of  2,590 
milestones  and 
targets  completed  or 
fulfilled  

Of  the  256  milestones  and  targets  with  a 
focus on gender equality in the 27 RRPs, 83 
are  already  reported  as  completed  or 
assessed  as  fulfilled,  representing  a  32% 

89   This point is confirmed by the supporting study, see pages 40 to 41.  
90   This point is confirmed by the supporting study, see pages 40 to 41.  
91   See pages 134 to 136 of the supporting study. 
92   Each milestone or target contributes towards two of the six policy pillars, although some milestones or targets can 
contribute  towards  the  same  pillar  as  both primary  and  secondary. The  total number  of  fulfilled milestones  and 
targets across all six individual pillars, when added together, thus exceeds 1,153 (which is the number of milestones 
and targets assessed by the Commission as fulfilled by 1 February 2024). 

93   Milestones and targets reported as completed by Member States or assessed as fulfilled by the Commission. 

37 

 
 
 
progress 
positively assessed). 

rate 

(approximately 

13% 

Policies for the next 
generation, children and 
the youth, such as 
education and skills 
(pillar 6) 

Green transition (pillar 
1) 

C. Supporting the green transition 

D. Supporting the digital transition  Digital transformation 

(pillar 2) 

Progress  rate  of  35%  (17%  assessed  in 
payment  requests),  with  222  of  636 
milestones  and 
targets  completed  or 
fulfilled  

Progress  rate  of  35%  (17%  assessed  in 
payment  requests),  with  908  of  2,625 
targets  completed  or 
milestones  and 
fulfilled. 

Progress rate of 31% (approximately 15% 
assessed in payment requests), with 721 of 
2,297 milestones and targets completed or 
fulfilled. 

Source: European Commission 

i. 

Improving  the  resilience,  crisis  preparedness,  adjustment  capacity  and 
growth potential of the Member States 

The  RRF  has  contributed  to  preserving  public  investment  in  the  EU,  in  sharp 
contrast with other crisis episodes. It is expected to boost investment going forward, 
thereby providing support to Member States’ growth potential. The EU’s aggregate 
public investment ratio is expected to rise to 3.5% of GDP in 2025, having increased from 
3.0% in 2019 to an expected 3.3% in 2023, according to the Commission’s 2023 Autumn 
Forecast94. In contrast with previous macroeconomic shocks, public investment remained 
robust during the COVID-19 pandemic and the energy crisis. The 2023 Autumn Forecast 
also finds that approximately half of the increase in public investment between 2019 and 
2025 is related to investment financed by the EU budget, particularly by the RRF. By the 
end of the forecast horizon, national budgets in most EU Member States are projected to 
devote more resources to investment than they did prior to the pandemic, with Slovenia, 
Portugal and Italy expected to record the largest increases. In contrast, Hungary, and to a 
lesser  extent  the  Netherlands,  are  set  to  reduce  their  nationally  financed  investments 
compared to 2019. 

The RRF supports a wide range of measures contributing to the objective “to improve 
the resilience, crisis preparedness, adjustment capacity and growth potential of Member 
States”. The measures are diverse and cover various policy areas, from health- and long-
term care to the effectiveness of judicial systems and anti-money laundering supervision95. 

94   See European Economic Forecast – Autumn 2023, available at: https://economy-finance.ec.europa.eu/economic-

forecast-and-surveys/economic-forecasts/autumn-2023-economic-forecast-modest-recovery-ahead-after-
challenging-year_en.  

95   For further information, see European Commission (2023) Recovery and Resilience Facility Annual Report 2023 
(COM(2023) 545 final/2), available at: https://commission.europa.eu/publications/recovery-and-resilience-facility-
annual-report-2023_en.  

38 

 
 
 
 
 
The RRF also supports measures that directly contribute to fostering the growth potential 
of  Member  States,  ranging  from  reforms  to  support  the  business  environment  or 
competitiveness,  to  research  and  development  and  innovation,  or  to  the  cultural  sector. 
This view is supported by the academic literature, with some authors96 considering that the 
contribution  of  the  RRF  in  support  of  institutional  resilience  mostly  come  from 
investments  and  reforms  aimed  at  modernising  public  administrations  and  improve  the 
effectiveness and integrity of public governance institutions. They show that 39% of the 
reforms supported by the RRF in euro area countries relate to the public sector, notably 
reforms in health care, in the judiciary and tax administration – and note that, before the 
introduction  of  the  RRF,  progress  in  these  areas  was  particularly  slow97.  A  majority  of 
respondents  in  the  public  consultation98  also  agreed  that  the  RRF  fosters  the  growth 
potential of the EU to some or a large extent.  

The balance between reforms and investments varies across policy areas. There are 
more  investments  aimed  at  strengthening  the  Member  States’  strategic  autonomy  (33 
investments  versus  four  reforms)99,  improving  their  crisis  preparedness  (39  investments 
versus 11 reforms) or modernising and strengthening health care (196 investments versus 
94 reforms). In contrast, there are more reforms than investments in areas related to fiscal 
policy (65 reforms versus seven investments), taxation (70 reforms versus 11 investments), 
rule of law (39 reforms versus two investments) and fraud prevention (54 reforms versus 
14  investments)  or  interventions  to  improve  the  effectiveness  of  public  administrations 
(290 reforms versus 208 investments).  

There has been significant progress in implementing measures related to resilience 
and growth potential, with over 40% milestones and targets contributing to these RRF 
objectives reported as completed by Member States or assessed as satisfactorily fulfilled 
by  the  Commission  (see  Table  4).  962  of  2,317  milestones  and  targets  contributing  to 
resilience and 1,152 of 2,780 milestones and targets contributing to growth are reported as 
completed by Member States or assessed as fulfilled by the Commission (680 milestones 
and targets for reforms and 282 for investments contributing to resilience; 591 milestones 
and targets for reforms and 561 for investments contributing to growth), which yields a 
progress rate of 41% (over 20% assessed in payment requests) for both pillars combined. 
As  aforementioned,  it  is  too  early  to  assess  in  how  far  this  progress  (an  output)  has 
translated  into  the  actual  implementation  of  reforms  and  investments.  However,  some 
evidence points to the results achieved so far. 

96   Bankowski,  K.,  Bouabdallah,  O.,  Domingues  Semeano,  J.,  Dorrucci,  E.,  Freier,  M.,  Jacquinot, P.,  Modery,  W., 
Rodríguez-Vives, M., Valenta, V., and Zorell, N. (2022) The economic impact of NextGenerationEU: a euro area 
perspective, available at: https://www.ecb.europa.eu/pub/pdf/scpops/ecb.op291~18b5f6e6a4.en.pdf.  

97   See Bankowski, K., Bouabdallah, O., Domingues Semeano, J., Dorrucci, E., Freier, M., Jacquinot, P., Modery, W., 
Rodríguez-Vives, M., Valenta, V., and Zorell, N. (2022) The economic impact of NextGenerationEU: a euro area 
perspective, available at: https://www.ecb.europa.eu/pub/pdf/scpops/ecb.op291~18b5f6e6a4.en.pdf.  

98   European Commission (2023) Summary Report of the Public Consultation concerning the Mid-term evaluation of 
the  Recovery  &Resilience  Facility  (RRF),  available  at:  https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/13608-Recovery-and-Resilience-Facility-2020-2024-mid-term-evaluation/public-consultation_en.  

99   These figures and all other in this paragraph include RRF sub-measures. 

39 

 
 
Business organisations had an overall positive view of the EU’s efforts in addressing 
the post-COVID  economic challenges100. RRP measures designed to  bolster economic 
recovery and resilience,  while overall relevant,  have  however not  always addressed the 
needs of SMEs. Progress in implementing SME-related measures varies across Member 
States, with some SME stakeholders raising issues related to the slow speed of RRF funds 
in  reaching  the  ultimate  recipients  and  pointing  to  the  complexity  of  RRF  supported 
programmes, designed at national  level, which negatively affects  SMEs  participation101. 
The issues conveyed by SMEs primarily need to be addressed at Member States level. In 
its proposal for a Strategic Technologies for Europe Platform (‘STEP’) from June 2023, 
the  Commission  proposed  a  single  ‘Sovereignty  portal’  where  SMEs,  as  well  as  other 
businesses, would be able to find all information about existing funding opportunities for 
STEP-related  investments,  including  under  the  RRF,  and  relevant  contact  details  of 
national authorities102. 

Data on the common indicators103 point to positive results in the areas of improving 
the  effectiveness  of  public  administrations  and  increasing  healthcare  capacity.  21 
Member States have reported approximately 309 million users of new or upgraded public 
digital  services  supported  by  RRF  measures,  although  the  data  cannot  exclude  that  the 
same  person  has  used  the  service  multiple  times.  As  regards  the  increase  in  healthcare 
capacity (in terms of the maximum number of patients per year), nine Member States have 
reported  a  total  of  45.8  million  additional  capacity  of  new  or  modernised  healthcare 
facilities  supported  by  the  RRF.  The  common  indicators  also  show  that  over  17,500 
researchers have been supported by the RRF across 17 Member States. 

Numerous  resilience-enhancing  measures  in  the  health  sector  have  already  been 
implemented and led to tangible results104. For example, in line with its RRP, Spain has 
made  progress  in  purchasing  and  installing  new  medical  equipment.  In  Estonia,  a 
regulation  expanding  the  list  of  healthcare  services  and  pharmaceutical  products 
reimbursed by the Estonian Health Insurance Fund entered into force on 1 April 2023. The 
digitalisation of healthcare is also included in many RRPs, and the use of e-consultations 
and  digital  tools  has  improved  patient  care  and  access  to  specialists  in  some  Member 
States105,  thereby  positively  impacting  the  national  healthcare  systems.  For  example, 
Croatia has already procured and deployed medical and computer equipment to 40 primary 
healthcare locations in remote and rural areas, via the Telecordis project. The equipment 

100   See  BusinessEurope  (2022)  Reform  Barometer:  Taking  Stock  of  the  EU’s  Competitiveness  After  2  Years  of  the 
Pandemic,  available  at:  https://www.businesseurope.eu/sites/buseur/files/media/reports_and_studies/reform_ 
barometer_2022/2022-03-23_reform_barometer_2022_final.pdf. This is also confirmed by the results of a survey 
of SMEs and SME support organisation in the EU, conducted as part of the case study on SME included in the 
supporting study. 

101   See the case study on SMEs included in the supporting study. 
102   See European Commission Proposal for a Regulation of the European Parliament and of the Council Establishing 
the  Strategic  Technologies  for  Europe  Platform  (‘STEP’)  (C M(2023)  3    final),  20  June  2023,  available  at: 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52023PC0335. 

103   See data on common indicators (7), (8), and (12) amongst others. 
104   Evidence in this paragraph is sourced from the supporting study (see pages 89 to 92) and from the associated case 

study on the digitalisation of healthcare. 

105   See the case study on the digitalisation of healthcare included in the supporting study. 

40 

 
 
installation has resulted in 356 telemedicine services provided, allowing for  the reading 
and interpretation of diagnostic results. The project has also resulted in improved access to 
diagnostic services, quicker diagnosis, and enhanced healthcare quality in rural areas. 

More generally, some resilience-enhancing reforms implemented to date are already 
showing  positive  results,  although  it  is  too  early  to  evaluate  their  full  impact  on 
resilience,  crisis  preparedness,  adjustment  capacity  and  growth  potential  of  the 
Member States. For example, in line with their RRP, Croatia has implemented106 various 
legislative  measures  that  aim  to  establish  a  legal,  organisational,  and  technological 
framework to reduce backlogs, shorten proceedings in civil and commercial courts107 and 
strengthen  the  transparent  and  efficient  administration  of  cases.  Despite  the  short  time 
since the adoption of the measures (in 2022 and 2023), there are already some results in 
terms of reduction of the duration of litigation in civil and commercial cases: the time taken 
to resolve a civil case has been reduced by almost 100 days at the end of 2022, compared 
to 2020 figures. The time needed to resolve a commercial case has also been reduced by 
more  than  50  days,  which  illustrates108  In  Italy,  several  measures  related  to  a  series  of 
structural  public  administration  reforms109  have  already  been  implemented  to  date,  in 
particular  the  activation  of  the  ‘Recruitment  Portal’.  This  is  a  single  platform  where 
administrations, employees and those interested in entering the civil service can find all 
data  concerning  job  opportunities  in  the  public  sector,  access  procedures  and  their 
implementation110. The effect of this public administration, combined with other upcoming 
structural reforms111 included in the Italian RRP, is expected to have a positive impact on 
GDP, on aggregate investment and consumption, on labour productivity, as well as well as 
a range of positive social impacts112. 

The RRF also  supports structural  reforms aimed at strengthening  the rule of law, 
and  in  particular  judicial  independence.  These  structural  reforms  outlined  in  the 

106   The following measures have been implemented as of the second quarter 2023: i) the introduction of electronic tools 
and  adequate  administrative  capacities  for  the  State  Judicial  Council  and  the  State  Attorney’s  Council;  ii)  the 
amendments to the Bankruptcy Act and the Consumer Insolvency Act; iii) the amendments to the Code of Criminal 
Procedure;  iv)  the  amendments  to  the  legislative  framework  in  the  area  of  justice;  v)  the  new  Non-contentious 
Procedure Act; and vi) the start of six new training programmes introduced in the framework of the judicial training 
programme. 

107   This example refers specifically to civil and commercial courts in Croatia, not to criminal or corruption cases. This 
this without prejudice to the Commission’s analysis on criminal courts included in the 2023 Rule of Law report. 

108   See page 68 of the supporting study. 
109   The  reform  aims  to  i)  improve  access  with  the  simplification  and  digitisation  of  recruitment  procedures,  (ii)  to 
reduce the time of administrative procedures and administrative burden for businesses and citizens, (iii) upskilling 
to better align knowledge and organisational skills with the needs of a modern and effective administration. 

110   See pages 71 to 72 of the supporting study. 
111   The Italian structural policy measures studied by D’Andrea et al (2023) are grouped by the authors into five areas 
of reforms: i) public administration; ii) justice; iii) competition (which also includes the reform of the procurement 
system);  iv)  education  and  research;  and  v)  labour  market  policies  and  training.  For  further  information,  see 
D’Andrea, S., D’Andrea, S., Di Bartolomeo, G., D’Imperio, P., Infantino, G., and Meacci, M. (2023)  Structural 
reforms  in  the  Italian  National  Recovery  and  Resilience  Plan:  A  macroeconomic  assessment  of  their  potential 
effects,  available  at:  https://www.dt.mef.gov.it/export/sites/sitodt/modules/documenti_it/analisi_progammazione 
/working_papers/WP-2-marzo-2023.pdf. 

112   See D’Andrea, S., D’Andrea, S., Di Bartolomeo, G., D’Imperio, P., Infantino, G., and Meacci, M. (2023) 

Structural reforms in the Italian National Recovery and Resilience Plan: A macroeconomic assessment of their 
potential effects, available at: https://www.dt.mef.gov.it/export/sites/sitodt/modules/documenti_it/analisi 
_progammazione/working_papers/WP-2-marzo-2023.pdf.  

41 

 
 
Semester  CSRs  are  relevant  to  protect  the  EU  financial  interests  and  strengthen  the 
business environment in the Member States concerned and are expected to have an impact 
on its growth potential113. For example, Hungary, Romania and Poland have included in 
their RRPs reforms aimed at strengthening judicial independence. Whilst it is too early to 
assess the results of these reforms, particularly since the content of these reforms has not 
yet been notified to or assessed by the Commission by February 2024, the mere fact of 
having included them in their respective RRPs can be considered as a positive step114. This 
view is supported by academic authors115 who discuss the potential role of the European 
Semester and the RRF to address rule of law issues and conclude that the RRF has become 
a powerful tool to make progress to protect the rule of law. 

ii.  Mitigating the social and economic impact of the crisis, in particular on 
women, by contributing to the implementation of the European Pillar of 
Social Rights 

One of the objectives of the RRF is to mitigate the social and economic impact of the 
COVID-19 crisis. The Regulation specifically calls for the RRF to improve the social and 
economic situation, while making a particular reference to the effect on women. In order 
to analyse the progress achieved in this area, this evaluation first discusses the progress 
achieved  with  the  implementation  of  milestones  and  targets  in  the  areas  of  social  and 
territorial cohesion as well as policies for the next generation, children and the youth, such 
as education and skills. Furthermore, it looks at measures contributing to gender equality.  

The RRPs coverage of social and territorial cohesion is more present in some plans 
than others, with good overall progress. In some Member States (e.g. Spain and Italy) 
social and territorial cohesion is streamlined across all components of the RRP. 876 of the 
2,590  milestones  and  targets  contributing  to  social  and  territorial  cohesion  are  already 
reported as completed by Member States or assessed as fulfilled by the Commission (431 
milestones and targets for reforms and 445 for investments), representing a 34% progress 
rate (15% assessed in payment requests). 

Progress is also tangible for the milestones and targets contributing to policies for the 
next generation, children and the youth, such as education and skills. So far, 222 of 
636 milestones and targets are already reported as completed by Member States or assessed 
as  fulfilled  by  the  Commission  (105  milestones  and  targets  for  reforms  and  117  for 
investments), which yields a progress  rate of 35% (17% assessed in payment requests). 
Positive advancement has also been shown as regards milestones and targets for measures 
related to the cultural and creative sectors, with 62 of 195 milestones and targets reported 
as completed by Member States or assessed as fulfilled by the Commission. 

113   See Council (2023) European Semester 2023: country-specific recommendations agreed, available at: 

https://www.consilium.europa.eu/en/press/press-releases/2023/06/16/european-semester-2023-country-specific-
recommendations-agreed/.  

114   This is confirmed by the findings of the supporting study, see page 92 of the study. 
115   Fromont, L.; and Van Waeyenberge, A. (2021) Trading rule of law for recovery? The new EU strategy in the post-

Covid era, available at: https://doi.org/10.1111/eulj.12426.  

42 

 
 
Member  States  are  also  progressing  with  the  implementation  of  measures  with  a 
focus on gender equality and equal opportunities for all. The 27 plans adopted contain 
134 (sub-)measures with a focus on gender equality, and many reforms and investments 
that are  explicitly  aimed at  contributing  to  equal opportunities in  general116. Of the 256 
milestones  and  targets  with  a  focus  on  gender  equality  in  the  27  RRPs,  83  are  already 
reported  as  completed  or  assessed  as  fulfilled,  representing  a  32%  progress  rate 
(approximately 13% positively assessed). 

Data  on  the  common  indicators117  point  to  positive  results  in  improving  social, 
economic  and  territorial  resilience  following  the  pandemic.  With  support  received 
through the RRF, 13 Member States have reported that over 1.3 million people have either 
found employment or engaged in job searching activities and 20 Member States reported 
that over 8.7 million have participated in education and trainings to improve their skills. In 
addition, classroom capacities of childcare and education facilities have increased by over 
246,000 persons per year across the seven Member States who reported on this. 

The RRF has helped in addressing social, economic and territorial challenges, in line 
with  the  relevant  European  Semester  CSRs.  For  example,  Spain,  France,  Italy  and 
Croatia have included ‘Active Labour Market Policies’ (‘ALMP’) that address a number 
of key labour market challenges in line with their CSRs in 2019 and 2020.  

The final labour market impact of measures cannot be evaluated at this stage, given 
the short time horizon and the time lag in observing impacts on the labour market, 
but first examples of results are emerging. Therefore, further monitoring and evaluation 
of  the  ALMP  measures  will  be  needed118.  Nonetheless  early  evaluations  for  the  youth 
subsidy  measure  in France, which was satisfactorily fulfilled in  the context of France’s 
first payment request, suggests that the measure had a positive effect on the quality, if not 
quantity, of employment for young people119. Research on France’s youth hiring subsidy 
measure  shows  that  it  was  associated  with  a  6%  increase  in  the  number  of  subsidised 
contracts of long duration – i.e. the contracts eligible for the youth hiring subsidy. Despite 
this increase, the measure did not have effects on the total employment of young people, 
as the new contracts substituted for non-salaried and substitute employment. The measure 
did, however improve the quality of employment, in line with the objective of the measure 
to reduce labour market segmentation120. Another example concerns Spain, which adopted 
in December 2021 a labour market reform that generalised the use of open-ended contracts 

116   For further information, see European Commission (2023) Recovery and Resilience Facility Annual Report 2023 
(COM(2023) 545 final/2), available at: https://commission.europa.eu/publications/recovery-and-resilience-facility-
annual-report-2023_en.  

117   See data on common indicators (10), (11), and (13) amongst others. 
118   Evidence in this paragraph is sourced from the case study on ‘Active Labour Market Policies’ the included in the 

supporting study. 

119   Dubost, C.L. (2023) Les effets sur l’emploi de l’aide à l’embauche des jeunes instaurée en 2020, Dares Document 
d’Étude  No.  2  ,  available  at :  https://dares.travail-emploi.gouv.fr/sites/default/files/38c480360da2174e6f 
710964628cb188/DE%20266_Effet%20AEJ.pdf. 

120   France  Stratégie  (2021)  Comité  d’évaluation  du  plan  France  Relance:  Premier  rapport,  available  at: 

https://www.strategie.gouv.fr/publications/comite-devaluation-plan-france-relance-premier-
rapport#:~:text=Pour%20ce%20premier%20rapport%2C%20le,la%20rénovation%20énergétique%20des%20bâti
ments. 

43 

 
 
and incentivised the internal flexibility of firms, striking a long-awaited balance between 
workers’ protection and firms’ flexibility. Recent data from the Bank of Spain121 confirms 
that the reform was successful in meeting its objectives of increasing the number of open-
ended contracts and reducing the number of temporary or fixed-term contracts.  

iii.  Progress on supporting the green transition 

The green transition is a key focus of the RRF and has been allocated a significant 
amount of RRF funding across all Member States. The total number of (sub-)measures 
contributing  to  the  green  transition  is  983  (sub-)measures  (262  reforms  and  721 
investments), including over 2,600 milestones and targets (576 for reforms and 2,046 for 
investments)122. The biggest expenditure supporting the in all the RRPs has been allocated 
to sustainable mobility (31%), followed by energy efficiency (29%) and renewable energy 
and networks (14%). In addition, all Member States’s RRPs have exceeded the target of 
37%  of  total  allocation  set  in  the  RRF  Regulation,  with  the  total  estimated  climate 
expenditure  amounting  to  EUR  275  billion  or  over  40%  of  the  total  plans’  allocations. 
Several Member States are even dedicating over half of their total allocation to climate 
objectives,  such  as  Austria,  Bulgaria,  Denmark,  Estonia,  Luxembourg,  Malta,  and 
Finland.  

Progress  in  implementing  measures  related  to  the  green  transition  has  been  good 
overall. Over third of milestones and targets have been reported as completed or assessed 
as satisfactorily fulfilled by the  Commission. Specifically,  908 of 2,625  milestones and 
targets related to the green transition are already reported as completed by Member States 
or assessed as fulfilled by the Commission (319 milestones and targets for reforms and 589 
for  investments),  which  yields  a  progress  rate  of  approximately  35%  (17%  assessed  in 
payment requests). Given that final effects will only materialise in the longer term, it is too 
early to assess the RRF’s impact on the green transition overall and to gauge the impact of 
green-transition  measures  more  specifically.  Nonetheless,  the  already  fulfilled  ‘green’ 
milestones  and  targets  have  helped  increase  momentum  for  the  green  transition123,  as 
exemplified below.  

Data  on  the  common  indicators124  point  to  positive  results  in  the  areas  of  energy 
savings  and  deploying  renewable  energy  infrastructure.  15  Member  States  have 
reported already achieving about 28 million Megawatt-hours of savings in annual primary 
energy  consumptions,  10  reported  over  54,000  Megawatt  of  additional  operational 
capacity for renewable energy, and 15 reported installing over 530,000 new or upgraded 

121   Banco de España (2023) El aumento de los contratos indefinidos y su posible impacto en el gasto, available at : 
https://www.bde.es/f/webbde/SES/Secciones/Publicaciones/InformesBoletinesRevistas/BoletinEconomico/23/T1/
Fich/be2301-art19.pdf. 

122   For further information, see European Commission (2023) Recovery and Resilience Facility Annual Report 2023 
(COM(2023) 545 final/2), available at: https://commission.europa.eu/publications/recovery-and-resilience-facility-
annual-report-2023_en.  

123   See pages 92 to 97 of the supporting study. 
124   See data on common indicators (1), (2), and (3) amongst others. 

44 

 
 
refuelling and recharging points for clean vehicles. Overall, the primary energy savings 
achieved so far approximately correspond to the installed electricity capacity in Belgium.  

Whilst it is too early to draw conclusions on impacts of measures addressing energy 
efficiency  in  buildings,  some  examples  of  results  are  emerging.  For  example,  whilst 
France and Romania are making good progress towards implementing their milestones and 
targets for energy efficiency in buildings, Latvia is experiencing some delays, and Bulgaria 
is lagging behind125. France is one of the few Member States that already reports energy 
savings, with 3.0 Terawatt-hour in savings reached by end of 2022, mostly via schemes 
concerning heating and domestic hot water. Energy efficiency measures are however long-
term  construction projects  by nature, and it is too early to  draw  firm  conclusions  about 
energy savings impacts for most other Member States, despite their achievement of various 
outputs laid down in the milestones and targets in the Council Implementing Decisions 
(such  as  published  calls  for  tender,  applications  to  energy-efficiency  calls  for  tender, 
granted projects etc). Other examples illustrate how RRF-supported measures are having 
an impact on the ground. For instance, with the aim to develop clean mobility solutions to 
decarbonise the transport sector, Germany adopted a reform on a ten-year tax exemption 
for purely electric vehicles. Data from the German Federal Motor Transport Authority126 
demonstrates  that  there  has  already  been  a  steady  growth  in  pure  electric  vehicles  in 
Germany, suggesting that the measure is delivering good results in this sector in Germany. 
Overall,  most  respondents  in  the  public  consultation127  consider  that  the  RRF  has 
contributed or will contribute to the green transition (62%) and the European Green Deal 
(64%) to some or to a large extent. 

Member States recognise the Do No Significant harm (‘DNSH’) principle as a new 
feature that has strengthened the ‘green’ dimension of RRF reforms and investments 
and  helps  achieve  the  RRF’s  green  objectives,  according  to  the  results  of  the  public 
consultation  and  a  survey  of  key  RRF  stakeholders128.  EU  and  national  respondents 
expressed  their  satisfaction  with  the  novelty  of  the  principle  and  its  potential  to  shape 
investments  in  line  with  the  European  Green  Deal  objectives,  noting  that  the  principle 
could  have  positive  “spillover  effects”  into  national  policy  systems  and  improve  the 
environmental sustainability of Member States’ public investments.  

Box 2: REPowerEU  

Most  Member  States  have  already  added  specific  chapters  to  their  RRPs  in  order  to 
finance key investments and reforms which will help achieve the REPowerEU objectives. 
So far, 23 Member States have seen their REPowerEU chapters adopted by the end of 2023, 

125   Evidence in this paragraph is sourced from the supporting study (see pages 92 to 97) and from the associated case 

study on the green transition. 

126   See Box 3 on ‘German reform on ten-year tax exemption for purely electric vehicles’ on pages 69 and 70 of the 

supporting study. 

127   See European Commission (2023) Summary Report of the Public Consultation concerning the Mid-term evaluation 
of the Recovery &Resilience Facility (RRF), available at: https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/13608-Recovery-and-Resilience-Facility-2020-2024-mid-term-evaluation/public-consultation_en. 

128   See page 97 of the supporting study. 

45 

 
 
while  the  remaining  four  are  expected  to  be  adopted  in  2024.  It  is  too  early  to  assess  the 
implementation of REPowerEU chapters as payment requests related to these chapters will start 
in  2024.  It  is  however  expected  that  the  measures  will  help  Member  States  move  to  a  more 
reliable, secure, and sustainable energy supply. More than EUR 60 billion from the approved 
REPowerEU chapters is allocated to contribute to save energy, substitute fossil fuels and address 
immediate  security  of  supply  needs,  while  diversifying  away  and  reducing  dependency  on 
Russian fossil fuels. 

The  REPowerEU  chapters  are  expected  to  contribute  to  the  REPowerEU  objectives  of 
enhancing  the  resilience,  security  and  sustainability  of  the  European  Union´s  energy 
system. This should be achieved by reducing reliance on fossil fuels and diversifying energy 
sources across the EU through measures to boost the uptake of renewables, to improve energy 
efficiency  and  to  expand  energy  storage  capacity.  Overall,  the  REPowerEU  chapters  aim  at 
allowing for the enabling of at least 20  Gigawatt of renewable energy by 2026, on top of 40 
Gigawatt  in  the  existing  plans.  In  addition,  the  revised  plans  include  long-lasting  energy 
efficiency  interventions  which,  once  implemented,  will  reduce  energy  bills  for  at  least  one 
million  households.  More  than  EUR  12  billion  will  be  made  available  to  decarbonise  our 
industry,  including  EUR  2.5  billion  for  renewable  hydrogen  production.  Strategic  clean-tech 
investments in electrolysers, batteries and solar panels will be fostered, together with dedicated 
green skills training of more than 100,000 individuals. 

Save Energy 

One of the main objectives of REPowerEU is to save energy and enhance energy efficiency 
as  the  cleanest  and  cheapest  way  to  address  the  energy  crisis.  Relevant  investments  are 
expected to support the delivery of national ambitions to reduce (by at least 30%, in most cases) 
energy consumption from buildings and industry129 and to reduce the climate impact as much as 
possible by accelerating the transition from fossil fuels (by complementing energy efficiency 
renovation with solar rooftops, heat pumps and phasing out of fossil fuels in heating)130. Energy 
efficiency will also protect households from higher bills and provide targeted support to help 
energy  poor  and  vulnerable  consumers131.  One-stop-shops  are  expected  to  bridge  the  gap 
between the fragmented supply and demand side to facilitate the delivery of energy efficiency 
measures132. 

Diversifying Energy supplies and enhancing the resilience of energy networks 

REPowerEU  investments  are  expected  to  strengthen  energy  infrastructure,  address 
immediate needs of security of supply and bottlenecks in both internal and cross-border 
transmission  and  distribution  networks.  Limited  support133  is  provided  to  targeted 
infrastructure for tackling the immediate security of gas supply and for reducing dependency on 
Russian fossil fuels. Moreover, REPowerEU also contributes to the EU´s energy independence 

129   See  for  example  the  REPowerEU  chapters  of  Belgium,  Croatia,  Czechia,  Denmark,  France,  Greece,  Hungary, 

Lithuania, the Netherlands, Portugal, Romania, Slovakia, and Sweden 

130   See for example, the REPowerEU chapters of Denmark, Greece, Italy, and Poland. 
131   See for example, the REPowerEU chapters of Romania. 
132   See for example, the REPowerEU chapters of Czechia, Romania. 
133   See for example, the REPowerEU chapters of Croatia, Italy and Poland. 

46 

 
 
by  supporting  the  manufacturing  of  strategic  net-zero  technologies  such  as  electrolysers, 
batteries and solar panels134. 

Fast forwarding the clean energy transition 

The  REPowerEU  chapters  aim  to  increase  the  share  of  renewables  by  delivering  8.4 
Gigawatt  of  power  from  offshore/onshore  wind  and  solar  by  2026135,  speed  up  the 
permitting  procedures136  and  secure  appropriate  grid  connections137  by  investing  in 
smarter, more flexible, digitally enabled grids138 to unleash the full potential of renewable 
energy  sources.  Electricity  storage139  and  biomethane/renewable  hydrogen  generation140  are 
expected  to  be  rolled  out  and  scaled  up  rapidly.  On  green  skills,  the  revised  plans  include 
measures  to  ensure  that  qualifications  are  in-line  with  labour  market  needs  by  mapping, 
reviewing,  and  updating  them.  A  system  of  accessible,  tailored  training  aligned  with  market 
needs should ensure that specialised workforce is available to meet the challenge of the transition 
to net zero economy141. 

Following the adoption of most REPowerEU chapters in the final months of 2023, Member 
States  will  have  three  years  to  implement  the  relevant  measures.  In  view  of  the  careful 
selection  of  measures  for  inclusion  in  the  chapters,  Member  States  are  optimistic  about  the 
timelines for implementation, as evidenced by interviews and surveys142. The limited remaining 
lifetime of the RRF however, which expires on 31 December 2026, has restricted the types of 
investment projects that Member States have selected in their plans, particularly regarding the 
deployment of technologies and infrastructures that requires a longer timeframe.  

iv.  Progress on the digital transition 

The RRF supports various measures contributing to the digital transformation in the 
Union. RRPs cover a range of measures, including deployment of next generation digital 
infrastructures and advanced technologies,  digital skills development  for the population 
and  the  workforce,  and  support  to  the  digitalisation  of  enterprises  as  well  as  of  public 
services143. Member States have exceeded the target of 20% of total allocation set in the 
RRF Regulation, with the total estimated digital expenditure amounting to EUR 130 billion 
or 26% of the total plans’ allocations. 

134   See for example, the REPowerEU chapter of Portugal. 
135   See  for  example,  the  REPowerEU  chapters  of  Czechia,  Hungary,  Lithuania,  Poland,  Portugal,  Romania,  and 

Slovenia. 

136   See for example, the REPowerEU chapters of Austria, Belgium, Czechia, France, Portugal, Romania, Slovakia, 

Slovenia, and Spain. 

137   See for example, the REPowerEU chapters of Belgium, Czechia, Greece, and Poland. 
138   See for example, the REPowerEU chapters of Czechia, Italy, Poland, and Romania. 
139   See for example, the REPowerEU chapters of Greece, Hungary, Malta, Poland, Portugal, and Spain. 
140   See for example, the REPowerEU chapters of Belgium, Croatia Estonia, Italy, France, and Spain. 
141   See for example, the REPowerEU chapters of Czechia, Italy, Poland, Romania. 
142   Evidence in this paragraph is sourced from the supporting study, see pages 114 to 116. 
143   For further information, see European Commission (2023) Recovery and Resilience Facility Annual Report 2023 
(COM(2023) 545 final/2), available at: https://commission.europa.eu/publications/recovery-and-resilience-facility-
annual-report-2023_en.  

47 

 
 
Member States have made significant progress in implementing measures related to 
the  digital  transformation,  and  nearly  a  third  of  related  milestones  and  targets  are 
reported as complete or assessed by the Commission as fulfilled. 721 of 2,297 milestones 
and  targets  related  to  the  digital  transformation  are  already  reported  as  completed  by 
Member States or assessed as fulfilled by the Commission (262 milestones and targets for 
reforms and 459 for investments), which yields a progress rate of 31% (approximately 15% 
assessed in payment requests).  

Data  on  the  common  indicators144  point  to  positive  results  related  to  the  digital 
transformation. Seven Member States reported that an additional 5.6 million dwellings 
had received internet access via high-capacity networks with support received under the 
RRF. In addition, 21 Member States reported that the number of users of new or upgraded 
public digital services had increased to almost 309 million users145. 

Some of the measures implemented in the digitalisation of health are already showing 
results on the ground146. The digitalisation of health has been a top priority for the EU in 
recent years and many Member States – Belgium, Croatia, Czechia, Denmark, and Estonia 
amongst  others  –  have  already  implemented  measures  related  to  the  digitalisation  of 
national  healthcare  systems  as  part  of  their  RRPs.  These  measures  include  eHealth 
services,  telemedicine  solutions,  and  improvements  in  healthcare  data  management  and 
they  have  been  effective  in  achieving  their  objectives,  such  as  empowering  patients, 
optimising healthcare delivery, and fostering innovation147. As aforementioned in Section 
4.1.2.B.i., these measures have also positively impacted healthcare systems, including the 
use of e-consultations and digital tools to improve patient care and access to specialists in 
Croatia and in other Member States148. 

While  investments  in  the  digital  sector  are  still  in  the  early  stages,  a  number  of 
reforms  supporting  the  digital  transformation  have  been  implemented  and  are 
starting to have an impact on the ground. For example, Romania adopted a reform to 
accelerate the national roll-out of 5G networks, in accordance with security regulations, 
and  to  provide  broadband  coverage  for  white  areas  (small  rural  municipalities,  isolated 
localities, disadvantaged inhabited areas), tackling the rural-urban digital divide, reducing 
the administrative burden and streamlining procedures and fees, creating the prerequisites 

144   See data on common indicators (5), (7), and (10) amongst others. 
145   As data is collected on the numbers of users (and not of persons), in some instances, the same person might have 

used the relevant digital public service multiple times. 

146   Evidence  in  this  paragraph  is  sourced  from  the  case  study  on  the  digitalisation  of  healthcare  included  in  the 

supporting study. 

147   Evidence  in  this  paragraph  is  sourced  from  the  case  study  on  the  digitalisation  of  healthcare  included  in  the 

supporting study. 

148   See section above on ‘on improving the resilience, crisis preparedness, adjustment capacity and growth potential 

of the Member States’ 

48 

 
 
for equal access to digital services and internet access149. Belgium’s  G reform introduced 
in 2021, and supported by the RRF, led to a significant increase in 5G traffic in 2022150. 

Many RRPs contain measures to develop digital skills and some have already been 
implemented151. Over 25,000 people in France have signed up for a training for digital 
skills thanks to an investment contained in the French RRP to top-up individual learning 
accounts for digital skills. In turn, the Italian RRP aims for 700,000 individuals at risk of 
digital  exclusion  to  have  benefitted  from  facilitation  and  education  services  for  the 
development and improvement of digital skills by the end of 2025.  

4.1.3. Effectiveness in supporting reforms: a key feature of the RRF 

Progress on the implementation of country-specific recommendations  

The RRF’s ability to support the implementation of reforms can be considered as one 
of the most effective features of the instrument152, and the RRF has proven to be a key 
tool to deliver on the European Semester’s CSRs153. In line with the RRF Regulation, 
Member States were required to effectively address in their RRPs all or a significant subset 
of  the  challenges  identified  in  the  relevant  CSRs.  In  addition,  milestones  related  to  the 
protection of the financial interests of the Union in all Member States must be satisfactorily 
fulfilled before any RRF payment can be disbursed following a payment request. There is 
unanimous agreement between Member States and the various EU institutions, including 
the European Parliament154 and the European Court of Auditors155, that the RRF has been 
effective in supporting  CSR-related reforms156. Relevant literature157 confirms this view, 
recognising  that  the  RRF  has  contributed  effectively  to  the  support  of  reforms  that 
otherwise  would  not  have  been  implemented.  Most  stakeholders  interviewed158  also 
confirm that the RRF has contributed to putting on the agenda long-awaited reforms linked 
to the CSRs that would otherwise have had little chance of being implemented. 

149   See European Commission (2023) Recovery and Resilience Facility Annual Report 2023 (COM(2023) 545 final/2), 
available at: https://commission.europa.eu/publications/recovery-and-resilience-facility-annual-report-2023_en. 

150   See Box 4 ‘Introduction of  G reform in Belgium’ on pages 70 and 71 of the supporting study. 
151   Evidence  in  this  paragraph  is  sourced  from  the  case  study  on  ‘Active  Labour  Market  Policies’  included  in  the 

supporting study. 

152   According to stakeholders consulted in the context of the supporting study, see pages 74 to 76 of the supporting 

study. 

153   See pages 74 to 76 of the supporting study. 
154   See European Parliament resolution of 10 May 2023 with observations forming an integral part of the decisions on 
discharge in respect of the implementation of the general budget of the European Union for the financial year 2021, 
Section 
at: 
https://www.europarl.europa.eu/doceo/document/TA-9-2023-0137_EN.html.  

(2022/2081(DEC)), 

Commission 

executive 

available 

agencies 

and 

III 

– 

155   European  Court  of  Auditors  (2022)  Special  Report:  The  Commission’s  assessment  of  national  recovery  and 
at: 

resilience 
appropriate 
https://www.eca.europa.eu/Lists/ECADocuments/SR22_21/SR_NRRPs_EN.pdf.  

plans:  Overall 

implementation 

available 

remain, 

risks 

but 

156   See pages 251 to 252 of the supporting study. 
157   See pages 251 to 252 of the supporting study. 
158   See pages 74 to 76 of the supporting study. 

49 

 
 
The RRF has significantly accelerated policy action to implement CSRs which was 
considered  slow in the past159.  The European Court of Auditors160 found that, over the 
2011-2017 period, only  1.6 % of CSRs were deemed to  have been ‘fully implemented’ 
within one year after issuance, and that only 26 % of the CSRs have been implemented 
over the full 2011-2018 period. In the two years preceding the RRF, the share of 2016-
20   CSRs reaching at least ‘some progress’ increased by only six percentage points from 
53% in 2018 to 59% in 2020. In comparison, the share of 2019-2020 CSRs reaching at 
least ‘some progress’ increased by    percentage points from  2% in 2021 before the RRF 
to almost 69% in 2023, after two years of RRF implementation (see Figures 7161 and 8). 
Since  the  start  of  the  implementation  of  their  RRPs,  Member  States  have  made  most 
progress  on  access  to  finance  and  financial  services,  followed  by  labour  market 
functioning, anti-money laundering and business  environment. At the same time, in the 
first years of implementation of the RRF, progress has been less visible in the areas of the 
single market,  competition and  State aid,  housing, long-term  care and pension systems, 
even if relevant reforms are foreseen in the RRPs and are expected to be implemented in 
the years ahead. Progress in the implementation of the recommendations adopted in 2022 
has also  been substantial. Member States have made at  least  ‘some progress’ in  almost 
52% of the recommendations addressed to them in July 2022. 

Figure  7:  Current  level  of  implementation  of 
2019-2020 CSRs 

Figure 8: Share of CSRs with at least “some 
progress” before and during the RRF 

Note: The multiannual assessment on the left graph looks at implementation of CSRs adopted 2019-2020 from the time 
the  recommendations  were  first  adopted  until  May  2023.  The  CSR  assessment  takes  into  account  the  degree  of 
implementation of the measures included in the RRPs and of those done outside of the RRPs at the time of assessment. 
Measures envisaged in the Annexes of the adopted Council Implementing Decisions on the approval of the assessment 
of the RRPs, which have not yet been adopted or implemented but are considered as credibly announced in line with the 

159   See pages 251 to 252 of the supporting study. 
160   Special report 16/2020 of the European Court of Auditors. 
161   See European Commission (2023) 2023 European Semester – Spring Package (COM(2023) 600 final), available 
at:  https://commission.europa.eu/system/files/2023-05/COM_2023_600_1_EN.pdf.  The  assessment  conducted  in 
May 2023 is backward-looking at a relatively early stage of implementation of RRPs. The results of the 2023 CSR 
assessment, together with those of previous years, are available at https://ec.europa.eu/economy_finance/country-
specific-recommendations-database/.  

50 

 
 
 
 
CSR  assessment  methodology,  warrant  ‘limited  progress’.   nce  implemented,  these  measures  can  lead  to 
‘some/substantial progress’ or ‘full implementation’, depending on their relevance. 
Source: European Commission 

The financial incentives provided by the RRF is one of the main factors in reinforcing 
the implementation of CSRs162. The fact that financial support is  conditional upon the 
implementation  of  reforms  is  the  most  relevant  factor  explaining  the  RRF's  success  in 
triggering  structural  reforms  that  address  the  European  Semester’s  CSRs.  This  is 
recognised  by  interviewees,  stakeholders  and  external  evaluators.  On  average,  the  link 
between  implementation  of  CSR-related  reforms  and  financial  support  is  stronger  for 
Member  States  that  receive  a  larger  size  of  the  financial  support:  those  that  receive  a 
proportionally bigger financial envelope in terms of their GDP are more likely to commit 
to and implement structural reforms. Moreover, the RRF serves as an incentive for Member 
States  to  internally  steer  the  political  debate  and  overcome  potential  resistance  against 
structural reforms. Furthermore, some observers have emphasised the positive role that the 
steering and incentives provided by the RRF are having on Member States, by fostering 
their commitment to the measures and timelines in their RRPs163. 

Some of the key reforms included in national plans have already been successfully 
implemented and are delivering results on the ground. A number of reforms supported 
by  the  RRF  have  already  been  introduced  across  a  wide  range  of  policy  areas:  labour 
market, social protection and pensions, education and training, civil and criminal justice, 
public  administration,  including  digitalisation  of  the  public  administration,  spending 
review  and  public  finance  governance,  anti-money  laundering,  licensing  simplification 
reforms  to  boost  the  investments  in  renewables,  roll-out  of  renewable  energy  and 
sustainable transport, introduction of 5G and broadband, structural reform of the education 
system, anti-corruption and tax planning164. Some have already led to tangible results: For 
example, Spain adopted in December 2021 a labour market reform that generalised the use 
of  open-ended  contracts  by  restricting  the  use  of  temporary  contracts  and  reducing  the 
contract menu and incentivised the internal flexibility of firms with the introduction of the 
RED mechanism, striking a long-awaited balance between workers’ protection and firms’ 
flexibility. Recent data from the Bank of Spain165 confirms that the reform was successful 
in meeting its objectives of increasing the number of open-ended contracts and reducing 
the number of temporary or fixed-term  contracts (see Section 4.1.2.B.ii). As mentioned 
above, results also show that, for example, the justice reform implemented in Croatia is 
already delivering on reducing the time needed to resolve civil and commercial cases166, or 

162   Evidence in this paragraph is sourced from the supporting study, see pages 74 to 76. 
163   See pages 74 to 76 of the supporting study. 
164   See page 12 of the supporting study.  
165   Banco de España (2023) El aumento de los contratos indefinidos y su posible impacto en el gasto, available at : 

https://www.bde.es/f/webbde/SES/Secciones/Publicaciones/InformesBoletinesRevistas/BoletinEconomico/23/T1/
Fich/be2301-art19.pdf. 

166   See pages 68 to 69 of the supporting study. 

51 

 
 
that  the  public  administration  reform  in  Italy  is  expected  to  have  a  positive  impact  on 
labour productivity and labour force upskilling167.  

4.1.4. Positive externalities 

The RRF had a positive effect on reducing the risks associated with sovereign-bank 
loops in the context of the COVID-19 crisis. Stylised simulations168 show that the crisis 
response policies of the EU strongly mitigated the risks associated with sovereign-bank 
loops169 in euro area countries in connection to the COVID-19 crisis. Together with the 
monetary  policy  measures  taken  by  the  ECB,  the  creation  of  the  contributed  to  macro 
financial  stability  in  the  aftermath  of  the  COVID-19  pandemic,  providing  a  structural 
policy commitment and financial safety net that avoided heightened market pressure on 
public finances and potential financial risks.  

The implementation of the RRF has also triggered positive effects for policy planning 
at  the  national  level170.  The  RRF  has  contributed  to  improving  inter-institutional 
coordination in the design of national reforms and investments171. In Slovenia, for example, 
the tight deadlines for the implementation of the RRP have helped the national government 
and  stakeholders  to  jointly  focus  on  efficient  implementation172.  In  addition,  relying  on 
national implementing bodies with experience in EU funds proved useful in dealing with 
the Commission. In Austria, the performance-based nature of the RRP served as a blueprint 
and inspired the setting-up of an instrument at national level for the distribution of funds 
between  different  levels  of  government  that  is  linked  to  pre-defined  quantitative  and 
qualitative  targets.  This  may  potentially  have  positive  repercussions,  including  for 
decentralised  States  more  generally173.  Stakeholders174  further  conveyed  that  the 
performance-based  approach  brought  predictability  and  accountability,  resulting  in  a 
“cultural shift” in policy planning and implementation. Overall, in some Member States, 
the RRF has changed implementation at national level by improving national governance 
and coordination and by accelerating delivery with a clear medium-term deadline (2026).  

The implementation of the RRF has also triggered some positive effects in terms of 
EU governance. With the RRF, the Commission and Member States have established a 
regular dialogue, based on the bottom-up nature of the instrument. This engagement has 
been  built  on  more  than  ten  years  of  experience  with  the  European  Semester,  while 

167   See D’Andrea, S., D’Andrea, S., Di Bartolomeo, G., D’Imperio, P., Infantino, G., and Meacci, M. (2023) Structural 
reforms  in  the  Italian  National  Recovery  and  Resilience  Plan:  A  macroeconomic  assessment  of  their  potential 
effects,  available  at:  https://www.dt.mef.gov.it/export/sites/sitodt/modules/documenti_it/analisi_progammazione 
/working_papers/WP-2-marzo-2023.pdf.  

168   See  Quarterly  Report  on  the  Euro  Area  (QREA),  Vol.  20,  No.  3  (2021),  available  at:  https://economy-

finance.ec.europa.eu/publications/quarterly-report-euro-area-qrea-vol-20-no-3-2021_en.  

169   See Fontana A. and S. Langedijk (20 9), ‘The Bank-Sovereign Loop and Financial Stability in the Euro Area’ in 

JRC Working Papers in Economics and Finance 2019/10, available at https://data.europa.eu/doi/10.2760/81563.  

170   Evidence in this paragraph is sourced from the supporting study, see pages 92 to 93. 
171   According to the results of a survey of Member States national administrations conduced as part of the supporting 

study, see pages 92 to 93 of the supporting study. 

172   See page 93 of the supporting study. 
173   See page 93 of the supporting study. 
174   See page 99 of the supporting study. 

52 

 
 
becoming more comprehensive, detailed and practical in the context of the Commission’s 
responsibilities  for  assessing  RRPs  and  the  related  payment  requests.  Overall, 
stakeholders175  confirmed  that  the  Facility  has  deepened  the  dialogues  and  exchanges 
between Member States and the Commission on investments and reforms compared to the 
pre-2021 European Semester. 

4.1.5. Limiting factors for the effectiveness of the Facility 

Factors  limiting  the  effectiveness  of  the  Facility  concern  both  the  design  and  the 
implementation of the instrument, as described below. 

A. Limiting factors related to the design of the Facility 

The comprehensive audit and control framework enshrined in the RRF Regulation 
appears  to  have  negatively  affected  the  speed  of  implementation  of  the  RRF,  with 
some stakeholders176, notably Member States authorities, calling for simplification177. 
Member States reported on the high workload stemming from different audit and control 
requirements  related  to  the  RRF.  At  the  same  time,  audit  and  control  procedures  are 
considered complex by stakeholders and there is a perceived overlap between controls and 
audits  by  national  authorities,  the  Commission  and  the  ECA.  Consultation  responses 
suggest  that  the  resulting  resource  needs  reduce  efficiency  as  those  resources  could 
otherwise have been dedicated to the implementation of the plans. Member States see room 
for simplifying control and audit procedures, ensuring better coordination among the actors 
involved and avoiding multiple checks. Whilst identifying potential areas of simplification 
is always relevant, there is also an onus on ensuring a proportionate approach to managing 
public money, given the scale of the budget and the relative novelty of the approach. 

The inclusion of a combination of milestones and targets in each instalment ensures 
that  balanced  progress  with  both  reforms  and  investments  is  being  made,  but  the 
fixed  composition  of  each  instalment  has  also  been  reported  to  slow  down  RRF 
disbursements.  The  RRF  Regulation  requires  Member  States’  RRPs  to  propose  a 
combination of reforms and investments and link them to instalments. The purpose is to 
avoid “cherry picking” and ensure a balanced progress of both reforms and investments, 
including  when  political  challenges  emerge  ahead  of  difficult  structural  reforms. 
Stakeholders, in particular Member States authorities, however report that Member States 
avoid  submitting  payment  requests  before  all  milestones  and  targets  envisioned  for  the 
specific  instalment  have  been  fully  completed,  which  can  lead  to  significant  delays  in 
payments  if  only  one  or  a  few  of  the  milestones  and  targets  are  pending178.  During  the 
stakeholder interviews, national authorities accompanied this problem description with a 
call  for  more  flexibility  in  (re)grouping  milestones  and  targets  for  a  specific  payment 
request. At the same time, it also has to be noted that in February 2023, the Commission 

175   As  mentioned  by  stakeholders  in  the  validation  workshop  organised  on  24  October  2023,  in  the  context  of  the 

supporting study. 

176   According to stakeholder consulted in the context of the supporting study, see pages 154 to 156. 
177   Evidence in this paragraph is sourced from the supporting study, see pages 154 to 156. 
178   See page 54 of the supporting study. 

53 

 
 
published  a  methodology  for  partial  suspension  of  payments,  which  provides  more 
transparency  on  the  suspended  amounts.  The  suspension  procedure  thus  gives  more 
flexibility to Member States who can (and do) now submit payment requests where not all 
milestones and targets have been fulfilled (yet). 

B. Limiting factors related to the implementation of the Facility 

Since the inception of the RRF Regulation in 2021, a range of unforeseeable external 
factors have markedly changed the economic and geo-political context in the EU and 
made  the  implementation  of  the  RRF  more  challenging.  Russia’s  war  of  aggression 
against Ukraine led to a spike in energy prices in 2022, exposing the vulnerabilities linked 
to the dependence on Russian fossil fuels. It has also driven inflation to levels unseen in 
decades,  increasing  price  levels  for  all  Member  States  and  causing  ‘cost  of  living’ 
difficulties for many households. The RRF has not been unscathed by the current global 
events,  with  inflation,  issues  in  global  supply-chains  and  labour  shortages  affecting  the 
implementation of many RRF measures across the Member States. 

In response to these challenges, Member States have used the opportunities offered 
in  the  RRF  Regulation  to  amend  their  RRPs,  which  has  however  slowed  down 
implementation.  In response to  inflation and supply-chain  issues, Member States  have 
reacted by (i) using national resources or additional RRF funding to bridge the gap between 
the actual current cost of their measure and what their initial RRF envelope is able to cover, 
(ii) adapting the targets to the increased costs, (iii) replacing investment projects that are 
no longer feasible from their plans, and/or (iv) postponing the initially foreseen timeline 
for the implementation of milestones and targets. At the same time, applying these changes 
to the RRPs programming takes some time and the implementation of some measures has 
been put on hold, resulting in delays and an overall slow-down of the implementation. It 
is  important  to  note  however  that  delays  in  the  submission  of  payment  request  do  not 
necessarily  translate  into  implementation  delays.  The  Member  States’  on-the-ground 
implementation  of  most  investments  and  reforms  has  continued,  as  evidenced179  by  the 
number of milestones and targets reported as ‘completed’ by Member States even though 
not  yet  assessed by the Commission under a formal payment request (as highlighted in 
Figure  5  in  Section  3.2.4.  and  as  discussed  throughout  Section  4.1.2.),  even  if  the 
submission of payment request has not followed the indicative timeline. 

Limited absorption capacity180 hampers the effectiveness of the RRF implementation 
in some Member States. When the RRF was adopted, several observers181 pointed to the 
risk of absorption capacity of the significant RRF funding, which would come in addition 
to the remaining EU Structural Funds from the 2014-2020 period, and the new Structural 

179   According to data reported by Member States as part of the RRF bi-annual reporting exercise. 
180   Commonly defined at the percentage of the total amount committed in the EU budget to a Member State that has 

been disbursed by the Commission to that Member State. 

181   See  Darvas,  Z.  (2020)  Will  European  Union  countries  be  able  to  absorb  and  spend  well  the  bloc’s  recovery 
funding?,  available  at :  https://www.bruegel.org/blog-post/will-european-union-countries-be-able-absorb-and-
spend-well-blocs-recovery-funding; and Alcidi, C., Gros, D., Corti, F. (2020) Who will really benefit from the Next 
Generation EU funds?, available at: https://www.ceps.eu/ceps-publications/who-will-really-benefit-from-the-next-
generation-eu-funds/. 

54 

 
 
Funds for the 2021-2027 period. The actual payments of structural funds depend on the 
ability of beneficiaries to use the funds, which vary significantly across Member States182. 
Under  the  RRF,  as  payments  are  made  upon  the  fulfilment  of  milestones  and  targets 
(related to both investments and reforms – performance-based approach), the absorption 
capacity is closely linked to the administrative capacity of Member States to implement 
the pre-agreed agenda of reforms and investments. In this context, the Committee of the 
Regions stressed that many Member States did not sufficiently strengthen administrative 
capacity  at  local  and  regional  levels,  which  is  a  precondition  to  ensure  proper 
implementation of the plans and an adequate take-up of the RRF funds. 

The administrative work required at national and sub-national  level to implement 
the RRF is higher than initially expected by Member States183. Some Member States 
have not been able to mitigate the increase in the workload of administrations observed at 
both  national  and  local  levels184.  Overall,  Member  States  that  experience  administrative 
and  staff  shortages  have  noted  that  the  administrative  burden  has  resulted  in  delays 
affecting  RRP  implementation.  Research185  illustrates  how  low  administrative  capacity, 
especially at local level, can affect the implementation of RRF-supported investments. The 
authors  analysed  the  implementation  of  investments  supported  by  the  RRF  in  ‘Early 
Childhood  Education  and  Care’  in  four  Member  States  (Italy,  Spain,  Germany  and 
Portugal), which are traditionally run at local level. They found that two key obstacles in 
implementation relate to (i) the lack of support/technical assistance to local authorities to 
develop projects’ proposals; and (ii) the lack of personnel especially at local level.  

More generally, an adequate administrative capacity within Member States is key to 
supporting  the  effectiveness  of  RRF  implementation.  To  ensure  the  effective 
implementation of their plans, some Member States put in place measures to strengthen 
their administrative capacity, such as reforms and investments aimed at modernising the 
public administration, including improving the transparency and effectiveness of tendering 
procedures  and  their  compliance  with  EU  legislation.  These  reforms  were  added  in  the 
RRPs to address specific regulatory hurdles and investment bottlenecks identified and have 
often  been  implemented  early  in  the  RRPs.  Some  Member  States  also  included  more 
specific interventions to directly support the administration to implement the plans. This 
comprises  measures  to  improve  the  organisation,  capacity  and  means  of  national 
administrations  directly  involved  in  the  implementation  of  plans  that  can  rely  on  the 
technical assistance from the Commission provided via the Technical Support Instrument 
(‘TSI’). This capacity building support is aimed at strengthening their institutions and their 
capacity to implement reforms. 23 Member States have received or are currently receiving 
general support for the horizontal aspects of RRP implementation, including support for 
the  revision  of  the  plans,  while  all  27  Member  States  are  benefiting  from  the  thematic 

182   See page 265 of the supporting study. 
183   See pages 124 to 125 of the supporting study. 
184   See page 125 of the supporting study. 
185   Corti,  F.,  Marobito,  C.,  Ruiz,  T.,  and  Luongo,  P.  (2022)  The  role  of  the  Recovery  and  Resilience  Facility  in 
strengthening  childcare  policies,  available  at:  https://feps-europe.eu/wp-content/uploads/2022/07/RECOVERY-
WATCH-Childcare-Policy-PP-1.pdf. 

55 

 
 
support linked to RRF measures’ implementation186. In addition to the TSI, another sectoral 
instrument available to Member States to support them in implementing RRF reforms is 
the Horizon Policy Support Facility. Member States such as Romania and Croatia have 
already requested and benefited from this support to help them implement key structural 
reforms of their national R&I systems foreseen in their plans.  

Local  and  regional  authorities,  as  well  as  social  partners  and  civil  society 
organisations,  pointed  to  their  insufficient  involvement  by  Member  States  in  the 
preparation and implementation of the RRPs. When submitting their RRPs, Member 
States  were  required  (under  Article  18  of  the  Regulation)  to  include  a  summary  of  the 
consultation  process  of  local  and  regional  authorities,  social  partners,  civil  society 
organisations,  youth  organisations  and  other  relevant  stakeholders,  explaining  how  the 
input of the stakeholders was reflected in their RRP. The involvement of social partners, 
local and regional authorities also positively contributes to the effectiveness of the RRPs’ 
implementation. The involvement of social partners has played a key role in speeding up 
the adoption process of some key reforms, especially for labour market or social policy 
reforms.  Relevant  stakeholders  (including  local  and  regional  authorities  or  civil  society 
organisations)  have  however  complained  about  their  insufficient  involvement  in  the 
national  context,  both  in  the  preparation  and  the  implementation  of  the  plans.  The 
European  Economic  and  Social  Committee,  in  its  report187  informing  the  mid-term 
evaluation  of  the  RRF,  specifically  called  for  a  greater  involvement  of  organised  civil 
society  in  the  implementation  of  the  RRF,  through  formal,  structured  consultation 
processes.  As  regards  sub-national  authorities,  according  to  a  survey  conducted  by  the 
European Committee of the Regions188, cities and regions reported a low involvement in 
the  monitoring  and  implementation  of  the  RRF  plans.  The  overall  low  involvement  of 
stakeholders  by  national  governments  for  the  preparation  of  the  plans  can  partly  be 
explained by the  exceptionally condensed time  available for programming of the RRPs 
during the COVID-19 crisis and by the various degrees of consultation.  

While  recognising  the  improvements  made  by  the  Commission,  some  Member 
States189  consider  that  the  Commission’s  guidance  on  the  RRF  was  not  always 
sufficiently  timely  and  clear.  Most  Member  States  interviewed  during  the  evaluation 
consider  that  the  Commission’s  communication  for  the  preparation  of  the  RRPs  in 
September 2020 was timely and clear190. However, with regard to the specific guidance on 
the DNSH principle from February 2021, a number of Member States regretted that it was 
published too late191 in the drafting phase of the plans. Some Member States had to modify 

186   See https://reform-support.ec.europa.eu/what-we-do/recovery-and-resilience-plans_en for further information. 
187   European Economic and Social Committee (2023) Mid-term evaluation of the Recovery and Resilience Facility, 
available at: https://www.eesc.europa.eu/en/our-work/opinions-information-reports/information-reports/mid-term-
evaluation-recovery-and-resilience-facility#downloads.  

188   European Committee of the Regions (2022) Implementation of the Recovery and Resilience Facility: The 

Perspective of Local and Regional Authorities – Results of the CoR-CEMR targeted consultation, available at: 
https://cor.europa.eu/en/engage/brochures/Documents/RRF-consultation-2022.pdf.  
189   Evidence in this paragraph is sourced from the supporting study, see pages 76 to 79. 
190   See page 76 of the supporting study. 
191   According  to  stakeholders  consulted  as  part  of  the  supporting  study,  this  was  due  to  the  discussions  on  the  EU 

Taxonomy that were still ongoing at that time, see page 77 of the supporting study. 

56 

 
 
their plans following the publication of the guidance, which caused additional burden and 
slowed down the implementation process. Moreover, some Member States are also of the 
view that the Commission’s Communication in February 2023 on the framework used for 
assessing milestones and targets and for the payment suspension methodology came rather 
late – and a majority of Member States consider that the payment suspension methodology 
remains  unclear  when  it  comes  to  reforms  because  of  the  discretion  given  to  the 
Commission in applying the methodology. To a lesser extent, a number of Member States 
conveyed that the informal dialogue with the Commission for the preparation and revisions 
of the plans and ahead of the submission of payment requests add administrative burden, 
suggesting for example to reduce the rounds of comments by the Commission to Member 
States  on  the  documentation  to  be  submitted  for  payment  requests.  The  Commission 
however  sees  this  informal  dialogue  as  a  key  element  facilitating  a  smooth  and  swift 
processing of payment requests. 

4.2. Efficiency 

This section assesses how the costs of implementing the Facility compare with its benefits, 
including an assessment of administrative burden and complexity with potential areas for 
simplification. 

4.2.1. RRF design 

There  are  efficiency  gains  by  supporting  reforms  and  investments  under  one 
instrument.  With  RRPs  combining  both  reforms  and  investments  in  one  plan,  they 
contribute to a more coherent sequencing between the two and encourage Member States 
to undertake reforms that will enhance the impact of investments. Accordingly, a majority 
(59%) of survey respondents192 consider that combining reforms and investments in one 
instrument leads to some or significant efficiency gains. Member States also report that 
coordinating the two is simpler when they are combined in one planning process193. 

The performance-based approach of the RRF is a key factor in enhancing efficiency. 
In the implementation of the RRF to date, the performance-based nature of the instrument, 
with financing not linked to cost, had led to strong commitments by Member States and 
provided incentives for them to deliver on the agreed measures within a clear timeframe. 
The results of the public consultation show that a majority of stakeholders supports this 
view194.  

Demanding  reporting  requirements  and  a  lack  of  flexibility195  are  perceived  as 
affecting the efficiency of the instrument. The various reporting requirements specified 
in the RRF Regulation (reporting on the achievement of milestones and targets; bi-annual 
reporting;  reporting  in  the  context  of  audits;  reporting  on  the  common  indicators)  have 

192   See page 156 of the supporting study. 
193   See pages 156 to 158 of the supporting study. 
194   European Commission (2023) Summary Report of the Public Consultation concerning the Mid-term evaluation of 
the  Recovery  &Resilience  Facility  (RRF),  available  at:  https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/13608-Recovery-and-Resilience-Facility-2020-2024-mid-term-evaluation/public-consultation_en. 

195   Evidence in this paragraph is sourced from the supporting study, see pages 154 to 156. 

57 

 
 
reportedly affected the efficiency of the instrument, with some Member States calling for 
simplification196.  Several  national  coordination  bodies  consider  that  the  common 
indicators,  while  anchored  in  the  Regulation,  have  limited  added  value  as  they  are  not 
directly  linked  to  tracking  results  of  reforms  and  investments.  Member  States  also 
conveyed a perception of rigidity in the interpretation of milestones and targets fulfilment 
by  the  Commission,  even  though  the  Communication  of  February  2023197  was 
acknowledged as an important step to clarify the margins of manoeuvre for Member States, 
especially when it comes to investments. 

4.2.2. RRF governance and implementation  

The RRF-related governance in Member States influences the efficiency of the RRP’s 
implementation,  in particular  through  the degree  of  centralisation  of  the  decision-
making process. Centralisation is reinforced by the performance-based approach of the 
RRF and the requirement to maintain a single national point of contact for verifying the 
fulfilment  of  the  relevant  milestones  and  targets  in  support  of  scheduled  payment 
requests198199. While the programming of the national RRPs required a certain centralisation 
in  all Member States,  differences emerge in  the governance of  implementing the plans, 
which  affect  the  efficiency  of  the  RRF.  One  of  the  main  differences  concerns  the 
involvement of the Prime Minister’s office, which tends to be correlated with a smoother 
implementation of the plans due to increased political ownership and enhanced capacity to 
steer internal decision-making processes. This is particularly the case for reforms.  

The involvement of social partners and local/regional stakeholders also matter for the 
efficiency of the implementation of RRPs. The different degree of involvement of sub-
national  authorities  in  the  design  and  implementation  of  the  plans  also  affected  the 
efficiency of the plans, in particular investments200. For example, some regions conveyed 
that the RRP measures chosen by their central governments did not always align with the 
local priorities: in their views, more participation of local/regional authorities during the 
development of the RRP could have resulted in a more efficient use of the funds to target 
local  priorities201.  For  investment  involving  local  authorities,  such  as  for  example  the 

196   According to stakeholders interviewed as part of the supporting study and to national stakeholders surveyed as part 

of the supporting study, see pages 154 to 156 of the supporting study. 

197   See European Commission (2023) Communication from the Commission to the European Parliament and the 

Council on the Recovery and Resilience Facility: Two years on (COM(2023) 99 final), available at 
https://commission.europa.eu/publications/communication-implementation-recovery-and-resilience-facility-0_en.  
198  See  Zeitlin  et  al.  (2023),  available  at:  https://feps-europe.eu/wp-content/uploads/2023/06/Governance-RFF.pdf; 
Carrosio  et  al.  (2022),  available  at:  https://feps-europe.eu/wp-content/uploads/2022/12/RECOVERY-WATCH-
Placed-Based-PP-1.pdf;  Bokhorst  and  Corti  (2023),  available  at:  https://www.cambridge.org/core/services/aop-
cambridge-
core/content/view/9A8DD6FA42CE44B44F4BD956B8EB0887/S0017257X23000143a.pdf/governing-europes-
recovery-and-resilience-facility-between-discipline-and-discretion.pdf;  and  Vanhercke  and  Verdun  (2021), 
available at: https://onlinelibrary.wiley.com/doi/full/10.1111/jcms.13267.  

199   Decisions on the national governance of the RRF are within the responsibility of the Member States. There are also 

examples of strong regional involvement present in some plans. 

200   Evidence in this paragraph is sourced from the supporting study, see pages 148 to 152. 
201   Regions for EU Recovery (2022) Benchmark study on the implementation of the RRF at regional level, available 
at:https://exteriors.gencat.cat/web/.content/Noticia/afers_exteriors/2022/pdf_220630_estudi_regions_4EU_recove
ry.pdf.  

58 

 
 
construction  of  childcare  facilities202,  some  challenges  have  emerged  as  negatively 
affecting  the  implementation  of  the  measures,  notably:  the  lack  of  resources  to  cover 
recurrent costs, the tight timeline and lack of technical capacity of municipalities to present 
projects in time, and the lack of qualified personnel to run the new infrastructures.  

4.2.3. Cost-benefit assessment 

In the absence of a counterfactual, quantifying the ‘benefits’ of the RRF to compare them 
to the ‘costs’ requires using macroeconomic models to estimate the benefits of the RRF. 
The  results  of  the  macro-economic  simulations,  both  in  the  evaluation  study  (NiGEM 
model) and by the Commission (QUEST model), have been presented in section 2. At this 
juncture, it is too early to go further. A full cost-benefit analysis will be conducted as part 
of the ‘ex-post’ evaluation.  

As it is a new instrument, the RRF created inevitable entry costs, but with differences 
across  Member  States.  An  overview  of  the  administrative  costs  incurred  by  Member 
States in implementing the RRF was established based on a survey of national coordination 
bodies203. The latter have counted the number of full-time equivalents (‘FTEs’) involved 
both for one-off and recurrent activities linked to the implementation.  While there were 
significant  variations  across  Member  States  in  FTEs  declared  by  coordination  bodies  – 
from a handful of FTEs in some Member States to over 100 FTEs in other – the survey 
results  demonstrate  that  there  have  generally  been  high  entry  costs  for  national 
administrations  to  become  familiar  with  the  functioning  of  the  RRF.  According  to 
representatives of most Member States (17 out of 21 for which feedback was provided), 
the  implementation  of  the  RRF  required  new  skills  and  knowledge  as  national 
administrations  were  not  familiar  with  all  formal  requirements  for  implementing  RRF 
projects, especially those related to reporting and verification based on results.  

The variations in administrative costs incurred by Member States depend on specific 
characteristics of the RRPs, such as the financial size of the plan or the number of 
measures  devoted to investments. As many administrative tasks are not  related to  the 
size  of  a  plan,  smaller  plans  tend  to  be  relatively  more  costly  than  larger  plans.  For 
example, in Germany and Poland (which have the two largest RRPs among those for which 
administrative costs are available), the administrative costs per euro of funding are notably 
low204. The total number of measures supported, in particular the number of investments, 
and the number of final recipients also matter: more investments and more final recipients 
is associated with more administrative workload.  

Similar to other instruments, the administrative costs linked to the implementation 
of the RRF have increased over time205. Most respondents (72%) in the survey of national 
authorities convey that the costs linked to the implementation of the RRF have increased 

202   See case study on ‘Early Childhood Education and Care’ included in the supporting study. 
203   Evidence in this paragraph is sourced from the supporting study, see pages 138 to 148. 
204   See page 146 of the supporting study. 
205   According to most respondents (72%) in the survey of national coordination bodies. Evidence in this paragraph is 

sourced from the supporting study, see pages 138 to 148. 

59 

 
 
over time206. However, only 18% of the respondents rated the increase as substantial. The 
cost increase is attributed to the demanding reporting requirements, as well as audit and 
control  requirements,  which  turned  out  to  be  more  extensive  than  initially  anticipated. 
Meeting them has required more resources,  time, and personnel  than initially expected. 
The implementation in the first half of the lifetime of the RRF has been  described as a 
‘learning-by-doing' experience by many stakeholders, including Member States and local 
or regional authorities. The administrative costs generated by the RRF vary significantly 
across Member States, with findings affected by the availability of data and governance 
choices concerning the implementation of RRPs at national level. In some Member States 
(e.g. Bulgaria, Estonia, Lithuania), existing structures have been adapted to manage the 
RRF, while in others (e.g. Belgium, Croatia, Portugal) new structures have been set up to 
coordinate the implementation of the RRP (e.g. new directorate or task force). Overall, the 
cost increase over time is however comparable to similar investment programmes, such as 
the  Cohesion  Policy.  Indeed,  for  the  Cohesion  programming  period  2014-2020,  the 
administrative workload has built up from the start of the programme preparation to reach 
a  peak  in  2017-2018,  and  then  declined  towards  closure  after  2022207.  Over  time,  the 
administrative burden associated with the RRF is expected to decrease as Member States 
authorities gain more experience. 

In particular, Member States have highlighted the need to mobilise more resources 
than initially planned to revise the RRPs. According to Member States208, the efficiency 
of the performance-based approach is reduced by the ‘excessively complex procedures’ for 
the plan modifications enshrined in the RRF Regulation, which do not distinguish between 
major or minor amendments and require Council approval for any modification.  

So  far,  the  implementation  of  the  RRF  has  not  brought  the  administrative 
simplification that Member States had hoped for209. Member States consider that the 
CIDs are too detailed given that every element must be checked at the relevant payment 
request – and that not every element should be binding. The legally binding character of 
each element included in the CID, including in the description of the measure, has been 
reinforced  by  the  strict  interpretation  of  the  European  Court  of  Auditors.  Likewise, 
stakeholders, notably Member States authorities, predicted that the administrative burden 
would remain higher compared to projects financed under  EU Cohesion  Policy. This is 
because, while Member States need to demonstrate the fulfilment of milestones and targets 
(as  disbursements  are  based  on  performance)  –  a  process  that  is  perceived  as  very 
demanding  by  Member  States  –  they  are  also  required  to  collect  evidence  of  the 
expenditure incurred as well as data on final recipients of RRF funds, for audit and control 
purposes210. This may be exacerbated by the coexistence of the two EU funding instruments 

206   See pages 138 to 148 of the supporting study.  
207   See  European  Commission  (2018)  Development  of  a  system  of  common  indicators  for  European  Regional 
at: 

Development 
https://ec.europa.eu/regional_policy/sources/studies/indic_post2020/indic_post2020_p1_en.pdf.  

interventions 

Cohesion 

available 

2020, 

Fund 

Fund 

after 

and 

208   Evidence in this paragraph is sourced from the supporting study, see pages 148 to 152. 
209   According to the results of the consultation with Member States’ RRF national authorities. 
210   Article 22(d) of the Regulation (EU) 2021/241 establishing the Recovery and Resilience Facility. 

60 

 
 
(RRF and structural funds) with two different approaches (performance-based and costs-
based). Overall, the requirements to protect the financial interests of the Union can lead to 
an administrative burden similar to that of other EU funds based on costs, such as Cohesion 
Policy funds211. Furthermore, the evidence provided by Member States, for each payment, 
to prove the delivery of concrete outputs (milestones and targets) is also essential to ensure 
their actual ‘performance’. 

4.3. Coherence 

4.3.1. Coherence of the RRF with other EU instruments 

The scope of the RRF, as reflected in the six pillars anchored in the RRF Regulation, 
broadly covers the main policy areas of EU relevance, with a specific focus on the EU’s 
twin transition via the climate and digital targets. The general coherence of the RRF with 
key EU policies is therefore ensured by the design of the RRF and reflected in the RRPs 
in  diverse  areas,  including  green,  digital,  social  and  rule  of  law.  Moreover,  the  strong 
coordination between the different services of the European Commission in designing and 
implementing the RRPs helped ensure coherence between the RRPs and Union policies. 

European Semester 

The RRF is in line with the European Semester priorities and has provided a novel 
and significant incentive to reinforce the implementation of CSRs. First, the European 
Semester  provides  a  framework  for  the  preparation  of  RRPs.  RRPs  are  “expected  to 
contribute to effectively addressing all or a significant subset of challenges identified in 
the relevant country-specific recommendations”212 adopted in the context of the European 
Semester. All RRPs were assessed against this criterion and needed to reach the highest 
(‘A’) rating for their plan to be approved. In this sense, EU priorities – tailored to Member 
States’ needs – guided the reforms and investments put forward in RRPs. In turn, the RRF 
offered financial incentives to implement the policy advice given under the Semester and 
has reinforced the implementation of the CSRs (see above under “effectiveness”). In other 
words, the RRF contributed to strengthening the link between EU funds and the European 
Semester,  which  in  turn  contributed  to  bringing  long-awaited  structural  reforms  into 
fruition, across a wide range of policy areas. The positive interactions213 between the RRF 
and the Semester are mutually beneficial214: the EU Semester supports the preparation of 
RRPs, while the RRF, in turn,  supports the  implementation  of the policy advice issued 
under the European Semester. By providing financial incentives in return for a coherent 
package  of  public  investments  and  reforms,  the  RRF  gave  European  governments 

211   According to results of the survey of RRF national authorities conducted as part of the supporting study, see pages 

152 to 154 of the supporting study. 
212   See Article 19(b) of the RRF Regulation. 
213   See pages 74 and 251 of the supporting study. 
214   Moschella, M. (2020) What role for the European Semester in the recovery plan? In-depth analysis requested by 

ECON Committee, available at: 
https://www.europarl.europa.eu/RegData/etudes/IDAN/2020/651377/IPOL_IDA(2020)651377_EN.pdf.  

61 

 
 
additional  means  to  overcome  domestic  institutional  resistance  in  the  face  of  Semester 
tools and recommendations215. 

The implementation of the RRF has been integrated in the European Semester, with 
reporting processes streamlined to limit the administrative burden both at national 
and  Commission  level.  The  European  Semester  and  its  national  reform  programmes 
offered  a  platform  for  the  bi-annual  reporting  under  the  RRF.  At  the  same  time,  the 
European Semester, and in particular the Country Reports, have been the key tool for the 
European  Commission  to  regularly  report  on  the  monitoring  of  RRP  implementation, 
making  the  implementation  of  the  RRF  a  key  part  in  EU  economic  coordination  and 
surveillance. The 2022 and 2023 European Semester both focused on the implementation 
of the RRPs, with CSRs focusing on the implementation of each Member States’ RRP216. 
In that sense, the RRF has been implemented in full coherence with the European Semester, 
limiting to the extent possible the increase in administrative burden that reporting on RRF 
implementation places on both national administrations and the EU. 

Technical Support Instrument (‘TSI’) 

Coherence between the RRF and the TSI is due to built-in synergies between the two 
instruments  and  the  alignment  of  their  assessment  criteria217.  The  RRF  Regulation 
actively  promotes  synergies  between  the  RRF  and  TSI  by  enabling  Member  States  to 
allocate up to 4% of their total allocation to technical support in RRP implementation218, 
an option used by four Member States219. The alignment of the assessment criteria of the 
RRF and of TSIs emphasises that both instruments have the same policy objectives and 
that  their  priorities  are  aligned.  For  example,  the  relevance  of  CSRs  is  one  of  the 
assessment  criteria  used  both  for  selecting  TSI  projects  and  for  approving  RRPs.  The 
coherence of the two instruments  is  evident in  the fact  that over 400 projects  approved 
under the TSI are linked to the preparation or implementation of Member States’ RRPs, 
highlighting the crucial role of TSIs in the Facility. 

Cohesion Policy 

With  the  parallel  implementation  of  the  RRF  and  Cohesion  Policy  programmes, 
Member States had to make strategic decisions in coordination with the Commission 
on the funds to use to finance investments. While double funding is prohibited, also in 
line with the Financial Regulation, a measure can be financed by both instruments as long 

215   Vanhercke B., and Verdun A. (2021) From the European Semester to the Recovery and Resilience Facility. Some 
social 
https://www.etui.org/sites/default/files/2021-
available 
11/From%20the%20European%20Semester%20to%20the%20Recovery%20and%20Resilience%20Facility_Som
e%20social%20actors%20are%20not%20resurfacing_2021.pdf.  

resurfacing, 

actors 

(not) 

are 

at: 

216   See  2022  European  Semester:  Spring  Package,  available  at:  https://commission.europa.eu/publications/2022-
european-semester-spring-package_en;  and  2023  European  Semester:  Spring  Package,  available  at: 
https://commission.europa.eu/publications/2023-european-semester-spring-package_en.  

217   Evidence in this paragraph is sourced from the supporting study, see pages 158 to 159. 
218   This can be achieved through transfers from national funds to TSI or by utilising transfers from the RRF to TSI. 
219   Romania, Croatia, Greece, and Cyprus have so far used these options, financing eight additional projects lined to 
their  RRPs  in  the  areas  of  healthcare,  education,  public  procurement,  energy,  better  regulation,  administrative 
burden reduction and investment promotion. More info available at: https://reform-support.ec.europa.eu/what-we-
do/recovery-and-resilience-plans_en.  

62 

 
 
as the same cost is covered only once, and as long as the RRF does not cover the mandatory 
national co-financing under Cohesion. The regulatory framework220 gives the responsibility 
to national authorities to ensure that the two instruments complement each other.  

To  ensure  synergies  and  avoid  overlaps  between  Cohesion  Policy  and  the  RRF, 
demarcations between the two have been included in national plans. Member States 
have put in place four approaches to demarcation, in a typology proposed by Lopriore221 
and by ECA222: (i) a thematic demarcation to reserve certain areas of funding exclusively 
for  the  RRF  (for  example  in  the  health  sector);  (ii)  a  territorial  demarcation  within 
individual sectors (for example the French RRP focuses on mobility in rural areas while 
the  European  Regional  Development  Fund  (‘ERDF’)  finances  it  in  urban  areas);  (iii)  a 
demarcation  based  on  the  typologies  of  beneficiaries  (for  instance,  the  German  RRP 
supports  the  energy  efficiency  of  residential  buildings  with  the  RRF,  while  support  for 
non-residential buildings comes from the ERDF); (iv) a temporal demarcation, with the 
absorption of funds based first on RRF resources and then on Cohesion Policy funds (with 
some  substitution  effects  between  the  two  instruments).  The  thematic  demarcation  has 
been the most frequently adopted approach by Member States223.  

However, some risks of substitution effects between RRF and Cohesion Policy have 
materialised224. The risk of possible substitution effects between the RRF and Cohesion 
Policy was only partially considered by Member States when drafting their RRPs. When 
RRPs  were  submitted  in  2021,  most  Operational  Programmes  under  Cohesion  for  the 
period  2021-2027  were  not  designed  yet.  Several  Member  States  did  not  adopt  ex-ante 
strategies to create synergies between the two EU funds. Evidence of substitution effects 
generated  by  the  RRF  to  the  detriment  of  cohesion  policy  has  been  reported  by 
interviewees concerning the 2021-27 programmes, while no significant substitution effect 
was reported for the 2014-20 operational programmes, as their implementation was already 
well  advanced  when  the  RRF  was  set  up.  In  some  Member  States,  some  more  mature 
projects  (e.g.  in  Spain,  Greece,  Italy  and Romania)  that  were previously  planned under 
Cohesion  instruments  (and  expected  to  be  implemented  under  2021-2027  cohesion 
programmes) were moved into the RRPs225. In Spain and Greece, the shift can be explained 
by  (i)  the  fact  that  the  RRP  was  prioritised,  (ii)  expectations  of  a  lower  administrative 
burden compared to cohesion, and (iii) the absence of national co-financing requirement. 
In Romania, the shift did not create difficulties due to significant investment gaps and the 
existence of an extensive pipeline of projects. The example of Romania shows that possible 
substitution  effects  depend  on  national  contexts:  in  Member  States  with  substantial 

220   See Article 28 of the RRF Regulation, Articles 11 and 22(3)(a) of Regulation (EU) 2021/1060. 
221   Lopriore,  M.  (2022)  Recovery  plans  and  structural  funds:  how  to  strengthen  the  link?,  available  at: 
https://www.eipa.eu/publications/briefing/recovery-plans-and-structural-funds-how-to-strengthen-the-link/.  
222   European  Court  of  Auditors  (2022)  Cohesion  and  NextGenerationEU:  concord  or  clash?,  available  at: 

https://www.eca.europa.eu/Lists/ECADocuments/JOURNAL22_01/JOURNAL22_01.pdf. 

223   According to results of the survey of RRF national authorities, see page 166 of the supporting study. 
224   Evidence in this paragraph is sourced from the supporting study (see pages 176 to 177) and from the associated case 

study on the functioning of the RRF and other EU funds. 

225   See pages 176 to 177 of the supporting study and the associated case study on the functioning of the RRF and other 

EU funds. 

63 

 
 
investment  gaps  in  traditional  sectors,  there  seems  to  be  a  lower  risk  of  displacement 
between the two instruments, and RRF resources are added to cohesion funding to tackle 
existing  needs.  In  addition,  some  Member  States  (e.g.  Slovenia)  have  redirected  staff 
previously  working  on  Cohesion  Policy  to  the  RRP  coordination  and  implementation 
bodies  to  accelerate  RRP  implementation,  delaying  the  implementation  of  Cohesion 
Policy226.  

At  the  same  time,  some  investments,  initially  introduced  in  the  RRPs,  but  then 
withdrawn  during  the  RRPs  revisions,  could  potentially  be  moved  to  Cohesion 
instruments.  In  Greece  for  example,  the  revised  RRP  which  was  submitted  to  the 
Commission in August 2023 withdrew some investments (in the water sector) from the 
RRP due to implementation delays beyond the control of the government. Given the longer 
eligibility period under Cohesion funds, Greece could potentially consider options to cover 
them under Cohesion Policy.  

There  is  a  large  potential  for  synergies  between  the  RRF  and  Cohesion  Policy. 
Synergies can be achieved, among others, by financing, different policy interventions with 
each  instrument  that  build  on  each  other  in  the  same  policy  area,  or  by  using  the  two 
instruments to finance different elements of the same investment. The possibility to use 
the two funds for the same investment has been used by a number of Member States. The 
Austrian  RRP,  for  example,  supports,  with  RRF  funds,  some  additional  sections  of  the 
construction  and  electrification  of  regional  railway  lines  that  already  benefit  from  the 
Connecting  Europe  Facility.  In  Bulgaria,  the  RRP  covers  the  set-up  of  newly  built 
‘Science,  Technology,  Engineering  and  Mathematics’  (STEM)  laboratories,  including 
high-tech classrooms in schools, while ESF+ covers the trainings of teachers. Synergies 
can also be achieved when reforms supported by the RRF benefit investments supported 
by structural funds (or national funds). For example, in Greece, the RRP supports a reform 
of the railway sector, to strengthen the rail infrastructure manager improve safety, service 
delivery  and  efficiency  in  delivering  new  investments  under  the  ERDF  and  CEF.  In 
Hungary, 
improving  public  procurement  systems, 
complemented  with  the  introduction  of  a  training  scheme  for  SMEs  to  facilitate  their 
participation  in  public  procurement  procedures.  ERDF  interventions  will  complement 
these measures by providing training and support to SMEs (particularly in less developed 
regions). The Portuguese RRP includes a reform on the administrative modernisation and 
digital transition of the central public administration, which is complemented by the ERDF 
and finances the digital transition of local and regional public administration. The Italian 
RRP includes a reform of the regulatory and market framework to improve the efficiency 
and  effectiveness  of  public  investments  in  the  water  sector,  which  will  help  address 
existing barriers to ERDF investments to improve sustainable water management. Under 
the RRF, Slovakia updated its legal framework to facilitate connecting new renewables to 
the grid. As part of the 2021-2027 Partnership Agreement with Slovakia, investments are 

the  RRP 

includes 

reforms 

226   Although  Slovenia’s  absorption of  Cohesion Policy  has  always  been  low  in initial  years  of  a  new  multi-annual 

financial framework. 

64 

 
 
expected to develop smart energy systems, grids, and storage, complementing the reform 
supported by the RRF. 

However, at this juncture, there is still limited evidence of synergies materialising. 
The literature227 has recognised that achieving synergies between RRF and Cohesion Policy 
is  challenging,  including  because  of  the  need  for  deeper  strategic  and  operational 
cooperation228 and difficulties in aligning schedules and procedures of different funds229. 
The European Committee of the Regions230 also noted that, as RRPs only partially address 
the territorial dimension, potential synergies with Cohesion Policy funds are limited.  

As  the  implementation  of  the  RRF  progresses,  synergies  between  RRF-supported 
reforms and Cohesion Policy investments are expected to increase231. The possibilities 
for thematic overlaps could  be exploited to  achieve additional impacts, also  taking into 
account existing financing gaps232. The policy progress made under the RRF, for example, 
in  mainstreaming  DNSH  considerations  will  also  be  paying  off  for  structural  funds, 
according  to  stakeholders  involved  in  the  implementation  of  Cohesion  Policy.  More 
generally,  the  reforms  supported  by  the  RRF  are  expected  to  improve  framework 
conditions for investments under Cohesion Policy. Lastly, stakeholders233 were of the view 
that it would be useful to build on the lessons learnt from the RRF features that have proved 
helpful, such as pre-financing and the support for both reforms and investments under one 
instrument.  Identifying  which  RRF  supported  measures  should  be  taken  forward  under 
cohesion (considering existing financing gaps) could help avoid a disconnect between what 
is done under RRF and what can be done in the longer run under cohesion. For instance, 
the Portuguese RRP supports initial investments in the hydrogen sector with the RRF, with 
the Portuguese authorities intending to follow up with Cohesion Policy funds234. 

4.3.2. Coherence with Member States’ instruments supporting the economic recovery 

227   See  European  Policies  Research  Centre  (2021)  The  Recovery  &  Resilience  Fund:  an  economic  stimulus  at  the 
expense of territorial cohesion?, available at: https://eprc-strath.org/eu/the-recovery-resilience-fund-an-economic-
stimulus-at-the-expense-of-territorial-cohesion/; and Bachtler, J., and Mendez, C. (2021) Recovery and Cohesion: 
https://eprc-strath.org/wp-
Ambitious 
content/uploads/2021/12/EoRPA-Report-21_2-Cohesion-Policy_-ISBN-version-3.pdf.  

Implementation, 

Challenging 

Objectives, 

available 

at: 

228   European Policies Research Centre (2021) The Recovery & Resilience Fund: an economic stimulus at the expense 
of territorial cohesion?, available at: https://eprc-strath.org/eu/the-recovery-resilience-fund-an-economic-stimulus-
at-the-expense-of-territorial-cohesion/; and Ferry, M., and Kah, S (2021), Pursuing Positive Interactions – within 
Structural  Funds  and  with  the  RRF,  available  at:  https://eprc-strath.org/wp-content/uploads/2021/11/IQ-Net-
Thematic_Paper_50_Post_Conference.pdf.  

229   Lopriore,  M.  (2022)  Recovery  plans  and  structural  funds:  how  to  strengthen  the  link?,  available  at: 
https://www.eipa.eu/publications/briefing/recovery-plans-and-structural-funds-how-to-strengthen-the-link/.  
230   European Committee of the Regions (2021) Regional and local authorities and the national recovery and resilience 

plans, available at: 
https://cor.europa.eu/en/engage/studies/Documents/Regional%20and%20local%20authorities%20and%20the%20
National%20Recovery%20and%20Resilience%20Plans/NRRPs_study.pdf.  

231   Evidence in this paragraph is sourced from the supporting study (see pages 176 to 177) and from the associated case 

study on the functioning of the RRF and other EU funds. 

232   See the case study on case study on the functioning of the RRF and other EU funds included in the supporting study. 
233   As  mentioned  by  stakeholders  in  the  validation  workshop  organised  on  24  October  2023,  in  the  context  of  the 

supporting study.  

234   Lopriore,  M.  (2022)  Recovery  plans  and  structural  funds:  how  to  strengthen  the  link?,  available  at: 
https://www.eipa.eu/publications/briefing/recovery-plans-and-structural-funds-how-to-strengthen-the-link/. 

65 

 
 
The  RRPs  were  implemented  in  full  coherence  with  Member  States’  national 
recovery strategies235. In Member States that had already put in place a post-pandemic 
recovery plan, for example France or Germany, the RRP built on, or integrated, the already 
planned measures and either replaced or further expanded them (since the RRF allowed to 
support measures that started from 1 February 2020). In fact, 18 Member States included 
a total of 150 milestones and targets in their RRPs whose implementation started after 1 
February 2020236, but were scheduled to be completed before the RRPs were submitted to 
the Commission in 2021/2022237. For Member States that did not yet have a recovery plan, 
the  RRPs  became  the  national  government’s  strategic  plans  for  the  recovery  after  the 
pandemic. The  relatively  short time span during which the RRPs  were drafted by most 
Member States, together with the medium-term horizon of the RRF implementation (until 
2026), allowed national authorities to develop RRPs that were coherent with the already 
existing or planned investments and reforms. 

4.3.3. Internal coherence of the RRPs 

The RRPs also provided for a coherent set of reforms and investments. The internal 
coherence of the measures put together by Member States in their RRPs was a criterion 
evaluated  by  the  Commission  when  assessing  the  plans.  The  overall  Commission 
assessment  on  the  coherence  of  RRPs  is  very  positive  (high  extent  –  Rating  A).  As 
discussed earlier, the combination of reforms and investment under one sole instrument is 
considered as one of the most effective aspects of the RRF238. 

How did the EU intervention make a difference and to whom? 

4.4. EU added value 

In the absence of a counterfactual, the additionality of the RRF appears difficult to assess 
and even more difficult to quantify. At the mid-term point, qualitative evidence, notably 
the outcomes of interviews carried out with national stakeholders in charge of designing 
and  implementing  the  RRPs,  provides  a  first  hint  regarding  the  EU  added  value  of  the 
instrument. 

4.4.1. Scale of RRF financing and additionality of measures supported by the RRF 

The scale of the RRF’s financial support is an important element to take into account 
when assessing the additionality of the instrument. With up to EUR  723.8 billion in 
total for 2021-2026  (EUR  385.8 billion in  loans and  EUR  338 billion  in non-repayable 
support),  and  additional  REPowerEU  resources  (EUR  20  billion  in  new  non-repayable 
support and EUR 2.1 billion of funds from the Brexit Adjustment Reserve), the size of 
RRF is unique in the EU (the closest in scale is the amount of resources mobilised under 
Cohesion Policy: EUR 543 billion for 2021-2027, of which EUR 377 billion in EU co-

235   Evidence in this paragraph is sourced from the supporting study, see pages 170 to 172. 
236   As per Article 17(2) of the RRF Regulation. 
237   Data is not yet available on the eligible REPowerEU measures that started from 1 February 2022. 
238   As reported by stakeholders in the Member States’ national RRF authorities and across the European institutions. 

66 

 
 
financing and EUR 166 billion in national co-financing). With its pre-financing, the RRF 
provided Member States with significant fiscal space in the aftermath of the COVID-19 
pandemic, thereby playing a stabilising effect at that critical juncture. Unlike other crises, 
the level of public investment has been preserved in the EU post-COVID and has increased 
in  a number of Member States (see Section  4.1.4). Moreover, the announcement of the 
RRF  has  contributed  to  reducing  sovereign  bond  spreads  in  the  EU  at  the  time  of  the 
COVID  shock,  which  in  turn  helped  mitigating  risks  of  financial  fragmentation  and 
supporting the recovery (see Section 4.4.3).  

The additionality of the RRF in individual Member States is correlated to the size of 
the financial support provided. A relevant proxy is the RRP allocation as a share of GDP, 
which varies from 16% in Greece to 0.1% in Luxembourg. For Member States where the 
RRF represents an important share of GDP, the RRF provided additional fiscal space to 
implement investments that would otherwise have been unlikely. For example, in the area 
of ‘Early Childhood Education and Care’, the primary contribution of the RRF has been to 
infuse fresh financial resources to support the expansion of childcare facilities239. In Italy 
and Spain (where the RRP allocation account respectively for 11% and 6% of GDP), the 
RRF  resources  were  reported  to  be  additional:  stakeholder  interviewees  explained  that, 
without the RRF, the investments in ‘Early Childhood Education and Care’ would not have 
taken  place.  In  Belgium,  the  RRF  funds  were  also  reported  as  additional,  topping  up 
already  existing  national  funds.  In  Poland,  RRF  funding  was  reported  as  additional, 
complementing  other  EU  funding  –  notably  funds  from  ESF+  and  national  funding.  In 
Germany, however, where the RRF accounts for around 0.7% of GDP, all funding under 
the RRF for investments in ‘Early Childhood Education and Care’ was reported as already 
budgeted for, and thus the EU added value of the RRF, in terms of support for investments, 
was limited.  

More  generally,  the  additionality  of  the  RRF  highly  depends  on  Member  States’ 
specific  situations,  in  particular  on  whether  the  Member  State  already  had  in  place  a 
national  recovery  plan  when  the  RRF  entered  into  force.  In  some  Member  States  (for 
example  Germany  or  France),  the  investments  supported  by  the  Facility  were  already 
planned in national recovery plans and the RRF mainly provided additional resources to 
implement and scale-up these investments. In the case of Germany, more than 80% of the 
the  June  2020 
investments 
Konjunkturprogramm240. In the case of France, the RRF exclusively finances investments 
included  in  the  national  plan  ‘France  Relance’  that  was  set  up  in  September  2020 
(financing  40%  of  the  EUR  100  billion  national  plan).  In  that  case,  the  RRF  provided 
additional  fiscal  space  to  scale-up  investments  already  envisaged,  therefore  enabling  to 
increase the ambition of the national plan. For other Member States (for example Italy and 

the  RRP  were  already 

included 

included 

in 

in 

239   According to semi-structured interviews conducted in the context of the case study on ‘Early Childhood Education 

and Care’ included in the supporting study. 

240   See Corti, F., Gros, D., Liscai, A., Ruiz, T., Kiss-Galfalvi, T., Gstrein, D., Herold, E., Dolls, M., and Fuest, C. 
(2022) The European added value of the Recovery and Resilience Facility: An assessment of the Austrian, 
Belgian and German plans, available at: 
https://www.europarl.europa.eu/RegData/etudes/STUD/2022/699513/IPOL_STU(2022)699513_EN.pdf.  

67 

 
 
Greece), the investments supported by the RRF would not have taken place otherwise, at 
least not in the same timeframe241.  

Stakeholders’ assessment of the additionality of the RRF has been positive overall but 
not  unanimously  so.  The  results  from  the  public  consultation242  show  that  around  two 
thirds  of  respondents  consider  that  the  RRF  has  contributed  to  the  economic  recovery 
following the pandemic and a similar share recognises the RRF’s contribution to the green 
and digital transitions. Most respondents believe that the RRF contributed to the initiation 
and implementation of reforms. A vast majority of stakeholders (around 80%) consider 
that the RRF produced, at least to a limited extent, more results than what Member States 
could  have  achieved  on  their  own.  However,  about  25%  of  respondents  (in  both  the 
national coordinator survey and the public consultation) do not agree with the view that 
the  measures  supported  by  the  RRF  would  not  have  been  implemented  otherwise.  For 
example, feedback from targeted interviews243 conveys that, in some Member States, such 
as Austria or Sweden, the reforms included in the RRPs had already been on the political 
agenda. This  is  also  related to  the  fact that, in  line with the  possibility  for retroactivity 
(under strict conditions)  provided by the RRF Regulation, 13% of the 1,153 milestones 
and targets fulfilled as of 1 February 2024 have been implemented before the date of the 
official endorsement of the RRPs. However, this does not necessarily mean that the related 
measures would have taken place without the RRF, as the drafting of the plans already 
began in September 2020 and several Member States started implementing measures in 
anticipation of RRF funding244. Moreover, the poor track record of reform implementation 
under the European Semester CSRs before the RRF contradicts the perception that RRF 
supported reforms may have happened anyway.  

The country-specific EU value added can be well illustrated by the example of ALMP 
measures245,  where  the  main  added  value  of  the  RRF  stems  from  the  combination  of 
investments with strategic reforms to address structural labour market challenges under a 
clear timeframe. All measures related to ALMP in the French RRP were developed prior 
to the RRP negotiation, as part of the plan ‘France Relance’, and would likely have been 
implemented  with  national  funding246.  In  Spain  and  Italy  on  the  other  hand  the  Facility 
appears to have provided an impetus for reform in some cases. In Spain, the modernisation 
of ALMPs was included in the government mandate agreed at the end of December 2019. 
At  the  same  time,  a  reform  on  hiring  incentives  that  had  not  advanced  for  years  was 
included  in  the  RRP,  highlighting  a  potential  added  value  of  the  RRF.  In  Italy,  an 
investment  on  strengthening  public  employment  services  would  have  been  partially 
implemented in the absence of RRF funding, however the Facility provided an additional 

241   According to interviews conducted in the context of the case studies included as part of the supporting study, see 

page 16 of the supporting study. 
242   See page 293 of the supporting study. 
243   See page 302 of supporting study. 
244   See page 218 of the supporting study. 
245   Evidence  in  this  paragraph  is  sourced  from  the  case  study  on  ‘Active  Labour  Market  Policy’  included  in  the 

supporting study. 

246   According to stakeholders interviewed in the context of the case study on ‘Active Labour Market Policy’ included 

as part of the supporting study. 

68 

 
 
EUR 200 million in financial support. In addition, it is unlikely that an ALMP reform on 
training  would  have  been  implemented  without  the  resources  provided  by  the  RRF. 
Finally, EU added value is most apparent in Croatia RRP, as the RRF provided a significant 
impetus for the introduction of new measures in ALMP overall. Some of the measures – 
specifically, the new targeted ALMP – already existed in a similar form and could have 
been implemented through ESF+, but the RRF allowed for additional funding and support 
for more specific and targeted measures. 

4.4.2. Convergence and supporting the Single Market 

By design, the RRF is expected to strengthen economic convergence in the EU. With 
its allocation key, the RRF was designed to support lower-income and more vulnerable 
Member States, which had also been hit the hardest by the pandemic. The RRF’s allocation 
of funding thus helps counteract the economic divergence, fostering economic stability and 
growth where it is most needed.  

The  RRF  is  also  expected  to  trigger  spillover  effects  that  are  benefiting  the  Single 
Market. The pandemic had introduced substantial risks to the functioning of the Single 
Market, with risks of lasting disparities in living standards and increased divergence within 
the Union. With its large financial support, the effects of RRF spending in one EU Member 
State have positive spillover effects in the rest of the European Union (intra-EU trade). 
Cross-border  projects  (see  Section  4.4.6.  below)  also  contribute  to  increasing  potential 
spill-over effects fostered by the RRF. Corti et al. (2022)247 consider that these spillover 
effects  are  particularly  relevant  in  the  areas  of  green  transition  and  digitalisation  as 
neighbouring Member States benefit from investments in transport or digital infrastructure 
or other aspects concerning digital transformation, such as broadband expansion and 5G.  

4.4.3. Impact on spreads 

The announcement of the RRF has contributed to reducing sovereign bond spreads 
in the EU at the time of the COVID shock, which in turn helped mitigating risks of 
financial  fragmentation  and  supporting  the  recovery.  To  examine  the  effects  of  the 
announcement  on  spreads  of  NGEU  and  its  core  instrument,  the  RRF,  the  supporting 
study248249 measured the impact on spreads as ‘the initial decline in sovereign bond spreads 
that  was  recorded  within  three  weeks  of  the  18  May  2020  announcement  of  the  initial 
Franco-German  proposal  for  a  recovery  fund’  (taken  at  the  moment  announcing  the 
upcoming  NGEU).  The  results  show  that  a  reduction  in  the  spread  of  benchmark  bond 
yields over the benchmark, being German Bundesanleihen, between 15 May 2020 (April 
for  monthly  data)  and  5  June  2020  (June  for  monthly  data)  for  almost  all  EU  Member 

247   Corti, F., Gros, D., Liscai, A., Ruiz, T., Kiss-Galfalvi, T., Gstrein, D., Herold, E., Dolls, M., and Fuest, C. (2022) 
The European added value of the Recovery and Resilience Facility: An assessment of the Austrian, Belgian and 
German plans, available at: 

248   Following the approach by Bankowski, K., Bouabdallah, O., Domingues Semeano, J., Dorrucci, E., Freier, M., 
Jacquinot, P., Modery, W., Rodríguez-Vives, M., Valenta, V., and Zorell, N. (2022) The economic impact of 
NextGenerationEU: a euro area perspective, available at: 
https://www.ecb.europa.eu/pub/pdf/scpops/ecb.op291~18b5f6e6a4.en.pdf.  

249   Evidence in this paragraph is sourced from the supporting study, see pages 177 to 178. 

69 

 
 
States250.  There  was  a  reduction  of  between  50  and  100  basis  points  for  those  Member 
States higher borrowing costs. In addition, by using RRF loans to finance spending that 
would otherwise have been financed domestically, those Member  States  with  relatively 
high  borrowing  costs  have  been  able  to  take  advantage  of  the  European  Union’s 
advantageous  borrowing  conditions  to  reduce  the  costs  associated  with  the  increased 
borrowing  that  has  resulted  from  the  COVID  shock.  In  this  respect,  even  if  the  EU 
borrowing costs have increased significantly over the past months on the back of higher 
interest  rates,  these  increases  are  comparable  to  those  experienced  by  highly-rated  EU 
Member States. 

4.4.4. Support for the implementation of EU policies 

With its large financial envelope, the RRF provided substantial funding to advance 
the implementation of common EU policies. For example, the binding climate and digital 
targets for the RRPs, which required Member States to allocate respectively 37% and 20% 
of RRF funds to projects supporting the climate and digital transitions, ensure that at least 
half of RRF funds are dedicated to fostering the green and digital transitions, among other 
priorities. The RRF also contributes to the implementation of the European Pillar of Social 
Rights, which is one element of the RRF general objective: the scope of the RRF includes 
social cohesion and policies for the next generation, and social aspects are also covered by 
the country-specific recommendations that Member States are addressing in their RRPs, 
ensuring that measures supported by the RRF also support this EU priority. 

4.4.5. EU added value of the RRF in supporting politically challenging reforms 

The RRF has  helped speed up the implementation of  long-standing and  politically 
challenging reforms. In particular, the RRF supported the implementation of reforms that 
had been the subject of long-standing CSRs in the context of the European Semester, i.e. 
they were recommended by the Council  as the most important reforms  to be tackled in 
each Member State. Progressing on these EU priorities represents EU value added. This 
has included reforms that would have most likely not have taken place without the RRF, 
such as rule of law reforms and structural reforms251 (e.g. long-standing CSRs such as long-
term care in Slovenia and the reform concerning regulated professions in Portugal). Among 
other examples, CSRs such as the ‘Zero-emission company cars’ of the Federal State in 
Belgium  and  the  Online  Access  Act  in  Germany  would  most  likely  not  have  been 
implemented in the short term without the RRF252. 

The RRF provided EU added value as it enabled the simultaneous implementation of 
reforms  and  investments  across  the  EU,  which  created  additional  impact253.  As 
evidenced  above,  the  simultaneous  implementation  of  the  RRPs  in  each  Member  State 
created additional impact with spillover effects.  Along the same lines, the simultaneous 
implementation  of  structural reforms  that were tailored to  Member States  needs  creates 

250   Excluding Estonia (for data availability reasons) and Germany (where the spread is zero by definition). 
251   See pages 184 to 188 of the supporting study. 
252   See pages 184 to 188 of the evaluation study. 
253   Evidence in this paragraph is sourced from the supporting study, see page 184. 

70 

 
 
additional impact, as the overall impact of these individual reforms is economically more 
beneficial when conducted by several/all Member States (e.g. labour markets reforms) than 
when conducted in isolation. The RRF amplified this joint and coordinated response.  

The  RRF  brought  a  new  dimension  to  EU  funding  instruments  by  making  the 
financing  of  investments  conditional  upon  the  implementation  of  reforms.  Under 
Cohesion  Policy,  the  importance  of  linking  investments  to  enabling  frameworks  and 
structural reforms was already embedded, for instance, through the necessary fulfilment of 
ex-ante  conditionalities  (evolved  into  enabling  conditions)  as  a  prerequisite.  However, 
Cohesion  Policy  does  not  finance  structural  reforms  (with  some  exception  of  targeted 
public administration reforms with an associated cost)254. Interviewees from a broad range 
of institutions (among which national authorities, the Committee of the Regions and the 
Economic and Social Committee) recognised the RRF support for structural reforms as a 
crucial asset of the RRF and highlighted that it effectively filled a gap compared to the 
status quo255.  

4.4.6. RRF support for multi-country projects 

The  RRF  contributed  to  the  implementation  of  multi-country  projects,  notably 
supporting the green and digital transitions. The RRF includes support for investments 
that have a significant cross-border impact. Member States were encouraged to consider 
such projects, which reflect common priorities of (several) Member States and are aligned 
with the objective of promoting further integration and cooperation within the EU. The 
importance of multi-country projects has further been strengthened in the amendment of 
the  RRF  Regulation.  This  includes  an  additional  assessment  criterion  placing  a  strong 
cross-border  or  multi-country  focus  on  all  measures  introduced  under  the  REPowerEU 
chapter.  An  overview  of  RRPs  shows  that  most  of  them  include  measures  with  multi-
country projects256, with the majority contributing to the green and digital transitions. More 
than half of the RRPs include measures contributing to multi-country projects or cross-
border initiatives related to the green transition, with the Important Projects of Common 
European  Interest  (‘IPCEI’)  on  hydrogen  showing  the  highest  uptake.  Most  RRPs  also 
include measures contributing to multi-country projects or cross-border initiatives in the 
area of the digital transformation: the IPCEIs on microelectronics (12 RRPs) and cloud 
technologies (six RRPs) are amongst the multi-country projects with the highest take-up. 
Further contributions towards the digital transformation are also seen in cloud technologies 
(with six RRPs including IPCEI measures), the European Digital Innovation Hubs (eight 
RRPs), 5G corridors (seven RRPs) and quantum communication (four RRPs).  

The additionality of RRF funds is also reflected in the widened pool of Member States 
implementing multi-country and cross-border projects. There is a growing number of 

254   Such as the targeted reforms of labour market institutions and services under the ESF+ if they have an associated 

cost. 

255   See the case study on the functioning of the RRF and other EU funds included in the supporting study. 
256   European Commission (2022)  Report from the commission to the  European Parliament and the Council on the 
at 

the  Recovery  and  Resilience  Facility,  COM(2022)  75 

implementation  of 
https://commission.europa.eu/system/files/2022-03/com_2022_75_1_en.pdf. 

available 

final, 

71 

 
 
Member States participating in multi-country projects (most noticeably IPCEIs), especially 
in  Central  and  Eastern  Europe257.  The  scope  of  IPCEIs  (notably  hydrogen)  would  have 
likely been lower in the absence of the RRF funds and the Facility has provided a source 
of  funding  for  Member  States  and  an  opportunity  to  integrate  IPCEIs  in  national 
programmes258. The availability of RRF funds has enabled greater participation levels in 
multi-country  projects,  with  the  inclusion  of  Member  States  who  would  not  have 
participated otherwise259. 

However, some authors consider that the impact and full potential of such projects 
could have been better exploited. Corti et al.260 highlighted some missed opportunities 
for developing cross-border projects and in developing European public goods as part of 
the RRF. While theoretically cross-border projects carry huge potential for advancing the 
competitiveness of the European economy, Corti et al. argue that only a minor share of 
RRF-supported cross-border projects had so far an effective cross-border impact. This can 
mainly be attributed to the complexity of cross-border projects, which require more time 
in design (against the tight 2026 deadline) and see more challenges in implementation due 
to the multi-partner component. Furthermore, external factors (such as the war in Ukraine) 
also had a negative impact on the materialisation of multi-country projects.  

Is the intervention still relevant? 

4.5. Relevance 

4.5.1. Relevance of the RRPs 

Each RRP includes an agenda of reforms and investments that are relevant both to 
each Member State and for EU policy priorities. The reforms and investments covered 
in the RRPs relate to the CSRs, which concern important and relevant strategic measures 
tailored to Member States’ needs. At the same time, as CSRs respond to broader EU policy 
priorities,  the  implementation  of  the  measures  included  in  the  RRPs  also  support  the 
broader EU agenda. In particular, with the specific climate and digital targets, the RRF 
directly  contributes  to  the  twin  transformations  (green  and  digital)  of  Member  States’ 
economies, which is an overarching EU-wide policy for years to come. The results from 

257   Eisl, A. (2022) Important Projects of Common European Interest (IPCEIs) as a New Form of Differentiation: An 
the  European  Single  Market,  available  at:  https://euidea.eu/wp-

for 

Analysis  of  Their  Challenges 
content/uploads/2022/03/euidea_pp_18.pdf.  

258   According to stakeholders interviewed as part of the case study on cross-border and multi-country projects, with 
specific focus on IPCEIs; see pages 145 to 149 of the supporting study and the case study on cross-border and multi-
country projects, with specific focus on IPCEIs. 

259   See Dias, C., Grigaitè, K., and Cunha, I. (2021) Recovery and Resilience Plans – Thematic overview on cross-

border projects, available at: 
https://www.europarl.europa.eu/RegData/etudes/IDAN/2021/689472/IPOL_IDA(2021)689472_EN.pdf; and Eisl, 
A. (2022) Important Projects of Common European Interest (IPCEIs) as a New Form of Differentiation: An 
Analysis of Their Challenges for the European Single Market, available at: https://euidea.eu/wp-
content/uploads/2022/03/euidea_pp_18.pdf. 

260   See Corti, F., Gros, D., Liscai, A., Ruiz, T., Kiss-Galfalvi, T., Gstrein, D., Herold, E., Dolls, M., and Fuest, C. 

(2022) The European added value of the Recovery and Resilience Facility: An assessment of the Austrian, Belgian 
and German plans, available at: 
https://www.europarl.europa.eu/RegData/etudes/STUD/2022/699513/IPOL_STU(2022)699513_EN.pdf.  

72 

 
 
the  different  consultations  show  broad  support  for  the  relevance  of  the  RRF,  with  no 
interviewee questioning the relevance of the instrument261. 

The RRF remained relevant in an evolving context, demonstrating the flexibility of 
the instrument to adapt to changing circumstances. While the RRF was created in the 
context of the COVID-19 shock to support the economic recovery and enhance the EU’s 
resilience, the RRF implementation is taking place in a changing environment, marked by 
Russia’s invasion of Ukraine, high inflation, and an energy crisis. Thanks to the continued 
relevance of its main policy objectives and its delivery model, the amendment of the RRF 
Regulation  in  the context  of  REPowerEU in  2023, and the mechanisms included in  the 
RRF  Regulation  for  amending  RRPs  based  on  objective  circumstances  (Article  21), 
ensured that the RRPs remained relevant and well suited to address the new challenges. In 
late 2022 and 2023, all 27 Member States submitted revised RRPs, in line with the different 
venues  provided  by  the  RRF  Regulation  to  amend  RRPs  (objective  circumstances, 
additional loans and updated maximum financial contribution).  

Member  States  highlight  hurdles  in  amending  the  RRPs  in  comparison  to  other 
instruments, although the RRF single envelope of funds available to each Member 
State provides agility. Most national authorities stated that the process to modify RRPs 
was heavy and cumbersome262.  Whilst  it is recognised that  modifying RRPs has been a 
necessity,  given  the  plans  are  conceived  for  the  medium-term  to  2026,  most  national 
authorities did not perceive the instrument as sufficiently flexible. The most cited issues 
related  to  the  plans’  revisions  are  the  procedures  for  amending  RRPs,  which  do  not 
distinguish  between  small  and  major  adjustments  (unlike  what  has  been  agreed  for  the 
Social Climate Fund, the set-up of which has benefited from the experience made with the 
RRF, where minor adjustments to the Plans, or the correction of clerical errors, are simply 
introduced by Member States and notified to the Commission) and the significant time lags 
between  the  decision  at  national  level  to  modify  a  plan  and  the  final  approval  of  the 
modification  by  the  Council.  The  supporting  study  highlights  that,  in  comparison  with 
Cohesion  Policy,  the  RRF  framework  is  perceived  as  too  rigid:  this  stems  from  the 
perceived rigidity of the process for revising RRPs which is considered by stakeholders263 
as more burdensome than under EU Cohesion Policy. Nonetheless, despite the complexity 
conveyed by Member States, all Member States’ RRPs were revised in 2022-2023 (with 
an impact on the RRF speed of implementation in 2023 highlighted in Section 4.1.). In 
general,  while  the  process  for  amending  RRPs  is  perceived  as  cumbersome,  the  broad 
scope of the RRF provides flexibility. For example, in 2023, during the revisions of RRPs, 
some  Member  States  allocated  more  resources  on  energy  measures  in  the  wake  of  the 
energy crisis or took additional loans to prioritise such measures further. 

The allocation key used to apportion funds among Member States proved relevant to 
support economic convergence in the EU in the post-pandemic context. The allocation 

261   See pages 190 to 191 of the supporting study. 
262   Evidence in this paragraph is sourced from the supporting study, see pages 191 to 194. 
263   See case study on the functioning of the RRF and other EU funds included in the supporting study. 

73 

 
 
key264 applied to 70% of the non-repayable support is based on the population, the inverse 
of GDP per capita of 2019 and the relative average unemployment rate of each Member 
State.  The  allocation  key  applied  to  30%  of  the  non-repayable  support  also  takes  into 
account the change in real GDP in 2020 and 2021. Taking these factors into account has 
ensured  that  Member  States  in  greatest  need  would  benefit  the  most.  Results  of 
macroeconomic  models265  indeed  predict  that,  given  the  allocation  key,  Member  States 
with below-average levels of GDP per capita are expected to experience the largest boost 
to  GDP  levels.  For  a  6-year  stimulus  and  a  high-productivity  calibration,  the  estimated 
increase in output reaches more than 3.2% in Greece; around 3% in Bulgaria, Croatia, and 
Romania; and around 2.5% in Italy and Portugal. However, some Member States who in 
June 2022 experienced a downward revision of their maximum financial contribution for 
non-repayable financial support made it clear that that this caused internal delays in the 
RRP  implementation  due  to  the  need  to  either  revise  the  plan,  or  to  compensate  the 
decrease in EU financing with national resources.  

Because  of the time limited design of the instrument, there were  limitations  in  the 
selection  of  investments  included  in  RRPs.  The  2026  deadline  limits  the  types  of 
investments included in RRPs since it excludes investments that would have required more 
time to implement266. Especially for the REPowerEU chapters, most investments had to be 
relatively  mature  already  to  fit  within  the  RRF  timeline,  particularly  in  the  renewable 
energy sector. The 2026 deadline has therefore limited the ambitions in the REPowerEU 
chapters267.  

4.5.2. Relevance of RRF loans 

While  the  RRF  loans  were  relevant  for  many  Member  States,  they  were  not  for 
others. Assessment  of  the rationale behind  Member States’ decisions to  apply – or not 
apply  –  for  loans  under  the  RRF  shows  that  a  mix  of  financial  and  non-financial 
considerations  has  driven  Member  States’  decisions268.  As  of  1  September  2023,  13 
Member  States  had  requested  loan  support  or  additional  one  as  per  the  revised  RRF 
Regulation's Article 14(6). The amount of loan support requested was EUR 292.6 billion 
(in current prices), corresponding to 76% of the total loan support available.  

The potential reasons to apply for RRF loans were related to whether the Member 
State faced higher interest rate on the markets or a reduction in non-repayable RRF 
support269. Some Member States with financing conditions on the markets at an interest 
rate  higher  than  the  EU  interest  rate  sought  additional  support  with  RRF  loans.  Some 
Member States that faced a downwards revision of their maximum contribution of non-

264   For details on the allocation key, see Annex I, II and III of the RRF Regulation. 
265   Pfeiffer, P., Varga, J.,  in’t Veld, J. (2023) Quantifying spillovers of coordinated investment stimulus in the EU, 
https://www.cambridge.org/core/journals/macroeconomic-

at: 

Cambridge  University  Press, 
available 
dynamics/article/quantifying-spillovers-of-coordinated-investment-stimulus-in-the-
eu/FFCCAAA20BD98AC50A93A4F24562EAD4.  

266   See pages 190 to 191 of the supporting study. 
267   According to stakeholders interviewed as part of the supporting study, see page 190 to 191 of the supporting study. 
268   See pages 194 to 196 of the supporting study. 
269   Evidence in this paragraph is sourced from the supporting study, see pages 194 to 196. 

74 

 
 
repayable support in 2022 also applied for loans to make up for the shortfall and ensure 
the continuity of their projects. Factors such as the health of public finances, the need for 
additional  funding,  inflation  concerns,  administrative  burden,  and  the  scale  of  planned 
projects have all played a role in determining whether Member States opted for RRF loans 
or not. 

On  the  contrary,  the  potential  financial  reasons  not  to  apply  for  RRF  loans  were 
usually related to larger available funding or more favourable financing conditions 
by  the  market  (when  RRF  loans  were  at  higher  interest  rates  compared  to  market 
alternatives)270. Some Member States also factored in inflation, i.e. concerns of injecting 
additional money into an economy already facing inflationary pressures. Member States 
that considered that the  maximum  contribution of non-repayable support  was sufficient 
also did not apply for loans.  

From a strict cost-of-funding viewpoint, RRF loans are expected to bring a sizeable 
return on investment (‘ROI’) for some Member States271. According to  Commission 
calculations  based  on  available  data  on  NGEU  versus  sovereign  cost  of  funding  in  the 
period  up  until  November  2023,  all  Member  States  who  requested  loan  support  were 
expected to benefit from a positive ROI272 from RRF loan disbursements. It was estimated 
at between 2% and 17% for nine euro-area Member States, and between 13% and 38% for 
four non-euro area countries. This ROI is however subject to market developments. For 
non-euro area Member States, high ROIs are accompanied by exchange rate risk, which 
depends on the volatility of the exchange rate with respect to the EUR.  

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1. Conclusions 

This mid-term evaluation provides a first and early assessment of the RRF midway 
through its lifetime, as required by its Regulation. The assessment is done against the 
five evaluation  criteria of effectiveness,  efficiency, coherence, relevance,  and EU value 
added. The evidence underpinning this evaluation is to a large extent based on an extensive 
external study, which is published at the same time as this SWD. 

While this evaluation presents significant information on implementation, it is still 
too early to assess the impact of the RRF since the impact of reforms takes time to 
materialise and only a few investments have been fully completed so far, in line with 
the RRF’s design. This report therefore presents the progress achieved to date in reaching 
the RRF’s specific objective, i.e. to provide Member States with financial support in order 
to  achieve  specific  milestones  and  targets  that  represent  steps  in  the  implementation  of 
reforms and investments. It also illustrates how the achievement of milestones and targets 

270   Evidence in this paragraph is sourced from the supporting study, see pages 194 to 196. 
271   Evidence in this paragraph is sourced from Monteiro, D. P. (2024), “Large-scale EU issuance: 3 years on”, Quarterly 

Report on the Euro Area, Vol. 22, No. 4 (forthcoming). 

272   Based on a discounted ROI approach, whereby the present value of the financial costs associated with a RRF loan 
(i.e., the stream of interest payments and future principal repayments) is compared with the present value of the 
financial benefit (i.e., the loan amount itself that is being granted). 

75 

 
 
has, in some cases, already translated into the implementation of reforms and investments 
by Member States. This in turn contributes to achieving the RRF’s general objective, i.e. 
to promote the Union’s economic, social and territorial cohesion. A fully-fledged impact 
evaluation will be possible only ex-post once the measures are fully implemented.  

The RRF, set up to help Member States recover and become more resilient after the 
COVID-19  crisis,  contributed  to  supporting  the  EU  economy  in  critical  times.  In 
contrast with previous macroeconomic shocks, public investment remained robust during 
the COVID-19 pandemic and the energy crisis.  The RRF has  contributed to  preserving 
public investment in the EU and is expected to boost it going forward: the 2023 Autumn 
Forecast finds that approximately half of the increase in public investment between 2019 
and 2025 is related to investment financed by the EU budget, particularly by the RRF. The 
announcement of the RRF has contributed to reducing sovereign bond spreads in the EU 
at  the  time  of  the  COVID  shock,  which  in  turn  helped  mitigating  risks  of  financial 
fragmentation (for details, see Section 4.4.3) and supporting the recovery. By design, with 
its  allocation  key  and  the  spillovers  effects  it  triggers,  the  RRF  is  also  expected  to 
strengthen economic convergence in the EU. The provision by the EU of debt-financed 
non-repayable support constituted a new element in the Union’s toolbox and has been an 
important element in supporting the recovery from the COVID-19 crisis, in particular in 
Member States with less fiscal space.  

At  the  half-way  point,  the  implementation  of  the  Facility  is  well  under  way.  The 
Commission already disbursed over EUR 225 billion and the implementation of RRPs is 
progressing  across all the six  pillars  that  define  the scope of the Facility (related to  the 
green  and  digital  transitions;  sustainable  and  inclusive  growth;  social  and  territorial 
cohesion;  resilience;  policies  for  the  next  generation).  By  1  February  2024,  1,153 
milestones  and  targets  out  of  6,266  had  been  assessed  as  satisfactorily  fulfilled  and  an 
additional 1,238 milestones and targets had been reported by Member States as completed, 
representing a progress rate of approximately 38% of the total number of milestones and 
targets under the RRF (with 18% of all milestones and targets assessed as satisfactorily 
fulfilled).  At  the  time  of  writing,  18  further  payment  requests  containing  over  600 
milestones and targets were under assessment by the Commission. Once these have been 
assessed, the stated number should increase significantly.  

Progress in RRF implementation varies across Member States. While some Member 
States have not yet submitted any payment request, others have already submitted three or 
more. Indeed, in line with the performance-based nature of the RRF payments can only be 
made when the pre-defined progress towards the achievement of reforms and investments 
has been made. First disbursements under the RRF were made early on, notably thanks to 
the pre-financing provided for those RRPs that were adopted before the end of 2021, and 
steadily continued in 2021 and 2022. However, the first half of 2023 has seen a slowdown 
in  disbursements,  with  Member  States  temporarily  delaying  their  payment  requests  to 
focus on the revision of plans and the addition of REPowerEU chapters.  

The monitoring of the Facility relies on a wide-ranging set of milestones and targets 
(more than 6,000). They represent concrete progress made towards the achievement of 

76 

 
the reforms and investments committed to by Member States in their RRPs. The common 
indicators, while providing useful insights on the progress of the Facility as a whole, have 
a number of methodological limitations since they have neither baseline nor target values 
to  measure  results  –  and  can  therefore  only  be  used  to  complement  the  information 
gathered on the fulfilment of milestones and targets. 

While it is not yet feasible to assess the impacts of the RRF, some positive findings 
already emerge at the halfway point on the main features of the Facility. First, pre-
financing  has  allowed  to  quickly  provide  financial  support  to  Member  States  after  the 
COVID crisis. Second, the RRF’s  ability to  support the implementation  of reforms  has 
been  considered  as  one  of  the  most  effective  features  of  the  instrument.  The  RRF  has 
proven  to  be  a  key  tool  to  boost  Member  States’  delivery  on  the  European  Semester’s 
country-specific recommendations. Third, the performance-based approach of the RRF is 
considered  instrumental  in  enhancing  its  effectiveness:  the  disbursement  upon  the 
completion of concrete outputs (i.e. milestones and targets) evidenced by Member States 
is key to ensure ‘performance’; disbursements upon the delivery of milestones and targets 
are fast and the approach provides meaningful incentives to Member States to deliver upon 
relevant reforms. Combining reforms and investments in one funding instrument creates 
synergies between them, and the integration of a comprehensive reform and investment 
agenda into a single RRP supports the internal coherence of national medium-term plans. 

Despite  these  positive  findings,  the  RRF  has  not  so  far  led  to  the  administrative 
simplification that some Member States had hoped for. Concerning the implementation 
of the instrument, the administrative work required at national and sub-national level to 
implement  the  RRF  is  higher  than  initially  expected  by  Member  States.  As  a  new 
instrument, the RRF created ‘entry costs’, and the administrative costs linked to the RFF 
implementation have increased over time. The procedure for amending RRPs is also seen 
as  burdensome  and  overly  complex  by  some  stakeholders,  notably  Member  States 
authorities.  Concerning  the  design  of  the  instrument,  the  requirements  to  protect  the 
financial interests of the Union led to a similar administrative burden as other EU funds 
based  on  costs  and  the  complex  audit  and  control  framework  enshrined  in  the  RRF 
Regulation has negatively affected the speed of implementation of the RRF. This may be 
exacerbated by the coexistence of the two EU funding instruments (RRF and structural 
(performance-based  and  costs-based). 
funds)  with 
Representatives of Member States’ coordinating bodies stress that the specific design of 
the RRF also led to demanding reporting requirements and a perceived lack of flexibility, 
thereby hampering effectiveness and efficiency. 

two  different  approaches 

With its large financial envelope, the RRF provided substantial funding to advance 
the implementation of common EU policies. The scope of the RRF, as reflected in the 
six pillars anchored in the RRF Regulation, broadly covers the main policy areas of EU 
relevance, with a specific focus on the EU’s twin transition via the mandatory climate and 
digital expenditure targets. Stakeholders, including non-governmental organisations, also 
recognise the DNSH principle as a feature that has strengthened the ‘green’ dimension of 
RRF reforms and investments and supports the achievement of the RRF’s green objectives. 

77 

 
The RRF’s focus on EU common priorities, including  the green  and digital transitions, 
supports  both  a  coherent  approach  to  these  policies  across  Member  States.  The 
implementation  of  the  RRF  is  well  integrated  with  the  European  Semester  process, 
providing it with more leverage. However, some substitution effects between the RRF and 
Cohesion Policy appear to have materialised. There is high potential for synergies between 
the two instruments - and synergies can be expected to increase in the future. 

While  the  RRF’s  additionality  is  difficult  to  quantify  in  the  absence  of  a 
counterfactual, the qualitative evidence available so far provides first hints as to the 
EU added value of the instrument at the half-way point. First, the additionality of the 
RRF relates to the scale of financial support, which is unprecedented in the Union’s history. 
The announcement of the RRF has contributed to reducing sovereign bond spreads in the 
EU at  the time of the COVID shock, which in  turn helped mitigating risks of financial 
fragmentation  and  supporting  the  recovery.  The  additionality  of  the  RRF  in  individual 
Member States is correlated to the size of the financial support provided,  which can be 
proxied  by  the  RRP  allocation  as  a  share  of  GDP:  for  Member  States  where  the  RRF 
represents  an  important  share  of  GDP,  the  Facility  provided  additional  fiscal  space  to 
implement  investments  that  would  otherwise  have  been  unlikely.  By  design,  and  in 
particular  through  its  allocation  key,  the  RRF  is  expected  to  strengthen  economic 
convergence in the EU. The evidence gathered for this mid-term evaluation shows that the 
additionality  of  the  RRF  regarding  reforms  also  lays  in  its  support  for  speeding  up  the 
implementation  of  long-standing  and  politically  challenging  reforms,  which  would  not 
have  been  implemented  otherwise.  The  RRF  brought  a  new  dimension  to  EU  funding 
instruments by making the financing of investments conditional upon implementation of 
reforms. Last but not least, the RRF contributed to the implementation of multi-country 
projects, notably supporting the green and digital transition, widening the pool of Member 
States implementing multi-country and cross-border projects.  

5.2. Lessons learned 

5.2.1. Design of the RRF 

With its large size and quick initial roll-out, the RRF has allowed for an appropriate 
EU policy response to the unprecedented economic and social crisis linked to COVID-
19  and  subsequent  challenges.  Through  its  pre-financing  feature,  the  RRF  swiftly 
provided fiscal space in the aftermath of the COVID-19 crisis. This was complemented by 
the reduction in sovereign bond spreads in the EU that followed the announcement of the 
agreement on a sizeable  EU recovery initiative. Since then, the RRF has  contributed to 
sustaining public investment  in  the EU. In contrast  to previous macroeconomic shocks, 
public investment in the EU has increased in the aftermath of the COVID shock. Together 
with  its  distinct  allocation  key,  which  favours  lower-income  Member  States  but  also 
considers  the  impact  of  the  COVID-19  crisis,  the  non-repayable  nature  of  the  financial 
support provided (and the possibility to request additional loan financing) enabled the RRF 
to support the recovery and economic convergence of the EU economies. The coordinated 
EU  approach  is  also  predicted  to  provide  substantial  benefits  in  terms  of  cross-country 
spillovers.  

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A key innovative feature of the RRF is its ability to support the implementation of 
structural  reforms.  Making  the  approval  of  RRPs  and  subsequent  disbursements 
conditional  upon  the  inclusion  and  gradual  implementation  of  key  reforms  has  created 
significant incentives to carry out structural reforms. Thanks to the RRF, implementation 
of  CSRs  has  significantly  advanced,  and  much  more  than  in  years  preceding  the  RRF. 
Moreover, combining complementary reforms and investments in a single plan – and under 
one instrument  –  is  beneficial and  can increase their impact since,  for example, certain 
enabling reforms can make subsequent investments more effective. However, the analysis 
also shows that incentives to implement difficult reforms are smaller for Member States 
where the RRF allocation is more limited compared to the size of the economy.  

The performance-based nature of the instrument brought a more holistic approach 
to public spending. Providing direct financial support for the fulfilment of milestones and 
targets yields commitments and incentives to deliver on the actual implementation of the 
agreed measures. For several Member States, it represents a shift towards a more effective 
approach to public spending, enhancing predictability and accountability. The functioning 
of the approach requires an adequate specification of milestones and targets that avoids 
ambiguities  about  their  fulfilment.  This  way,  it  also  allows  for  disbursements  of  funds 
related  to  the  achievement  of  early  and  intermediate  steps  of  reforms  and  investments. 
However, Member States conveyed that the performance-based nature of the instrument 
did not bring the administrative simplification that was hoped for. This is mainly due to 
the demanding audit and control requirements, the extent of information required to justify 
the fulfilment of milestones and targets (seen as excessively demanding by several Member 
States), and additional reporting requirements (such as the bi-annual reporting on progress 
with milestones and targets as well as on common indicators).  

By design, the RRF ensures a strong alignment of Member States policies with EU 
priorities. The binding climate and digital targets for the RRPs ensure that a large part of 
funds  is  dedicated  to  fostering  the  green  and  digital  transitions,  among  the  other  key 
priorities outlined in the RRF Regulation. By providing financial incentives to implement 
the  CSRs  under  the  European  Semester,  the  RRF  addresses  reform  and  investment 
priorities  that  have  been  agreed  as  key  EU  policy  orientations.  It  thereby  improves  the 
effectiveness and coherence of EU policies and EU spending. 

The RRF’s design ensures national ownership and accountability, but there is room 
for improvement regarding stakeholder involvement in its implementation, notably 
regarding regional and local authorities as well as  social partners and civil society 
organisations.  While  the  RRF  Regulation  broadly  defines  the  policy  priorities  to  be 
addressed, in line with the CSRs, the final decision on what measures to include in their 
RRPs  and  how  to  design  reforms  and  investments  lies  with  the  Member  States.  This 
decision is taken following public consultations and close dialogues with the Commission, 
and the RRP is eventually subject to a Council decision. In Member States with a more 
decentralised structure for managing Cohesion Policy, some regional and local authorities, 
as  well  as  other  stakeholders  including  social  partners  point  to  their  insufficient 
involvement  in  planning  and  implementing  the  RRF.  The  organisation  of  stakeholder 

79 

 
involvement and the set-up of public consultations and RRF monitoring bodies plays a key 
role in this regard. 

The governance structure of the RRF combines a strong role for both the Commission 
and  the  Council  in  a  multilateral  setting  and  provides  for  close  scrutiny  by  the 
European  Parliament  during  the  implementation.  The  11  assessment  criteria  in  the 
RRF Regulation  provide  leverage to steer the plans towards the implementation  of  key 
policy  priorities.  The  involvement  of  various  Council  bodies,  while  only  very 
exceptionally leading to changes in the RRPs or the assessment of payment requests so far, 
is an important part of the process. It enhances transparency and accountability, thereby 
helping  to  increase  trust  among  Member  States’  authorities  in  the  RRF.  The  European 
Parliament  is  closely  scrutinising  the  implementation  of  the  Facility  through  regular 
exchanges with the Commission, both at technical and political level. 

While  the  Facility  has  been  able  to  react  to  new  challenges,  some  stakeholders, 
notably  Member  States  authorities,  point  to  the  need  for  further  flexibility  in  the 
instrument’s design as a key lesson learned. The RRF has been agile in reacting to new 
challenges, as shown by the integration of REPowerEU and its flexibility in reacting to 
high inflation and supply chain constraints. Nevertheless, Member States have pointed to 
a  perceived  rigidity  in  the  way  the  RRF  Regulation  requests  them  to  implement  RRPs 
(strict interpretation of detailed milestones and targets, strict list of milestones and targets 
that  must  be  satisfactorily  fulfilled  to  receive  a  specific  instalment,  disbursement 
procedures) and regarding the process to revise them. While this perceived rigidity stems 
from  legal  obligations  anchored  in  the  RRF  Regulation,  and  its  intervention  logic  to 
provide support for coherent packages of investments and reforms, it has reportedly led to 
a higher-than-expected administrative burden and implementation delays.  

By  design,  the  performance-based  logic  of  the  RRF  leads  to  less  readily  available 
information about the final recipients of the funds, but improvements have already 
been  made.  While  information  on  final  recipients  of  RRF  funding  is  collected  by  the 
Member  States,  it  can  only  be  used  and  shared  for  specific  audit  and  control  purposes. 
Hence,  the  data  on  final  recipients  is  usually  not  provided  as  part  of  Member  States 
payment request documentation and is therefore less readily available under the RRF than 
under most cost-based instruments. However, with the amendment of the RRF Regulation 
in the context of REPowerEU, the obligation for Member States to publish data on the 100 
final  recipients  receiving  the  highest  amount  of  RRF  funding  was  agreed  by  the  co-
legislators, which goes some way to remedy this issue. At this point in time, there is also 
limited  reporting  on  results,  i.e.  completed  reforms  and  investments,  as  first  fulfilled 
milestones  and  targets  are  often  intermediate  steps  towards  completing  reforms  and 
investments.  

The common indicators’ data serves as a complement to the information gathered on 
the  fulfilment  of  milestones  and  targets.  The  monitoring  of  the  Facility  is  mainly 
achieved through the milestones and targets, which are specific to each plan and measure 
the concrete output – and upon completion of reforms and investments, also the results– 
achieved  in  each  RRP.  Additionally,  the  RRF  Regulation  introduces  the  concept  of 

80 

 
common  indicators.  While  their  purpose  is  to  report  on  the  overall  performance  and 
progress  of  the  Facility  towards  its  objectives,  they  do  not  comprehensively  cover  all 
investments  included in  the RRPs and do not  fully  capture the  contribution  of reforms, 
which  is  difficult  to  measure  using  numerical  indicators.  Furthermore,  the  common 
indicators do not  include final  target  values, which limits  their use in  the context of an 
evaluation  and  in  determining  the  RRF’s  effectiveness.  Because  of  these  caveats,  the 
common indicators’ data has only been used to a limited extent in this evaluation, mostly 
as complement to the information gathered on the fulfilment of milestones and targets. 

5.2.2. Implementation of the RRF 

National  governance  structures  matter  for  the  efficient  implementation  of  the 
Facility.  A  centralised  RRF  coordination  body,  typically  close  to  the  Prime  Minister’s 
office, tends to  be  correlated  with  more efficiency in  the design  and implementation of 
RRPs. In the case of a decentralised governance structure (for example by the responsible 
line  ministries),  coordination  bodies  are  facing  more  difficulties  in  ensuring  the 
implementation of RRPs vis-à-vis line Ministries.  

Given  the  innovative  and  novel  nature  of  the  RRF,  the  Commission  prepared 
extensive guidance documents had, which sometimes took more time than envisaged. 
Since  the  creation  of  the  RRF,  the  Commission  has  provided  Member  States  with 
comprehensive  RRF-related  guidance,  for  example  on  the  preparation  of  plans,  the 
application  of  the  DNSH  principle,  the  frameworks  for  satisfactory  fulfilment,  the 
suspension  of  payments  and  reversals  of  milestones  and  targets,  or  the  preparation  of 
REPowerEU chapters. The RRF Experts Group, composed of RRF experts of all Member 
States, meets  regularly  and provides  a forum  of dialogue  to  exchange and explain such 
guidance  and  exchange  best  practices.  Implementing  the  RRF  has  involved  a  lot  of 
“learning-by-doing”  for  both  Member  States  and  the  Commission.  Providing  robust 
guidance to Member States has therefore at times taken more time than expected. For some 
Member States authorities this proved to be a challenge where they would have liked to 
move faster or had to amend draft plans in light of newly issued guidance.  

While disbursements were timely in the first two years (2021-2022), the amendments 
of the plans in light of external factors slowed down payments in 2023. Following the 
amendment  of  the  RRF  Regulation  in  the  context  of  REPowerEU  in  early  2023,  most 
Member States added REPowerEU chapters to their RRPs. In addition, 30% of the total 
amount of grant support available, the allocation of which had been updated by end-June 
2023,  needed  to  be  committed  by  the  end  of  the  year.  Member  States  used  the  plan 
revisions necessary in this context as an opportunity to make additional changes. Where 
they  realised  that  the  achievement  of  specific  milestones  and  targets  had  become 
impossible  because  of  objective  circumstances  (such  as  high  inflation  or  supply 
constraints),  they  either  made  changes  to  the  measures  concerned  and/or  delayed  the 
submission  of  payment  requests.  Taken  together,  these  different  elements  resulted  in 
delays with respect to the indicative disbursement schedules in the CIDs. While obstacles 
in implementation and revisions in their design are unavoidable in the context of detailed 
multi-annual  policy  plans,  disbursement  delays  do  not  necessarily  slow  down 

81 

 
implementation on the ground, as discussed in Section 4.1. The Commission expects the 
2023 delays to be temporary, as interviews with Member States as well as their regular 
reporting on progress point to a catch-up in payments in 2024. 

The large amount of RRF funds available in addition to cohesion funds have strained 
the administrative and absorption capacity of  some Member States, also  given  the 
tight  timelines  and  the  required  ambition  of  the  supported  measures.  In  Member 
States that also receive significant amounts of cohesion funding, the simultaneous planning 
and programming of funds stemming from two different instruments can be challenging, 
especially for smaller administrations. Moreover, potential risks of double funding have to 
be  monitored  carefully.  Additional  complexities  for  administrations  can  arise  from  the 
inclusion of many small measures or cross-border projects in the plans. 

Several stakeholders, in particular the national coordination bodies, have called for 
a better balance between transparency/control and the resulting administrative costs. 
From  the  point  of  view  of  the  Member  States,  the  RRF  has  not  brought  the  expected 
simplification  of  administrative  procedures  compared  to  other  EU  funding  instruments, 
notably because of the comprehensive audit and control requirements (a perceived overlap 
between national, Commission and ECA audits has created uncertainty in Member States 
and an overload of administrative procedures). While the RRF Regulation lays down the 
audit  and  control  responsibilities  of  the  Member  States  and  obliges  the  Commission  to 
assess and scrutinise them, the Member States’ understanding of the resulting requirements 
was sometimes different than the ones imposed by the European Court of Auditors and the 
European Parliament as discharge authority. Moreover, various reporting obligations for 
Member States stemming from the Regulation (bi-annual reporting, common indicators, 
final  recipients  etc.)  involves  a  significant  amount  of  work  for  both  national 
administrations  and  Commission  services.  These  reporting  requirements  add  onto  the 
continuous monitoring of progress on milestones and targets ahead of upcoming payment 
requests to meet the goals of the Facility. At the same time, they provide transparency and 
enable communication on the progress with milestones and targets. 

5.2.3. Looking ahead – what to make of the lessons learned 

The Commission has taken steps to address shortcomings identified in this mid-term 
evaluation.  Progress  has  been  achieved  in  terms  of  increasing  awareness  of  existing 
flexibility with additional Commission guidance on the implementation of RRPs (e.g. the 
framework for assessing milestones and targets273) or increasing transparency through the 
adoption of the payment suspension methodology, which provided clarity on the financial 
consequences of partially fulfilling milestones or targets, while preserving the incentives 
for implementing the plans in line with the objectives of the RRF Regulation. Moreover, 
Member  States’  administrative  capacities  have  been  strengthened  through  enhanced 
support from the TSI and dedicated sessions in the RRF Expert Group. 

273  See Annex I of European Commission (2023) Recovery and Resilience Facility: Two years on A unique instrument 
final,  available  at 

transformation  COM(2023)  99 

at 
https://commission.europa.eu/system/files/2023-02/COM_2023_99_1_EN.pdf. 

the  EU’s  green  and  digital 

the  heart  of 

82 

 
 
Further action within the scope of the RRF Regulation will be considered to facilitate 
implementation.  Where  feasible,  the  Commission  will  consider  ways  of  supporting 
Member States’ in strengthening their administrative capacity for the implementation of 
RRPs.  Given  that  many  Member  States  consider  the  process  to  change  RRPs  as  too 
burdensome,  slow  and  unnecessarily  complex,  the  Commission  will  keep  exploring 
possible ways to mitigate their administrative burden. The streamlining of the process for 
processing  payment  requests  in  the  Committees  (EPC  and  EFC)  is  considered  a  first 
improvement.  

Further reflection is needed on common indicators and their design to better monitor 
and  evaluate  impact.  The  limitations  of  the  common  indicators  have  been  subject  to 
several discussions with the European Parliament and the European Court of Auditors274, 
and the Commission has committed to look into possibilities to improve the quality of the 
common indicators data275. Moreover, there is a need to further reflect on the design and 
use of common indicators, particularly for future performance-based instruments. It would 
be useful to have a higher number of common indicators with clear baselines and target 
values to  enable the proper measurement of results. At the same time, the reporting  on 
common  indicators  has  contributed  to  the  administrative  burden  for  Member  States 
authorities, which also needs to be taken account when designing monitoring frameworks 
for potential future instruments. 

A  proposal  for  legal  amendments  to  improve  the  functioning  of  the  RRF  is  not 
warranted  at  the  current  juncture.  Article 32  of  the  RRF  Regulation  refers  to  the 
possibility of accompanying this mid-term evaluation with a legislative proposal to modify 
the RRF Regulation. However, this is considered unnecessary for several reasons. First, 
the Commission has taken steps to facilitate implementation and will continue to explore 
further steps where appropriate and necessary. Second, the Regulation has already been 
amended in the context of REPowerEU. Raising expectations regarding possible changes 
to the functioning of the RRF could further delay implementation on the ground. Third, 
with only two and a half years to go until the deadline for Member States to achieve the 
final  milestones  and  targets  of  their  RRPs  by  end-August  2026,  the  focus  should  be 
squarely  on  implementation  going  forward.  The  Commission  will  continue  to  provide 
active support to Member States in this context. 

The  successful  features  of  the  RRF  and  the  main  lessons  learned  from  its 
implementation can inform the design of future EU funding instruments. In view of 
the temporary nature of  the RRF, which will expire at  the end of 2026, it seems  worth 
reflecting  on  what  features  of  the  Facility  might  inspire  the  design  of  EU  funding 
instruments in the context of the next Multi-annual Financial Framework, starting in 2028. 
Such  features  include  notably  the  effectiveness  of  the  performance-based  approach  in 
delivering on reforms, the combination of reforms and investments in one instrument, and 

274   See  ECA  Special  report  26/2023:  The  Recovery  and  Resilience  Facility’s  performance  monitoring  framework, 

available at: https://www.eca.europa.eu/en/publications?ref=SR-2023-26.  

275   See  Replies  of  the  European  Commission  to  the  ECA’s  special  report  on  the  RRF’s  performance  monitoring 
framework,  available  at:  https://www.eca.europa.eu/Lists/ECAReplies/COM-Replies-SR-2023-26/COM-Replies-
SR-2023-26_EN.pdf#page=8&zoom=100,92,866.  

83 

 
 
a clear focus on EU policy priorities, including by way of mandatory expenditure targets 
to promote the climate and digital transitions, combined with a country-specific approach 
based on the European Semester process. The frontloading of funding, as done with RRF 
pre-financing,  seems  particularly  suitable  in  situations  where  a  swift  crisis  response  is 
required.  For  any  future  performance-based  instrument,  some  considerations  in  the 
formulation of milestones and targets could be made. It is important to ensure an adequate 
balance between the necessary level of detail to ensure adequate monitoring and avoidance 
of  ambiguity,  while  allowing  for  possibly  necessary  adjustments  during 
the 
implementation, taking into account evolving circumstances Moreover, future instruments 
should  be  based  on  objectives  fulfilling  the  S.M.A.R.T  criteria276,  consider  a  stronger 
involvement of regional and local  authorities as  well as non-governmental  stakeholders 
and pay specific attention to reinforcing administrative capacity as well as transparency 
and communication requirements. 

5.2.4. Looking ahead – the RRF ex-post evaluation 

The ex-post evaluation of the RRF, to be completed in 2028, will aim to assess the 
results and impact of the Facility. As discussed, this mid-term evaluation comes too early 
to  properly  and  conclusively  assess  the  RRF’s  impact.  Given  that  there  is  no  overall 
method  available  to  compare  the  implementation  of  the  whole  Facility  with  the 
counterfactual situation without the RRF, the Commission aims, for the ex-post evaluation 
in  2028, at  using advanced micro and macro-econometric methods and modelling tools 
aiming at identifying and assessing, to the extent possible, the causal impact of selected 
reforms  and  investments  and  their  additionality.  Contrary  to  the  theoretical  model 
simulations  and  first  examples  put  forward  for  the  mid-term  evaluation,  it  should  be 
possible by 2028, for the ex-post evaluation, to empirically analyse the impacts of some 
measures supported by the RRF (as they are expected to be completed by the end of 2026). 
Those impacts may have matured depending on the timeline and nature of the investments 
and reforms delivered by the Member States under the Facility. 

The Commission services will prepare a research plan which aims at providing input 
to the ex-post evaluation. The availability of comprehensive data will be key for the ex-
post evaluation. Given that the RRF is mainly funding nationally implemented measures, 
data will also have to be collected at national level to the extent that these become available. 
As the ex-post evaluation will have to make use of adequate micro- and macro-economic 
data, it must be ensured that these will become available when RRF-funded measures are 
finalised.  As  priority  themes,  the  ex-post  evaluation  will  focus  on  the  main  objectives 
included in the RRF Regulation, notably on the green and digital transitions, the impact on 
social and economic resilience as well as convergence within the EU. 

276   Objectives should be specific, measurable, assignable, realistic, and time-related (‘S.M.A.R.T’). 

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ANNEX I: PROCEDURAL INFORMATION 

The mid-term evaluation of the Recovery and Resilience Facility (‘RRF’), in the middle of the programme’s operating time, has been completed in line 
with Article 32 of the Regulation establishing the RRF277. The Decide planning entry for the mid-term evaluation is PLAN/2022/2114.  

In  line  with  the  requirements  set  out  in  the  Commission  Better  Regulation  Guidelines,  the  mid-term  evaluation  considered  the  criteria  of  relevance, 
effectiveness, efficiency, EU value added and coherence. The exercise relies primarily on an external independent supporting study commissioned by the 
Commission in January 2023 and concluded in November 2023. In order to ensure validity, the analysis and conclusions of the supporting study are based 
on the evidence obtained using several evaluation methods (literature review, semi-structured interviews with targeted stakeholders, targeted consultations, 
open public consultation, case studies with roundtables and a validation workshop). The cut-off date of the supporting study is end of July 2023, with the 
eight  case  studies  having  a  cut-off  date  of  end  of  September  2023.  A  few  limitations  were  experienced  during  the  preparation  and  completion  of  the 
supporting study. Annex 2 provides a detailed overview of these shortcomings, together with the mitigation strategies adopted.  

The mid-term evaluation has been undertaken jointly by DG ECFIN and SG RECOVER. DG ECFIN and SG RECOVER also chaired the inter-service 
group (‘ISG’) that was set up to manage the external supporting study and has been involved in all key steps of the process. Apart from DG ECFIN and 
SG RECOVER, members of the ISG came from a broad range of Commission services (26) that are responsible for EU-policies relevant to the RRF278. The 
ISG provided information, expertise and quality assurance in line with evaluation standards and provided a useful steer to both the supporting study and 
this SWD. Specifically, the ISG was involved in:  

a) Establishing the evaluation roadmap and call for evidence;  

b) Establishing the Terms of Reference (‘ToR’) for the supporting study;  

277   Regulation  (EU)  2021/241  of  the  European  Parliament  and  of  the  Council  of  12  February  2021  establishing  the  Recovery  and  Resilience  Facility,  available  at:  https://eur-

lex.europa.eu/eli/reg/2021/241/oj/eng.  

278   The ISSG is composed of representatives of DG AGRI, BUDG, CLIMA, CNECT, COMM, COMP, DEFIS, DIGIT, EAC, EMPL, ENER, ENV, FISMA, GROW, HOME, JRC, JUST, LS, MOVE, 

OLAF, REFORM, REGIO, RTD, SANTE, TAXUD and TRADE. 

85 

 
 
 
c) Designing the stakeholder consultation strategy;  

d) Reviewing and quality assuring the deliverables of the supporting study; 

e) Preparing the Commission services’ Staff Working Document.  

The  call  for  tenders  was  launched  in  January  2023.  Following  the  verdict  of  an  evaluation  committee,  the  specific  contract  to  undertake  the  external 
evaluation was awarded to a consortium co-led by ECORYS and CEPS using Framework Contract number ECFIN-048-2023 – ref. Ares(2023)810564. 
The consortium included the National Institute of Economic and Social Research, Csil and Wavestone. 

The evaluation call for evidence ran between 8 November 2022 and 6 December 2022, to seek wider feedback. This was followed by an open public 
consultation (OPC) which ran for twelve weeks from 16 March 2023 to 8 June 2023. (OPC Decide planning entry PLAN/2022/2114).  

A kick-off meeting on the supporting study, where the ISG and the external contractor discussed the deliverables and the evaluation methods, took place 
on 23 March 2023. ISG meetings on the inception and interim reports of the external study were held on 18 April 2023 and 19 June 2023 and an ISG 
meeting on the draft final report and final report was respectively held on 15 September and 20 October 2023. Following a validation workshop with a 
range  of  experts,  the  definitive  final  report  was  approved  by  ECFIN/RECOVER  on  31  January  2024.  To  provide  appropriate  support  and  ensure  the 
contractor’s access to the necessary information as comprehensively as possible, regular dialogues were organised between the contractor and DG ECFIN 
and SG RECOVER from April 2023 onwards. These dialogues continued until the finalisation of the supporting study, which was published at the same 
time as this SWD. The content of the supporting study remains the sole responsibility of the authors and does not necessarily reflect the  views of the 
Commission. 

The supporting study acted as the primary source of evidence to inform the SWD, which was drafted in October and November 2023 by SG RECOVER 
and ECFIN staff. The draft SWD was presented and discussed at the ISG meeting on 27 November and advise, input and feedback from ISG members was 
incorporated. A revised version of the SWD was then circulated and supported by all ISG members by 5 December 2023 in a written procedure. 

As with all evaluations related to programmes with a major impact on the EU budget or which are of strategic importance for the Union, the mid-term 
evaluation carried out by DG ECFIN and SG REC VER is subject to scrutiny by the Regulatory Scrutiny Board (‘RSB’). An RSB upstream meeting was 
held on 2 October 2023, followed by a meeting with the RSB on 17 January 2024. The RSB provided some recommendations for improvement and gave 
a positive opinion on 8 February 2024. 

86 

 
Table A1.1 below summarises the main points of the RSB review and how they have been integrated into the evaluation. 

Board’s Recommendations 

The macroeconomic modelling and simulations cannot be used to provide 
an  evaluation  of  the  actual  impact.  They  can  serve  rather  as  an  ex-ante 
model prediction. 

The limitations of the evidence base for assessing the impact of the Facility 
at  this  early  stage  should  be  systematically  acknowledged  and  reflected 
throughout the report. 

Integration of the recommendations into the mid-term evaluation 
report 
The results of the macroeconomic simulations have been deleted from the 
sections about effectiveness, efficiency and EU added value, as well as in 
the conclusions.  

Instead, the results of the macroeconomic simulations feature in the section 
on the intervention logic section and points of comparison, to illustrate what 
the expected macroeconomic impacts compared to a scenario with no RRF. 

The  report  underlines  (in  the  introduction,  in  the  sections  about 
effectiveness, efficiency and EU added value, as well as in the conclusions) 
that  it  is  too  early  at  this  juncture  to  conduct  a  full  impact  evaluation/to 
assess the impact of the RRF general objective.  

The  effectiveness  section  also  better  explains  the  links  between  the 
achievement  of  M&Ts  and  the  RRF  general  objective.  It  clearly 
distinguishes  between  the  achievements  on  the  RRF  specific  objectives 
(disbursements and M&T achievement) and what can be said, at this early 
juncture, on the progress towards the RRF general objective (divided under 
its various elements) - with examples about available results on completed 
reforms taken from the case studies. 

The report should be clearer about the additionality of the RRF. 

The  EU  added  value  section  has  been  developed  further,  notably  with 
further  elements  on  the  RRF  additionality,  discussing  the  scale  of  RRF 
the 
financing,  convergence  and 

spillover  aspects, 

support 

for 

87 

 
The  report  should  systematically  present  and  analyse  evidence  from  the 
various  consultations  and  should  be  specific  throughout  on  which 
stakeholder group said what.  

The conclusions should better reflect the key findings of the analysis. 

The lessons learned should be further developed, in particular on the need 
to improve the monitoring framework to better demonstrate the impact of 
the Facility. 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

implementation of common EU policies, on top of the support for reforms 
and for multi-country projects. 

The evidence gathered from consultations activities, conducted both by the 
Commission  (open  public  consultations)  and  the  consultants  (interviews 
and targeted surveys) is included in section 4 of the report, by stakeholder 
group when relevant. 

The conclusions have been revised to fully reflect the key findings of the 
analysis. 

The lessons learned have been developed further, including with a point on 
the common indicators and on the upcoming ex-post evaluation. 

This  annex  presents  the  methodological  approach  to  the  mid-term  evaluation.  It  describes  the  design  of  the  methodology,  the  tools  used  for  data  and 
information gathering and the results obtained. It also provides insights on the limitations encountered and the mitigation strategies adopted.  

Evaluation design  

The methodology of the evaluation study was designed to respond to (i) the evaluation questions detailed in the Terms of Reference for the mid-term 
evaluation study of the RRF, and (ii) the Better Regulation Guidelines evaluation criteria. It rests on three pillars:  

1.  Participatory  and  inclusive  data  collection  and  analysis  through  a  stakeholder  consultation  programme  (semi-structured  interviews,  surveys,  public 
consultation and case studies) and a validation workshop;  

2. A mixture of qualitative and quantitative input, with qualitative input obtained mainly through document analysis and stakeholder input and quantitative 
input, including macroeconomic modelling, supporting the qualitative information to the extent possible; and  

88 

 
3. Triangulation, i.e. the information and data collected from a range of different sources using a range of methods collectively provides answers to the 
evaluation questions prepared by DG ECFIN and SG RECOVER.  

Tools for information gathering and results obtained  

The information and data required for the study were collected using the following methodological tools: 

Literature Review 

To support the mid-term evaluation an extensive literature review has been carried out in the context of the supporting study279, presenting experts and 
academia’s views on the RRF. The literature review has been carried out to inform the different aspects of the mid-term evaluation, namely: 

•  The overall functioning and implementation of the RRF, including reporting in the European Semester and audit; 

•  Progress with the implementation of the RRF across the six RRF Pillars: green transition, digital transformation, smart sustainable and inclusive 

growth, social and territorial cohesion, health, economic, and social and institutional resilience, and policies for the next generation; 

•  Progress with cross-border projects and EU added value; 

•  The macro-economic impact of the RRF; 

•  The role of sub-national actors in implementing the RRF (drafting and implementation); 

•  The role of social partners and civil society in implementing the RRF (drafting and implementation). 

The literature review includes a systematic review of a broad set of sources which was subsequently used to prepare the country-specific analysis and the 
case studies, as well as the preparation of the surveys and the macro-economic analysis. The table A2.1 below summarises the key documents reviewed for 
the preparation of the different phases of the mid-term evaluation. The main findings of the relevant literature are provided in Annex III of the supporting 
study, while the bibliography is included in Annex IV. Concerning the case studies, the references to the literature reviewed are indicated at the end of each 
case study in the supporting study. 

279   See Annex III of the supporting study, starting from page 250. 

89 

 
 
Table A2.1: Literature review – key source 

Sources 

RRF Regulation and REPowerEU, Council Implementing Decisions plans and payments’ request and related annexes,  perational 
Arrangements  (where  available),  RRP  national  websites  and  related  publications,  National  Bank’s  RRF-related  publications, 
Research institute and think tanks country specific RRF-related publications, the Commission’s publications on the RRF (e.g. Review 
Reports, Fact sheets on bi-annual reporting from Member States) EP studies and papers produced by and for the EP Research Service, 
ECA’  audit  reports  and  discussion  papers,  Committee  of  the  Regions  and  European  Economic  and  Social  Committee  reports 
Eurofound reports. 

Analysis 

Country specific analysis 

Council  Implementing  Decisions  and  related  annexes,  Operational  Arrangements  (where  available),  RRP  national  websites  and 
related  publications,  National  Bank’s  RRF-related  publications,  Research  institute  and  think  tanks  country  specific  RRF-related 
publications, the Commission’s thematic reports, EP studies and papers produced by and for the Epary Research Service, ECA’ audit 
reports and discussion papers 

Case studies 

European  Central  Bank  publications,  including Economic bulletins,  Occasional  Papers,  and  Blogs,  Research  institutes  and  think 
tanks, DG ECFIN publications  

Macroeconomic analysis 

For coordination bodies: RRF Regulation and REPowerEU 

Surveys 

For national parliaments: built on information collected for country-specific analysis 

Sources changed based on the interviewee: 

-  Coordination bodies and Commission lead negotiators: see sources for country-specific analysis 

-  Other DGs in the EC: same sources as case studies (so far done only EAC and EMPL, respectively for ECEC and ALMP 

Semi-structured interviews (not related to case 
studies) 

case studies) 

-  EFC/EPC: Regulations 

-  EP: RRF/REPowerEU Regulations and Recovery and Resilience Dialogues between the EP and the EC 

- 

Social partners: RRF/REPowerEU Regulations and their own position papers on RRF 

Academic literature, OECD reports and other think tank publications 

Background information 

Source: Supporting study 

90 

 
 
Databases creation 

The contractor established a database with primary (available monitoring data) and secondary information on implementation (collected via desk research 
and interviews). The main characteristics of the databases are presented below. 

•  Primary database – it includes data provided by the Commission (payments, milestones and targets, investments and reforms, tagging) and the 
Recovery and Resilience Scoreboard280. The data from the Commission has been complemented by Scoreboard information where needed. The data 
was used extensively in the evaluation questions on Effectiveness. 

•  Secondary database – it includes information on the implementation of the RRF, which is based on the interviews and the desk research performed 

at Member State level. The database is provided in Annex V of the supporting study. 

The Primary database was partly updated by the Commission after the supporting study, in order to allow for the incorporation of up-to-date monitoring 
data in the SWD. 

Public Consultation 

The public consultation was conducted from 16 March 2023 to 8 June 2023. The consultation was available via a dedicated webpage in all official EU 
languages. It was open to feedback from anyone interested in the topic.  

A total of 172 responses were received. Data was screened in line with the Better Regulation Toolbox. No duplicates or campaigns were identified, which 
means that all responses were included in the analysis. The largest number of contributions stems from Portugal (57 responses), followed by Belgium (16) 
and Germany (15), Spain (13), Romania (12), Italy (11) and Czechia (10 responses). Four replies come from Austria and three from Hungary. Jointly, 
respondents from these Member States accounted for almost three out of four replies. All but one respondent indicated an EU Member State as their country 
of residence. Respondents from 24 Member States provided responses.  

The  consultation  outcome  and  the  summary  report  are  available  on  the  following  website:  https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/13608-Recovery-and-Resilience-Facility-2020-2024-mid-term-evaluation/public-consultation_en.  

280   See https://ec.europa.eu/economy_finance/recovery-and-resilience-scoreboard/index.html.  

91 

 
 
Surveys 

Two targeted surveys were launched at the end of May 2023 and closed on 7 July 2023. The first survey addresses key national stakeholders involved in 
the programmes’ implementation, in the projects’ selection, and in the monitoring and reporting procedures. The views expressed provide information on 
the  state  of  implementation,  administrative  costs  and  burden,  agility  of  processes  and  rules,  potential  overlaps  and/or  synergies  with  other  existing 
instruments,  in  particular  cohesion  programmes,  and  views  about  the  performance-based  system.  The  second  survey  targeted  members  of  National 
Parliaments involved in Committees in charge of reforms supported by the Recovery and Resilience Facility.  

The survey questionnaires were translated in all official languages of the EU. The survey questionnaires were uploaded on EUSurvey,  an open-source 
software solution funded by the Commission for creating surveys and questionnaires. 

Table A2.2 Survey Status 

Date of launch 
Total number of contacts 

Survey 1 – to key RRF 
national stakeholders 
18 May 
60 (plus snowball 
effect) 
 5 (plus ad hoc emails) 
40 
Of which fully answered questionnaire  18 
Of which partially answered questionnaire  22 

Number of reminders 
Total number of replies  

Survey 2 – to national 
parliaments 
25 May 2023 
1,820 

5 
5 
1 
4 

Source: Supporting study 

Due to the low number of responses received for the survey from member of the national parliaments, its results could not be considered as representative 
to be incorporated into the independent external evaluation report supporting this SWD. 

Details on the survey addressing key national stakeholders involved in the programmes’ implementation. 

The questionnaire was structured into eight sections, with the initial one designated as the “welcome” (section A). The following sections sought to collect 
information about the respondents’ profile (section B: “Respondent profile”), their country of origin, and the governance organisation set up to manage 
RRF  within  their  Member  State  (section  C:  “Country”).  Subsequent  sections  aimed  to  collect  participants’  perceptions  and  opinions  concerning  the 

92 

 
 
effectiveness of the RRF (section D: “Effectiveness of RRF”), its efficiency (section E: “Efficiency of RRF”), as well as its coherence and added value 
(respectively section F: “Coherence of RRF” and section G: “Value added of RRF”). The final section allowed respondents to share potential contacts to 
be contacted to further contribute to the evaluation and share any thoughts that were not addressed in the survey (section F: “Final remarks”). 

In total, the survey received responses from 40 participants, representing 24 different EU Member States281. Five responses came from Austria, accounting 
for 13% of the replies. Estonia, Italy, and Ireland each contributed three responses (8%). Two replies (5%) were provided by each of the following Member 
States: Cyprus, France, Latvia, Romania, Slovak Republic, and Slovenia. No contributions were provided by representatives from Malta, Luxembourg, and 
Sweden. All other Member States provided one response each. Figure A2.1 below offers comprehensive information regarding the country of origin of the 
respondents.  

Figure A2.1 – Country of respondents (n=40) 

5

3

3

3

6

5

4

3

2

1

0

2

2

2

2

2

2

1

1

1

1

1

1

1

1

1

1

1

1

1

1

Source: Supporting study 

In answering the survey, participants had to provide information concerning their role in the RRF. 85% (34) of them declared that they were involved in 
the monitoring of the RRF while almost 73% (29) participated in activities related to performance management. Over half of the respondents (55%; 22) 
reported involvement in payment requests and more than one third (37%; 15) in control and audit activities. Moreover, around 43% (17) stated that they 
were involved in implementing the RRF strategy. Figure A2.2 below shows the roles held in the RRF by the participants. “ ther” replies include different 

281   Question “Country”, section C.  

93 

 
 
 
activities  such  as  coordination  activities,  the  implementation  of  a  RRF  management  and  internal  control  system,  consulting  and  outreach  activities, 
evaluation activities as regards to RRP milestone and targets achievement, support to the design of a centralised monitoring system, methodological aspects 
and management of data quality issues, support to administrations responsible for the implementation of reforms and investments, and the promotion of 
ex-post evaluations on the impacts of the RRP. 

Figure A2.2: Role of the respondents in the RRF (n=40; multiple answers possible) 

Monitoring

Performance management

Payment requests

Implementation strategy

Control & audit

Implementation of investments

Implementation of reforms

34

29

22

17

15

13

12

Other

0

4

5

10

15

20

25

30

35

40

Source: Supporting study 

Respondents were also asked to select which (if any) other EU programmes they have been or are involved in282. Only 35% (14) of them provided such an 
information,  with  the  vast  majority  (86%;  12)  being  or  having  been  involved  in  the  European  Structural  and  Investments  Funds.  Around  8%  (3)  also 
declared being or having been involved in InvestEU programme (see Figure A2.3 below). “ thers” answers include European Economic Area Grants, the 
‘Aim, Learn, Master, Achieve’ EU initiative, the EU programme for Employment and Social Innovation, NextGenerationEU and REPowerEU.  

Figure A2.3: Involvement of respondents in other EU programmes (n=14; multiple answers possible) 

282   Question “Involvement in other EU programmes (select all that apply)”, section B.  

94 

 
 
 
European Structural and Investment Funds

12

Others

InvestEU

4

3

0

2

4

6

8

10

12

14

 Source: Supporting study 

On 18 September, Members of the Expert Group of the RRF were invited to provide responses to three evaluation questions: 

•  Question 1: The 31 August 2023 was the deadline to ask for the RRF loans. What was the rationale behind your decision to apply – or not apply – 

for loans under the RRF? 

•  Question 2: To what extent do you believe that the reforms and investments outlined in the RRP would have been pursued simultaneously if the 

RRF were not in place? And what efficiency gains (if any) is this simultaneous implementation generating? 

•  Question 3: Looking at the implementation of your RRF plan, can you identify any (positive or negative) effects that you did not expect when you 

design the plan? 

Six Member States answered this additional request and provided the answers, which have been included in the Final Report of the supporting study. 

Interviews 

In total 61 horizontal semi-structured interviews were conducted in the context of the supporting study. In addition to the horizontal interviews, additional 
95 semi-structured interviews were conducted in the framework of the case studies and specific analyses. In total, 156 semi-structured interviews were 
conducted. Table A2.3 below summarises the semi-structured interviews conducted: 

Table A2.3.: Interview Progress 
Institution 

National coordination bodies 
National competent ministries/ national court 

Country  specific  analysis 
analysis 
26 interviewed (Missing: Luxembourg) 
- 

/  horizontal 

Cases studies 

- 
5 for ALMP 

95 

 
 
National agencies 

Local/regional government 

Managing authorities  
Businesses 

European Commission (SG RECOVER and ECFIN) 

European Commission (Other DGs) 

- 

11  interviewed  (8  lead  negotiators  and  3 
directors) 
7 interviewed: DG EMPL, DG BUDG, DG 
CLIMA,  DG  ENV,  DG  GROW,  DG 
REFORM, DG RTD 

Economic  and  Financial  Committee  and  Economic 
Policy Committee 
EP 
European Social Partners 

European Economic and Social Committee  
Committee of the Regions 
EU level NGOs 

2 interviewed 

3 interviewed 
4  (ETUC,  SGI  Europe,  EPSU,  Business 
Europe) 
2 interviewed 
- 
5 interviewed 

EU agencies 
Experts 

 - 
- 

96 

5 for Cross-border 
3 for ECEC 
4 for Energy Efficiency  
3 for Rule of Law 
7 for Digitalisation 
3 for SME 
2 for gender 
1 for Cross-border 
1 for Energy Efficiency 
2 for Digitalisation 
7 for ECEC 
1 for Energy Efficiency 
7 for Cohesion Policy 
3 for Cross-border 
4 for SME 
1 for gender 

3 EMPL for ALMP) 
1 GROW for Cross-border 
1 EAC for ECEC 
1 ENER for Energy Efficiency 
7 REGIO for Cohesion Policy 
1 REFORM for Cohesion Policy 
1 JUST for gender 

- 

- 
- 

1 for Cohesion Policy 
1 for Cohesion Policy 
3 for Energy Efficiency 
2 for Rule of Law 
1 EIGE for gender 
5 for ALMP 

 
 
 
 
 
Source: Supporting study, updated on 14 September 2023. 

Selection of Case Studies 

6 for Rule of Law 
2 for gender 

The aim of the case studies283 prepared in the context of the supporting study is to take a deep dive into several themes relevant to the RRF’s objectives, 
identify  and  analyse  unintended  consequences  and  highlight  challenges  or  success  stories  in  implementing  RRF  measures.  This  mid-term  evaluation 
includes eight cross-country thematic case studies. The case studies are aligned with the six pillars defined in Article 3 of the RRF Regulation: (a) Energy 
efficiency  buildings  (green  transition);  (b)  Digitalisation  of  healthcare  (digital  transformation);  (c)  Support  to  SMEs  (smart,  sustainable  and  inclusive 
growth); (d) Active labour market policies (social and territorial cohesion); (e) Rule of law (health, and economic, social and institutional resilience); and 
(f) Early Childhood Education and Care (Policies for the next generation). In addition to the case studies on the six pillars, two additional case studies have 
been added, one on cross-border projects and one on the interaction between other EU Cohesion Policy and the RRF. Except for the case study on Cohesion, 
the approach followed was composed of three steps: 

•  First, a description of the measures included in the RRPs, starting from the status of milestones and targets and the level of governance involved 

(national or subnational). This step largely relied on desk research. 

•  Second, an assessment of the effectiveness, coherence, added value and relevance of the investments and reforms included in the plans. This required 
assessing – to the extent possible – the already tangible results. This step relied on desk research and semi-structured interviews. In total, 88 semi-
structured interviews as detailed above (including also interviews executed for gender equality). 

•  The third step built  on the combination of the previous two steps for the identification of missed opportunities and persisting gaps, and of the 
obstacles or delays currently encountered in the execution of the plans. The third step included the organisation of roundtables with key national 
stakeholders responsible for the implementation and policy experts. 

The topics of the case studies have been chosen to cover the scope of the RRF (defined by the six policy pillars), as well as two key thematic analyses (on 
the support for cross-border projects and on a comparison between the RRF and Cohesion Policy). They focus on Member States where RRF implementation 
is the most advanced for the topics covered, while ensuring a balanced representation of all Member States. They are instrumental to deep dive into the 

283   Provided separately in Annex VIII of the supporting study and summarised in the next section. 

97 

 
 
implementation  of  the  Facility  in  key  policy  areas,  but  cannot  be  considered  as  representative  of  all  topics  or  all  Member  States,  due  to  variety  and 
heterogeneity of measures included in the Member States RRPs.  

Summary of results of the case studies 

The case studies were produced by the contractors of the supporting study and represent data and views collected and compiled by them. The cut-off date 
of the case studies is end of September 2023 and reflects data available by that date. 

Energy efficiency buildings (green transition) 

The measures examined for this case study contribute to the green transition (pillar 1), focusing particularly on measures related to energy efficiency in 
buildings.  

This case study aims to assess the effectiveness, coherence and EU added value, and relevance of the RRF energy efficiency measures. It focuses on four 
Member States: Bulgaria, France, Latvia, and Romania.  

The main results of the case study are the following: 

Effectiveness 

The funding in  France,  Romania, and Bulgaria is  considered ambitious and contributes significantly to the identified investment  needs, while Latvia's 
funding  falls  short  of  its  renovation  needs.  Latvia  has  however  allocated  significant  funding  to  similar  measures  under  EU  structural  funds.  Common 
challenges in all countries include a lack of skilled workforce and rising material prices, which can impact implementation of the measures. Whilst the four 
Member States under study meet the threshold for medium-depth renovations required by the Commission to meet the minimum of 30% energy saving, 
many of the 27 Member States lack of measures for deep-renovations (i.e. that go beyond the 30% energy savings minimum). There are however some 
exceptions to this lack of incentives towards realising deep renovations: for example, the French ‘MaPrimeRenov’ incentivises deeper renovation through 
bonuses to beneficiaries based on the energy saving obtained. Similarly, the Romanian Renovation Wave Fund contains a specific call for deep renovations 
and has earmarked EUR 255 million for it. 

98 

 
In terms of effectiveness and impact of the relevant measures, France and Romania are making good progress toward their milestones and targets for energy 
efficiency in buildings. Both countries have fulfilled or completed all their milestones and targets that were due in 2022 and were on track for 2023. Latvia 
is somewhat behind, and Bulgaria is lagging behind their indicative timeline due to political tensions.  

It  is  too  early to  draw conclusions about  the impacts  on energy savings  of the implemented measures and investments  due to  the long-term  nature of 
construction  projects.  Various  outputs  have  however  been  achieved,  such  as  published  calls,  sufficient  number  of  applicants  and  of  granted  projects. 
Availability of information on results, particularly quantitative results, of different measures differs significantly between countries.  

Apart from Latvia, all countries provide enabling reforms and technical assistance to ensure the effectiveness of the grants  provided. For example, the 
French plan foresees a reform of the thermic regulation of new buildings as well as a housing policy reform. France also has a pre-existing public scheme 
that provides technical assistance. Bulgaria’s plan includes several reforms with the one to create one-stop shops being key in providing technical assistance 
to citizens and businesses. Finally, Romania does not provide any technical assistance but the Romanian RRP includes a reform that supports investments, 
within the RRP, to enhance energy efficiency. 

In terms of targeted stakeholders, most measures target private building owners with a few targeting public buildings. In the French plan, the amount of aid 
available to individual households depends on their specific income (i.e. the amount of financial support decreases as household income increases) and 
French government finances up to 90% of the cost of renovation for low-income households. Bulgaria is introducing a definition and criteria for energy 
poverty which will allow better targeting of vulnerable households. The Romanian instrument can cover up to 100% of the renovation costs, which is an 
advantage for poorer households but may create dependencies or high expectations on government support, particularly for households who may not need 
the aid. 

Common challenges for all four Member States analysed in the case study are a lack of skilled workforce and the recent inflation. The lack of skilled labour 
is an issue especially in Romania, Bulgaria and Latvia, and rising material prices cause a risk for the implementation of all measures. 

Coherence 

99 

 
The  RRP  measures  are  guided  by  the  principles  of  the  EU’s  Renovation  Wave  Strategy284,  building  on  the  principle  of  efficiency  and  affordability. 
Affordability in renovations is described as making energy-performing and sustainable buildings widely available, in particular for middle- and low-income 
households and vulnerable people and areas.  The measures include to  a lesser extent inclusion of decarbonisation and integration of renewables, even 
though these aspects still exist together.  

Whilst the extent of alignment between RRP measures and Member States’ National Energy and Climate Plans and Long-Run Renovation Strategies varies 
across  the  four  countries,  many  Member  States  had  a  coherent  approach  in  developing  their  measures  by  integrating  them  into  existing  policies  and 
programs. Some Member States, such as France, Latvia and Bulgaria, also had pre-existing programs that necessitated rapid RRP implementation. Synergies 
with other EU and national programs in the four Member States were identified and exploited to increase the scope and scale of the renovation efforts. The 
measures in the four Member States also align with the objectives of the REPowerEU plan, focusing on energy savings and renewable energy production, 
and some Member States (such as France and Romania) requested additional funding from REPowerEU for measures contributing to energy efficiency of 
buildings. 

EU added value 

Many of the RRP measures targeting energy efficiency of buildings in the four Member States covered in the case  study build upon existing investment 
programs, funded either nationally or from other EU funds. Importantly, the RRF however allowed the Member States to significantly expand the scope 
and funding of these measures, thus resulting in EU added value. Whilst it is too early to assess the impacts of reforms, the inclusion of energy-efficiency 
reforms in the RRPs provided additional pressure on and resulted in a political commitment from the four Member States to conduct the required legislative 
change quicker, given the synergies created by the RRF created in combining reforms and investments. Overall, the availability of RRF funding allowed 
these existing programs to substantially expand their capacity. Without the Facility, these programs might have continued, but at a much smaller scale. 

Relevance 

284   The Renovation Wave Strategy, published in October 2020, is set to improve the energy performance of buildings. The Commission aims to at least double renovation rates in the next ten years and 
make sure renovations lead to higher energy and resource efficiency. For further information, see European Commission (2020) A Renovation Wave for Europe – Greening our buildings, creating jobs, 
improving lives COM(2020) 662 final or https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficient-buildings/renovation-wave_en.  

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The RRP measures on energy efficiency in buildings are expected to remain relevant and feasible until 2026. Demand for funding remains high in all four 
Member States under study and renovation measures are well-received by the public. The ambitious EU targets up to 2050 necessitate a fundamental shift 
in Member States' energy systems, making continued investment in energy efficiency imperative. Latvian stakeholders (given their northern climate and 
old building stock) concur on the relevance of these measures, and similar supportive sentiments exist in France and Romania, where the popularity of 
renovation  programs  demonstrates  their  continued  relevance.  In  Bulgaria,  while  the  first  round  of  calls  for  application  to  the  renovation  funding  was 
successful, the reduction in available renovation grants (from covering 100% of the costs of renovation to covering 80% of the costs) may impact demand 
and require mitigating actions, such as the creation of a one-stop shop integrating all information necessary for energy renovations and enabling energy 
efficiency  improvements  under  an  Energy  Service  Companies  model  (both  are  reforms  foreseen  in  the  Bulgarian  RRP)  or  the  provision  of  additional 
funding. 

Threats to the relevance of these energy-efficiency measures include (i) fund exhaustion, (ii) inflation, (iii) increased construction material costs, and (iv) 
the need for future-proofing renovations. The proposed revision of the Energy Performance of Building Directive285 – especially regarding harmonisation 
of Energy Performance Certificates and Minimum Energy Performance Standards – may affect the relevance of RRP measures, although it is not yet clear 
what the concrete impacts may be. 

Digitalisation of healthcare (digital transformation) 

The measures examined for this case study contribute to two of the RRF pillars: Digital transformation (pillar 2), focusing specifically on digital public 
services,  and  health,  and  economic,  social  and  institutional  resilience  (pillar  5),  focusing  specifically  on  healthcare  and  modernisation  of  public 
administration and delivery of public services.  

This case study aims to assess the effectiveness, coherence, EU added value, and relevance of the RRF eHealth investments. It focuses on five Member 
States: Belgium, Croatia, Czechia, Denmark and Estonia.  

The main results of the case study are the following: 

285   For further information, see https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficient-buildings/energy-performance-buildings-directive_en#:~:text=The%20revised%20directive%20will% 

20increase,of%20infrastructure%20for%20sustainable%20mobility.   

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Effectiveness 

The measures put forward in the five Member States support the roll out of eHealth services, telemedicine solutions, and improvements in healthcare data 
management. They have generally been effective in achieving their objectives, such as empowering patients, optimising healthcare delivery, and fostering 
innovation. The measures positively impacted healthcare systems, including the use of e-consultations and digital tools to improve patient care and access 
to specialists. Additionally, efforts to strengthen eHealth governance and ensure data security are highlighted as essential for the success of these measures. 

In Belgium, the establishment of a Health Data Authority and clear architecture for sub-projects has been achieved, raising awareness among stakeholders. 
In  Czechia,  the  release  of  prioritised  use  case  standards  and  the  publication  of  telemedicine  guidelines  represent  notable  milestones,  with  further 
advancements expected through the RRP. Croatia’s Telecordis project has successfully improved healthcare access and quality in remote areas through 
telemedicine.  In  Denmark,  telemedicine  services  like  KontaktLæge  have  been  integrated  into  various  healthcare  settings,  and  patient  involvement  in 
telemedicine  has  shown  promising  results.  Estonia’s  measures  have  successfully  strengthened  primary  healthcare  and  renewed  e ealth  governance, 
ensuring improved access to specialist care and updated governance frameworks. 

Coherence 

All analysed measures address CSRs on health or healthcare. The measures of Belgium, Croatia, Czechia and Estonia align with their respective healthcare 
CSRs, while Denmark’s measures focus on improving healthcare resilience without specific e ealth CSRs. 

Investments and reforms in the RRPs are aligned in all Member States, except Czechia, which only put forward reforms related to eHealth. In Croatia, 
investments align well with the eHealth reform, promoting remote monitoring and data transmission in healthcare. In Denmark, a standalone investment 
supports digital health initiatives. Estonia’s investment aligns with multiple healthcare reforms, improving healthcare accessibility and integration. Belgium 
does not have eHealth reforms, though adopted a legislation setting up the Health Data Authority. In all Member States, the measures complement various 
actions put forward by country-level strategies.  

EU added value 

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The RRF has proven to be a crucial instrument for supporting the digitalisation of healthcare in Belgium, empowering regions and expediting innovative 
projects. Croatia's national eHealth information management system was not funded by the RRF, but it aimed at enhancing eHealth management nationally. 
Czechia and Denmark also view the RRF as the right instrument for this purpose. Estonia did not use the RRF to support healthcare digitalisation. 

In Belgium, the RRF was vital for the successful implementation of eHealth investments, aiding with private sector engagement and funding. Without it, 
project  delays  would  have  been  likely.  Without  RRF  funding,  Czechia  would  have  depended  on  other  programmes,  but  the  speed  and  scope  of 
implementation would have been uncertain. Croatia's national eHealth information management system was not funded by the RRF, but it aimed to enhance 
eHealth management nationally. Denmark's KontaktLaege app and telemedicine projects, being relatively small, would have proceeded even without the 
RRF due to their importance in the Member State's healthcare system.  

Relevance 

In Belgium, several RRF projects address administrative tasks and healthcare efficiency, although not all intended projects made it into the RRF scope. A 
three-year timeframe remains sufficient for implementing IT-related sub-projects with a focus on educating stakeholders for effective utilisation. In Croatia, 
eHealth projects enhance digital healthcare access and telemedicine services, especially in remote areas. For the implementation, telemedical services were 
prioritised due to the COVID-19 pandemic, while costly investments in innovative technologies pose challenges. For Czechia, there is the potential for a 
significant shift from fragmented paper-based systems to standardised interoperability. The Member State integrated stakeholder needs into its strategy 
documents and ongoing  discussions. Denmark's  measures  transform  patient  interactions through  telemedicine, with  apps  and electronic questionnaires 
improving healthcare efficiency. They continue to be relevant, especially post-COVID, with a strong emphasis on digital solutions in healthcare and respond 
to the needs of patients, healthcare providers, and policymakers by creating a resilient healthcare system. Estonia has successfully implemented all eHealth 
measures, aligning with the needs of patients, healthcare providers, and policymakers, aiming to enhance accessibility, reduce costs, and promote a human-
centred approach in healthcare. 

Support to SMEs (smart, sustainable and inclusive growth) 

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The measures examined for this case study contribute to the smart, sustainable and inclusive growth pillar286 with a particular focus on SMEs and on the 
policy areas ‘Support to SMEs’, ‘Business Environment/ Entrepreneurship’, ‘Research, Development and Innovation’ and ‘Digitalisation of Businesses’.  

This case study aims to assess the effectiveness, coherence, EU added value, and relevance of the measures supporting SMEs. It focuses on four Member 
States: Greece, Ireland, Portugal, and Finland.   

Effectiveness 

Across the analysed Member States, progress on SME-related measures varies. Overall, no major delays have been identified in implementing SME-related 
measures across Member States. Across the consulted stakeholders from the four Member States, there is a general consensus that they will be successful 
in completing or disbursing the RRF funding before 2026.   

Coherence 

Regarding coherence with existing national or EU policies targeting SMEs, the case study focuses on coherence with the Small Business Act (‘SBA’), the 
Invest EU programme, and the Single Market Principles. It finds that the first three SBA key principles, which aim at creating a supporting environment 
for entrepreneurship, receive relatively less attention through SME-related measures in the four selected Member States compared to the remaining SBA 
key principles.  

The Greek RRP aligns with  EU programs  and  SBA, particularly  in  reducing  administrative burden, but  falls short in  supporting  SME growth  beyond 
national borders. 

The Finnish RRP addresses the European Commission’s recommendations for internationalising Finnish SMEs and includes measures for digital and green 
transitions. 

286   As stipulated in the RRF Regulation, the pillar covers smart, sustainable and inclusive growth, including economic cohesion, jobs, productivity, competitiveness, research, development and innovation, 
and a well-functioning internal market with strong SMEs. As such the pillar in itself is rather broad, but the regulation further emphasises the importance of promoting economic development that is 
both intelligent and environmentally sustainable. 

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Irish SME measures cover a limited number of SBA key principles, with a focus on reducing regulatory barriers and accessing potential digital and green 
opportunities. 

Portuguese measures align with SBA principles, particularly by focusing on cross-border e-commerce, green investments, and access to finance through 
Banco Português de Fomento. 

The case study also finds that none of the selected Member States have included provisions in their regulatory simplification measures to enhance SMEs’ 
access to public procurement. Regarding the alignment with Invest EU, the Greek RRF loan facility shows strong alignment with the Invest EU program, 
contributing to addressing the financing gap in the Member State. 

Regarding the alignment with  the EU SME strategy, there are varying  degrees of  alignment  across  Member States with  a focus on SMEs driving the 
sustainable transition and empowering SMEs to reap the benefits of the digital transition. In contrast, the main pillars of reducing the regulatory burden, 
improving market access, and improving access to financing are the least covered by SME-related measures. More specifically, no Member State included 
in the analysis targets laying the groundwork for an SME IPO Fund and only Portugal covers (partly) the sub-pillar on creating a more conducive and 
inclusive environment for access to finance.  

When looking at the coherence of the measures with the principles of the EU Single Market in providing equal access to RRP opportunities to EU companies 
the SME-related measures included in the four selected RRPs allow for the participation of foreign businesses. No clear example or case of this occurring 
could however be identified. To facilitate access, information for Finnish and Portuguese measures had been made available in English next to their national 
languages, however in Greece information was often only available in Greek. 

EU added value 

Stakeholders across the four Member States generally agree that investment measures and some reform measures implemented under the selected RRPs 
would not have been executed without the existence of the RRF. The Facility’s dedicated funding source motivated Member States to address immediate 
recovery  needs  while  driving  long-term  challenges  like  digitalisation,  the  green  transition  and  innovation,  as  exemplified  by  Portugal’s  digital 
transformation measures with broader scope and impact due to the RRF. 

Relevance 

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The SME-related measures successfully cover digital and green areas by providing investment support and improving regulatory hurdles for investments 
in these areas.  The coverage of included measures in addressing the SME-relevant CSRs from the 2020 European Semester varies significantly by Member 
State. For example, while Greece covers all relevant CSRs and Portugal and Finland most of them, the Irish measures only address one CSR.  Beyond the 
relevance of the measures regarding the CSRs, the study also looked at SME-specific needs identified in the EU SME Performance Review. Similarly, 
here, the study found that Greece covers all of their 2021 and 2023 challenges fully or partially and Portugal covers all but one related to late payments. 
Both  Finland  and  Ireland’s  measures  are  less  relevant  regarding  the  needs  identified  by  the  SME  Performance  Review.   owever,  Finland  especially 
manages to address the issue of internationalisation and skills. 

Active labour market policies (social and territorial cohesion) 

The measures examined for this case study contribute to social and territorial cohesion (pillar 4) and relate to the modernisation of labour market institutions 
and employment support in the RRPs, focusing on active labour market policies (‘ALMPs’). The analysis also examines the role of public employment 
services (‘PES’).  

The case study analyses the effectiveness, coherence, EU added value and relevance of measures relating to ALMPs. It focuses  on four member states, 
France, Italy, Spain and Croatia, selected because of their significant labour market challenges reflected in the CSRs. They were also selected because all 
four Member States contain significant reforms and investments targeted at active labour market policies in their RRPs.  

The main results of the case study are the following: 

Effectiveness 

ALMP measures generally address key labour market challenges and CSRs. However, the labour market situation of vulnerable groups (France, Croatia) 
and the coordination of ALMP between territorial levels and with other employment and social policies (Spain, Italy) could have been addressed more 
comprehensively. 

Implementation of ALMP measures is progressing in all Member States. In Italy and France, take-up of ALMP measures is exceeding the (interim) targets 
agreed, in line with the fact that higher targets were set at national level. In Croatia, however, issues are observed regarding the new ALMPs, and the target 
envisioned for 2025 might not be reached. 

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The  case  study  finds  that  implementation  progress  can  be  helped  or  hindered  by  measures’  design  features  and  external  factors,  such  as  emigration.  
Investment in the capacity of regional actors to deliver measures is also of crucial importance for successful implementation.  

The labour market impact of the measures is difficult to evaluate, given the short time horizon. Early evaluations for France suggest that measures have 
had a positive effect on the quality, if not quantity, of employment for young people. Preliminary data on the Italian National Programme for the Guaranteed 
Employability of Workers (‘G L’) programme shows limited success, with only one third of participants in an active employment relationship six months 
after entering the programme. 

Concerning the impact of the measures on social and territorial cohesion, results are mixed. In Italy, Spain and Croatia, measures include explicit design 
features aimed at furthering one or both of these. In contrast, the most significant French measures focus on a large population. This low level of targeting 
is likely to limit the capacity of the measures to advance social or territorial cohesion. In addition, even in Member States where social and territorial 
cohesion  are  an  explicit  aim  of  the  measures,  implementation  difficulties  can  undermine  these  goals.  In  Croatia,  actual  take-up  of  measures  among 
vulnerable groups appears low to date. In Italy, the picture is rather positive with regard to social cohesion, as take-up of the GOL programme among 
vulnerable groups is high. Yet efforts to enhance territorial cohesion appear to have had a limited effect, as regions benefitting most from GOL take-up or 
PES staff increases do not appear to be the ones most structurally disadvantaged.  

Coherence 

A number of measures  largely  build on the previous institutional  and policy regime, particularly  in France,  Italy  and partially in  Croatia. This  can be 
problematic if measures constitute a continuation of previous malfunctioning governance structures, such as the persistent issues concerning the lack of 
coordination of ALMPs in Italy. In Spain or Croatia, however, innovations in ALMPs were advanced in order to address malfunctioning elements in the 
previous system. Underlying structural issues such as low levels of funding or low capacity of public employment services persist in Spain and Croatia and 
could undermine the coherence of measures within existing structures, if not remedied.  

Synergies and complementarities between investments and reforms in the plans can be identified, including linkages between specific measures and broader 
policies within the plans. Synergies between RRP measures on ALMPs and other EU or national funds exist in all Member States. Specifically, several 
examples of synergies between the RRF and ESF+ can be identified. 

EU added value 

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The added value of RRF measures varies across Member States. In France, all measures would have been implemented in the absence of the RRF. In Spain 
and Italy, some measures would have been implemented without the RRF, but there are some examples where the RRF appears to have provided an impetus 
for reform. Finally, Croatia is a case where the RRF was used to advance significant structural reforms that would likely not have been advanced in its 
absence. 

Relevance 

In the French RRP, a significant number of ALMP measures were heavily frontloaded. Where measures were designed specifically as a crisis response 
(e.g.  youth  hiring  subsidy),  rather  than  specifically  targeting  structural  challenges,  continued  relevance  is  limited.  However,  the  majority  of  measures 
already existed prior to the introduction of the RRP, and continue to be used currently, though scaled back to pre-crisis levels. Beyond measures focused 
on young people, there is also a clear emphasis on up- and re-skilling, which is expected to have continuing relevance in the context of structural labour 
market changes. Employment of vulnerable groups however remains a significant labour market challenge in France, along with labour shortages and skills 
mismatches, and should be addressed through further measures in the future. In Italy, Spain and Croatia, measures have a stronger focus on structural labour 
market challenges, which increases their continuing relevance. Nevertheless, issues related to the implementation of measures, particularly those related to 
the effectiveness of regional actors and coordination of policies, may continue to hinder implementation in coming years in Italy and Spain, thereby reducing 
the relevance of measures. 

Rule of law (health, and economic, social and institutional resilience) 

This case study reflects the state of play of implementation of the RRF on 30 September 2023.    

This  case  study  analyses  the  contribution  of  the  RRF  to  institutional  resilience,  derived  from  investments  and  reforms  aimed  at  modernising  public 
administrations and improving the effectiveness and integrity of public governance institutions. This is done by analysing the effectiveness, coherence, EU 
added value, and relevance of a selected group of RRF measures in the field of justice. 

Three Member States have been selected to conduct the case study: Hungary, Romania and Poland. The three countries have included various reforms 
aimed at strengthening the independence of their judicial systems in their RRPs. 

The main results of the case study are the following: 

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Effectiveness 

Among  the  10  measures  under  study  and  due  until  Q2  2023,  by  September  2023  only  one  non-legislative  reform  has  been  formally  notified  to  the 
Commission and positively assessed as part of a payment request: the adoption of a strategy for the judiciary in Romania. 

Hungary and Romania have adopted key legislative reforms in response to milestones planned up to Q2 2023, even if not always in line with the indicative 
calendar. Poland has adopted legislation to reform the disciplinary regime of judges, but the most recent reform has not yet entered into force, as it is 
pending at the Constitutional Court. None of these legislative acts have been formally notified to the Commission as part of a payment request at the time 
the case study was completed.  

In some cases, it is uncertain if the adopted legislative amendments will be notified in their current form to the Commission or will be further revised before 
notification. It is also unclear if the Commission will consider these amendments sufficient to fulfil the milestones. This is particularly true for milestones 
that include multiple legislative and non-legislative requirements or elements subject to interpretation (e.g. introduction of an amendment to strengthen 
the independence of judges).   

It is too early to assess the results of the recent reforms adopted. However, an overview can rely on the opinions of national experts regarding the potential 
and expected results of these reforms. These opinions should be interpreted with caution, as some of the reforms may be subject to further amendments 
before being formally notified to the Commission or complemented with additional regulations, and expert opinions may go beyond the formal milestone 
requirements. 

In Hungary, national experts acknowledge that the justice package includes provisions to strengthen the powers and role of the National Judicial Council, 
reinforce the independence of Hungary’s Supreme Court (Kúria), abolish the power of public authorities to lodge constitutional complaints and remove 
obstacles to references for preliminary rulings to the European Court of Justice but point at weaknesses in the reform which  may hamper the effective 
application of the laws. 

In Poland, experts287 acknowledge that the new Chamber of Professional Liability has allowed to review various decisions taken by the former Disciplinary 
Chamber and has cancelled all the suspensions adopted by the former Chamber. However, they note that a number of judges continue to be subject to 

287   The profile of the experts mentioned in this case study summary is listed in annex 1 of the case study; eight experts were interviewed in total. 

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disciplinary investigations and proceedings related to the content of their judicial decisions and forced transfers. Besides, there is wide consensus that the 
new Chamber does not comply with the requirement stemming from Article 19(1) TEU of being an “independent and impartial court established by the 
law”. 

In Romania, the general consensus is that the Justice Laws have brought positive effects, such as more safeguards regarding the civil and disciplinary 
liability of magistrates and new provisions to make the Supreme Council of the Magistracy more transparent and accountable. However, some experts as 
well  as  the  Venice  Commission,  consider  that  some  provisions  are  problematic  and  require  further  improvement  (e.g.  on  the  rules  governing  the 
appointment of deputy managers in courts and prosecutors’ offices, or on the duration of the mandate of high-ranking prosecutors).    

Coherence 

The use of the RRF is well articulated with that of other EU-level instruments in support of justice reforms. In all three countries, RRP actions to strengthen 
the independence of justice are coherent with the analysis of priorities and concerns presented in the Commission’s Rule of Law Reports and (in the case 
of Romania) Cooperation and Verification Mechanism reports. 

However, according to some experts as well as the four largest associations of judges in Europe, the actions required in the Polish RRF are not fully 
coherent with the implementation of rulings of the European Court of Justice which declare the nullity of the former Disciplinary Chamber as well as all 
the decisions taken by this institution. 

EU added value 

Assessing the ‘added value’ of the RRF is very difficult as it implies comparing an expected situation (the expected results from implementing the RRPs) to 
a counterfactual scenario (what would have happened in the absence of the RRF). The perception of national experts however is overall positive. 

According to various national experts and stakeholders who were interviewed in the context of the study, the reluctance of the Hungarian government to 
introduce the reforms in the draft RRP provides evidence that such reforms would not have been introduced in the absence of an incentive to access EU 
support. The link between these reforms and RRF funds constituted an important motivation. According to these interviewees, E the risk of seeing EU 
cohesion funds blocked due to the non-fulfilment of the horizontal enabling condition on compliance with the Charter of Fundamental Rights was equally 
important.  

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In Poland, experts consider that the RRF has induced some positive legislative actions but has not been fully effective in bringing about the expected results 
in terms of strengthening the independence and impartiality of courts (which is the explicit goal of milestone F1G). According to national experts, various 
reasons explain this lack of effectiveness such as the fact that very few people are aware that RRF funds are conditioned on the rule of law reforms and the 
way in which RRF funds are delivered (in tranches of payments conditioned on the implementation of the corresponding reforms and investment) which 
makes possible for a reluctant government to ‘play time’ without the effects being visible to the population. 

In Romania, national experts note that the added value of the RRF in promoting the amendments to the justice laws is less clear-cut as these amendments 
were also required under the Cooperation and Verification Mechanism. Various experts from different Member States note that a positive feature of the 
RRP is that the reform commitments are very transparent and detailed in the form of milestones. This allows experts or civil society organisations to keep 
track of progress done by Member States and monitor the decisions taken by the Commission as well as preventing the procedure from potentially being 
decried as politically arbitrary.   

Relevance 

Justice measures included in the three RRPs tackle major challenges of the respective national justice systems identified in the 2021 edition of the Rule of 
Law report288. They mostly consist in legislative amendments which are expected to remain relevant over time. While they all address key aspects affecting 
the independence of the justice systems, they do not address some other structural problems. At the same time, the legal basis, nature and design of the 
RRF (a short-term and temporary instrument, with a focus on the CSRs) do not make it an appropriate instrument to address all structural concerns in an 
all-encompassing manner, but it is rather a complementary tool to other instruments that the Commission has at hand when it comes to the Rule of Law 
and justice reforms. 

288   See https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021DC0700.  

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Early Childhood Education and Care (Policies for the next generation) 

The  measures  examined  for  this  case  study  contribute  to  policies  for  the  Next  Generation  (pillar  1)  and  relate  to  early  childhood  education  and  care 
(‘ECEC’)289.  

This  case  study  aims  to  assess  the  effectiveness,  coherence,  EU  added  value,  and  relevance  of  the  RRF  ECEC investments,  focusing  on  five  specific 
Member States: Germany, Italy, Poland, Spain and Belgium (Wallonia).  

The main results of the case study are the following: 

Effectiveness 

The implementation progress varies across Member States. According to the case study estimates, the expected results by Member States are the following: 

• 

Italy:  Creation of 237,500-244,300 ECEC places, enhancing  coverage. This  could  elevate public or publicly  funded childcare availability from 
13.3% to 27.6%. 

•  Poland: RRF and ESF+ will establish 102,577 new childcare places, taking coverage from 20.2% to 29.9%, progressing towards the national 33% 

target by 2030290. 

•  Belgium (Wallonia): The RRF expansion will boost regional coverage from 28.2% to 32.5%, nearly reaching the 33% regional target. 

•  Germany: The RRF investment aims to elevate childcare coverage to 38.3%, increasing affordability for 30.3% of the population. 

•  Spain:  The  Spanish  RRF  plans  foresee  an  increase  in  childcare  coverage  from  40.2%  to  46%,  possibly  exceeding  the  50%  target  in  the  Child 

Guarantee National Action Plan291 and expanding coverage of affordable services to 26,5%.  

289   ECEC refers to any regulated arrangement that provides education and care for children from birth to compulsory primary school age. https://education.ec.europa.eu/education-levels/early-childhood-

education-and-care/about-early-childhood-education-and-care.  

290   See https://www.gov.pl/web/rownetraktowanie/krajowy-program-dzialan-na-rzecz-rownego-traktowania. 
291   See https://ec.europa.eu/social/ajax/countries.jsp?langId=en&intPageId=5538.  

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A significant reduction in existing territorial gaps in the offer of affordable childcare services is expected in Poland (among provinces), Germany and Spain 
(among regions)292. Decreases are expected to be moderate in Italy (among provinces) and less significant in Belgium (among municipalities). In Poland, 
Spain and Italy, socio-economically disadvantaged territories are expected to increase coverage to a larger extent. 

In all analysed Member States, there have been some delays in the implementation of the investments to expand ECEC services. The main implementation 
challenges involved issues with participation of municipalities in tenders, either because of funding mechanisms (municipalities need to anticipate costs), 
the lack of local capacity, or due to higher costs linked to rising inflation. 

Coherence 

Complementary reforms and investments have been included in the Spanish and Polish RRPs. In the case of Italy  and Belgium, the RRF investments 
explicitly contributes to the implementation of reforms adopted at the national level before the RRF. No explicit link is found in Germany. 

Poland stands out for its integrated EU funding approach with the reforms. Other Member States, such as Germany and Belgium have combined RRF funds 
with national resources in order to increase impact of the investments and expand further the coverage of childcare services. In the case of Italy, national 
resources have been allocated to cover the recurrent costs of the investments in infrastructure under the RRF. 

The European Union provides guidance to member states in the field of ECEC through key documents, including the 2019 Council Recommendation on 
High-quality ECEC293, the 2021 Council Recommendation on the European Child Guarantee294, and the 2022 Council Recommendation on Early Childhood 
Education  and  Care,  establishing  the  new  “Barcelona  Targets”  for  2030295.  Belgium’s,  Italy’s,  Poland’s,  and  Spain’s  RRPs  align  with  some  of  these 
priorities. For instance, Italy’s plan connects its ECEC investment to the Italian Child Guarantee action plan, aiming to expand childcare services and 
accessibility, with a focus on reducing fees. Spain and Belgium also integrate ECEC measures into their respective Child Guarantee action plans. Poland 
instead refers to the 2019 High-quality ECEC recommendations, while Germany’s plan refers only to the CSRs 20 9.   

292   For ES and DE data on places to be created are available only at regional level. For BE, IT and PL data are available at municipal level.  owever, for IT and PL the large number of municipalities 

involved (more than 2.000), make reporting at this sub-national level complicated and potentially not explicative. As a result, we decided to aggregate results at the NUTS-3 level (provinces). 

293   See https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019H0605(01).  
294   See https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021H1004.  
295   See https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022H1220(01).  

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EU added value 

The primary contribution of the RRF has been to infuse fresh financial resources to support the expansion of childcare facilities. In Italy and Spain, the 
RRF resources are completely additional, namely without the RRF these investments would have not taken place. In the case of Belgium, the RRF funds 
are additional and top up already existing national fundings. In Poland, RRF funding is additional and integrates other EU funding – notably from the ESF+ 
and national funding. The exception is Germany, where all funding under the RRF was already previously budgeted for, and thus there is no EU added 
value as such. 

Relevance 

The case study demonstrates that the RRF will contribute to tackle structural problems facing ECEC systems in the selected Member States, notably the 
lack  of  available  services,  territorial  inequalities  in  coverage  with  socio-economically  disadvantaged  areas  lagging  behind.  The  relevance  of  the 
interventions in the future, might however depend upon a number of critical factors, as several challenges are undermining the feasibility of the measures. 
These challenges include tight project timelines, a lack of prioritisation for funding in disadvantaged areas, rising infrastructure costs due to inflation, 
complex  procedures,  inadequate  technical  assistance,  and  uncertainty  regarding  sustaining  operational  costs.  The  potential  insufficiency  of  budget 
allocations for covering costs of running of new services, and the absence of fiscal equalisation mechanisms is also a major concern for municipalities. 
These factors may deter local authorities from applying for funding and/or in the future, force some to privatise services, reducing affordability, or quality, 
undermining the potential impact of childcare on both children’s development and parents’ opportunities to access labour market and increase households’ 
income. At the same time, staff shortages might affect the implementation of the measures adopted under the RRF with the risk that the new places created 
are not activated. 

Cross-border projects 

The measures examined for this case study contribute to cross-border and multi-country projects, with specific focus on Important Projects of Common 
European Interest (‘IPCEIs’). Member States can decide to include in their RRPs investments in cross-border projects in the digital, transport, energy, or 
waste sectors. Given the RRF’s emphasis on helping support the EU in reaching its climate neutrality targets and the digital transition, the measures to be 
examined for this case study fall under two main pillars, namely green transition and digital transformation. 

114 

 
The multi-country projects with the highest take-up in RRPs are the eleven participations in IPCEIs on hydrogen (included in eight RRPs). The IPCEIs on 
hydrogen include specific projects focused on building a European hydrogen ecosystem, including increased support for hydrogen production, storage, and 
applications, in particular in energy-intensive industrial and mobility sectors that are difficult to decarbonise. Regarding the digital transition, the case study 
analyses a handful of countries that decided to invest even in microelectronics, where areas such as low-power electronics, sensors, and process technologies 
will be strengthened. 

This case study aims to assess the effectiveness, coherence, relevance and added value of the RRF cross-border and multi-country projects, focusing on 
four specific Member States: Austria, Germany, France, and Spain. 

The main results of the case study are the following: 

Effectiveness 

The implementation progress varies across Member States. The expected results by Member States are the following: 

•  Austria: 2 0 million EUR investment to promote Europe’s autonomy in semiconductor production and promotion of integrated projects along the 

hydrogen value chain.   

•  France:  .2   billion EUR investment in development of carbon-free hydrogen production, with a target of  40MW/year electrolyser production 

capacity by Q4 202 . 

•  Germany:   .   billion  EUR  investment  in  hydrogen  decarbonisation  technologies,  with  a  target  of  at  least  300MW/year  electrolyser  production 
capacity by Q3 202 .  .  billion EUR investment in electronics design capabilities and deployment of the next generation processors and other 
electronic components. 

•  Spain: Five technological developments or prototypes throughout the renewable hydrogen value chain, two renewable hydrogen clusters and at least 

 00MW of electrolyser capacity.  

Progress of IPCEI-related implementation of reforms and investments within the RRPs varies significantly across the different IPCEIs and within the same 
IPCEI at project level.  

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In the case of microelectronics, Austrian companies reported having nearly completed the construction of the manufacturing factory, which will be followed 
by the setting up of the machine by the end of 2023, while others reported having started a successful simulation for a new furnace.  ydrogen-related 
investments, especially in Germany, foresee the building or renovation of infrastructure, which will lead to concrete results in the longer term. Progress 
registered so far regards the reduction of C 2 emissions and development of certain technologies. In Austria, half of the approved projects have started 
reporting some progress, including completing the material and new infrastructure testing and the approval of the plan to build an electrolyser in the country. 

While most milestones of the analysed IPCEI-related measures, which are mostly reforms, are fulfilled, the implementation of most IPCEI investments is 
facing potential delays. According to stakeholders interviewed in the context of the case study, this is due partly to differences in the official approval 
timelines of each Member State involved but also the result of the lengthy State aid notification process. Stakeholders found the process complex and not 
clearly defined in terms of processes, timeline, and responsibilities. Communication amongst participating Member States appears also to be challenging 
at times. 

In 2021, the Commission updated its guidance to Member States and its templates, which also contain detailed advice related to the procedure under the 
ICPEI Communication296.  

Coherence 

IPCEIs allow Member States to finance the early stages of industrial policy projects that are in line with their national and European priorities. The hydrogen 
IPCEI is in line with the Commission's efforts to support the development of an innovative and sustainable European hydrogen industry. Hydrogen plays 
a pivotal role within the European Green Deal and the REPowerEU plan, as its use will accelerate the decarbonisation of the energy system and provide an 
alternative to Russian imported fossil fuels.  

Similarly, the IPCEI on microelectronics and connectivity directly contributes to achieving several EU objectives including the European Green Deal, 
Europe’s Digital Decade, the Digital Europe Programme, the Connecting Europe Facility and the European Chips Act.  

296   See European Commission (2021) Communication from the Commission Criteria for the analysis of the compatibility with the internal market of State aid to promote the execution of important projects 
of  common  European  interest  (2021/C  528/02),  available  at:  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.C.2021.528.01.0010.01.ENG&toc=OJ%3AC%3A2021%3A5 
28%3ATOC.   

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While European regulations exclude the possibility of double-funding, synergies between the RRF and other EU funds are important. Member States can 
invest part of their RRF funds through the Member State Compartment of InvestEU. InvestEU provides financial instruments and incentives to attract 
private capital, while IPCEIs focus on identifying and promoting projects that have a significant impact on European competitiveness and innovation. 

EU added value 

IPCEI  projects  are  designed  to  address  important  market  or  systemic  failures  which  cannot  otherwise  be  adequately  addressed  and  thus  contribute  to 
providing  a  comparative  advantage  to  European  companies.  Stakeholders,  both  private  and  public,  partaking  in  different  IPCEI  waves  of  projects, 
emphasised the added value of cross-border projects. The case of the IPCEI on Microelectronics highlights how targeted funding of strategic value chains 
can help keep European companies remain relevant in the market. The case of the IPCEI on Batteries, enabled the development of a value chain that did 
not exist in the EU before, ranging from mining, repurposing, recycling and refining, to manufacturing of cells, modules, and systems as well as dedicated 
software and testing systems and solutions. 

Relevance 

As Europe seeks to maintain its competitiveness on the global stage, the identification and support of strategically important industries and technologies is 
essential. IPCEIs represent a useful tool for identifying such sectors as well as creating complex new value chains that have the potential to ensure the EU’s 
increased autonomy, long-term competitiveness, and economic growth. In light of the green and digital transition, it is vital to explore IPCEIs as a support 
to such areas to reach hydrogen production goals, phase out fossil fuels, and work towards energy independence. The outcomes of these projects are not 
solely focused on the near future; rather, they contribute to the EU's long-term sustainable energy objectives that go beyond 2026. 

Interaction between other EU Cohesion Policy and the RRF. 

Cohesion policy is the EU investment tool that lends itself best to an analysis in relation to the RRF. As the EU’s main investment policy, covering about 
a third of the EU budget, Cohesion policy is the most suitable term of comparison based on different dimensions: 

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•  Size. The amount of resources mobilised by Cohesion policy is the one that gets closest to the financial weight of the RRF. Taken together, the set 
of four funds297 that make up Cohesion policy in 2021-2027 have a size of about EUR 543 billion (of which EUR 377 billion in EU co-financing 
and EUR 166 billion in national co-financing) 

• 

Investment types. No other EU fund covers a similar breadth of investment types as Cohesion policy and the RRF. Both are multisectoral and aim 
to contribute to a diverse set of socio-economic policy objectives298.  

•  Link to reforms. Both instruments have recognised the importance of linking investments to an agenda of structural reforms.  

This case study aims to shed light on the interplay between the RRF and Cohesion policy, focusing on six Member States: Germany, Greece, Italy, Lithuania, 
Romania and Spain. This set of countries includes large recipients, as well as the experience of smaller countries as well. In addition, it covers countries 
with different levels of centralisation in the management of Cohesion policy funds, to better examine the potential added value of a centralised and direct 
management against a shared management system.  

The RRF model offers important innovations in the formulation and delivery of EU-funded investment policies and the support to reforms. Nevertheless, 
due to the current early stage of implementation of the RRF, definitive conclusions about its effectiveness and efficiency in comparison to Cohesion policy 
are limited. A more complete assessment inevitably requires the evidence deriving from the effects generated over time by the RRF, currently not yet 
available. 

The RRF’s novel elements bridging existing gaps have had varying importance in national contexts, depending on Member States’ specificities: 

•  Reforms. The RRF provides support in exchange for the implementation of investments and reforms, including those reforms not involving specific 
costs. These reforms improve the institutional and strategic framework in which also Cohesion policy investments are implemented, and do so with 
a strength that CP has traditionally not had, in terms of support to enabling frameworks. 

•  Size. The RRF has mobilised an amount of resources that, thanks to its sheer size, enables a scale of ambition that CP alone could not reach.  

297   European Regional Development Fund (ERDF), European Social Fund + (ESF+), Cohesion Fund (CF), Just Transition Fund (JTF). 
298   The policy finds its legal basis in Articles 174 to 178 of the Treaty on the Functioning of the European Union (TFEU). 

118 

 
 
•  More developed regions. The RRF has become a tool to increase competitiveness and channel investment to regions which are not among the less 
developed ones (as opposed to Cohesion policy focus on those299), but in which there are nevertheless major needs in terms of both the green and 
digital transitions. 

These elements, however, are also  related to challenges. First, within the context of the RRPs, the term  “reform” has encompassed actions of varying 
degrees of ambition and scope. Second, the size of resources mobilised under the RRF, coupled with the relatively tight eligibility period, resulted in a 
certain prioritisation at programming level that favoured the RRF over Cohesion policy. This, in turn, has triggered displacement effects in some Member 
States. Furthermore, the influx of RRF funds brought about a widespread increase in the workload for administrations at both  national and local levels 
across Member States. This elevated workload has not necessarily been fully mitigated by the measures put in place to strengthen administrations. Third, 
the lack of a territorial dimension in the RRF risks increasing disparities within Member States, and a conflict can be identified with Cohesion policy's goal 
of supporting regional convergence. Concerns about channelling resources to more developed areas were raised particularly with regard to Spain and Italy, 
the main beneficiaries of RRF grants, where territories with a better institutional capacity and a more vibrant productive ecosystem are also more able to 
conceive project proposals and attract financing. The territorial dimension is however not limited to the channelling of resources to certain types of territory; 
it  concerns  also  stakeholder  engagement  and  an  integrated  investment  approach,  and  these  two  aspects  as  well  have  so  far  received  a  more  extensive 
attention under Cohesion policy. Especially at a time of significant divides between core agglomerations and the peripheries, a weak territorial dimension 
may pose threats in terms of balanced socio-economic development.  

In terms of sectors of intervention, RRPs generally cover the same areas Cohesion policy has traditionally focused on, and beyond.  

As the focus of RRF implementation shifts towards investments, similar challenges are emerging to those that have long been associated with Cohesion 
policy. The RRF’s first phase of implementation, which focused mainly on reforms, has progressed generally in a timely way in 2021-2022. In relation to 
investments, however, administrative capacity issues, excessive administrative burden for managing authorities, the lack of mature projects, a difficult 
balance to find between the necessity of controls and an excessive level of scrutiny, in some Member States came to the surface in a fashion not dissimilar 
to traditional challenges that Cohesion policy has been long grappling with.  

299   ERDF and ESF+ foresee higher EU co-financing shares for less developed regions. Moreover, the CF is available only for Member States with a GNI per capita below 90% of the EU average.  

119 

 
 
There is a widespread perception that the simplification and administrative cost reduction expected from the RRF has not materialised. Although it was 
anticipated that the RRF would impose a lighter burden compared to Cohesion policy due to its centralised approach and the performance-based payment 
system, interviewed stakeholders have signalled that, in fact, there has not been a significant difference in terms of administrative burden yet. Survey results 
point to the same conclusion. As the investment component of RRPs progressively comes into play, more evidence is expected to become available in this 
regard.  

In terms of flexibility to adjust to a changing context, the RRF emerges as more rigid than Cohesion policy. In 2014-20, Cohesion policy offered a ready-
to-use policy framework to deliver immediate and wide-ranging support at a critical time and allowed the reprogramming of resources, thereby proving to 
be a flexible tool for policy making. Even if the RRF greatly expanded the possibilities for public investment across Member  States and is expected to 
provide a significant contribution to the removal of investment barriers, compared to Cohesion policy it is perceived as having a lower degree of flexibility 
in adapting to new circumstances. 

Ultimately, the main factors influencing the effectiveness of the RRF compared to Cohesion policy are the link to reforms, the political support, and media 
attention. The activation of structural reforms, as foreseen under the RRF, is widely acknowledged as a successful and impactful policy mechanism. Reforms 
supported by the RRF are also to the advantage of wider public investment frameworks and Cohesion policy. Reforms emerge as a decisive driver for 
change in combination with a focus on investments. The high level of priority given to the RRF by decision makers at EU level and in most Member States, 
in turn, has contributed to ensuring a mature project pipeline and, in the early phase, swift implementation. Extensive media coverage of RRPs is both a 
cause and an effect of this prioritisation and of RRF’s higher public profile compared to Cohesion policy. The impact that the RRF is expected to generate 
over  the  medium  term  likely  could  not  have  been  reached  making  use  of  the  existing  Cohesion  policy  framework  only,  as  these  three  key  elements 
influencing its effectiveness – reforms, political support, media attention – set the two instruments apart.  

Validation of the findings 

To validate the findings of the cases studies, the contractors of the supporting study have organised roundtables with representatives from national ministries 
and policy experts in the field (except for the Cohesion and Digitalisation case study). Below is the list of the roundtables: 

-  Energy Efficiency: 14 September 2023; 

-  Supporting SMEs: 12 September 2023; 

-  Rule of Law: 28 September (only with national experts); 

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-  Early Childhood Education and Care: 19 September 2023; 

-  Active Labour Market Policies: 14 September 2023; 

-  Cross-border projects: 8 September 2023. 

The contractor also organised a validation workshop to validate the main findings of the supporting study, which took place on 24 October 2023. The 
validation workshop was held under Chatham House rules, with the objective to stress-test the findings with a small group of experts. The agenda was 
organised  around  four  sessions:  (i)  a  first  session  to  take  stock  on  the  RRF  implementation,  (ii)  a  second  session  to  discuss  the  ‘performance-based 
approach’, (iii) a third session on the macroeconomic impact of the RRF, (iv) a fourth session to discuss the comparison between the RRF and Cohesion 
Policy. Overall, the discussions were open, lively and constructive. The invited experts largely supported the findings of the study, notably on the key 
success of the RRF in supporting reforms and the merit of its performance-based approach. Participants also supported the study’s findings on the RRF’s 
higher than expected administrative burden. Discussions pointed to the need to factor in the changing context of the RRF and political difficulty/sensitivity 
of some reforms/milestones. They also acknowledged the methodological caveats of the macroeconomic analysis, which is very sensitive to the assumptions 
on the additionality of RRF funds and cannot quantify the impact of reforms, thereby providing an underestimate of the effect on GDP. Participants further 
discussed possible synergies with Cohesion Policy, in the current period and hypothetically also in the future, for instance to continue funding successful 
measures started within the RRF after 2026.  

Analysis of costs and benefits 

In the context of this evaluation, the analysis of costs and benefits was conducted by the contractors of the supporting study along the following steps: cost 
mapping; assessing costs; assessing benefits; concluding on the benefit/cost ratio.  

The starting point was the mapping of relevant costs. Based on documentary review and conducted interviews, the costs of the RRF were mapped as shown 
below in table A2.4. 

Table A2.4: Mapping of Member States Administrative Costs 

DIRECT COSTS 

The funds made available to Member States, and the related financial 
costs (including Member States borrowing costs for loans) 

ADMINISTRATIVE COSTS OF RRF IMPLEMENTATION 
MEMBER STATES ADMINISTRATIVE COSTS 
Activities generating administrative costs 

121 

 
One-off 

-  Setting up the governance structure 
-  Drafting the NRRP 
-  Stakeholder consultations 
- 

Informal  dialogue  with  the  Commission  ahead  of  the  plan 
submission 

-  Official process of plan submission 
-  Drafting of the REPowerEU chapter 

Recurrent 

-  Bi-annual reporting on milestones and targets 
-  Bi-annual reporting on monitoring steps 
-  Bi-annual reporting on other EU funding 
-  Reporting on common indicators 
- 

Informal dialogue with the Commission ahead of payment requests 
submission 

-  Official submission of payment requests 
-  Monitoring and performance management 
-  Audits by national authorities 
-  Responses to audits by European authorities 

Source: Supporting study 
Note: Administrative costs do not include the costs borne by final beneficiaries or citizens to comply with obligations imposed by the RRF regulation as well as regulations related to the support received, 
such as State aid, public procurement and environmental legislation. They are out of scope of the present evaluation. 

To get an overview of administrative costs incurred in the context of the implementation of the RRF, a survey of national bodies involved in the activities 
listed in Table A2.4 was carried out. Specifically, survey respondents were asked to indicate the resources necessary, in terms of full-time equivalents 
(‘FTE’),  and  the  costs  incurred  for  external  services.  The  following  table  A2.5  shows  that  the  survey  results  are  patchy  and  do  not  provide  complete 
coverage of costs attributable to the various activities. Nevertheless, there is a relatively good coverage of information provided by coordination bodies. 
Hence, to ensure consistency, the elaborations presented in the rest of the section will focus solely on the costs reported by the coordination bodies. 

122 

 
Other bodies (e.g. 
monitoring/accounting) 

Audit Authority 

Cost for external experts  

Table A2.5: Mapping of data collected through the survey 

Member State 

Coordination body 

Ministries 

Austria 

Belgium 
Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 
Estonia 

Finland 

France 

Germany 
Greece 

Hungary 

Ireland 

Italy 

Latvia 
Lithuania 

Luxembourg 

Malta 

Netherlands 
Poland 

Portugal 

Romania 

Slovak Republic 

YES 

YES 
YES 

YES 

YES 

YES 

YES 
YES 

YES 

NO 

YES 
NO 

NO 

YES 

NO 

Partially 
YES 

NA 

NA 

YES 
YES 

YES 

YES 

YES 

NO 

Not relevant 
Not relevant 

Not relevant 

Not relevant 

Not relevant 

NO 
NO 

NO 

NO 

NO 
Only for one Ministry 

NO 

NO 

Only for three Ministries 

NO 
Not relevant 

NA 

NA 

NO 
NO 

NO 

NO 

NO 

FTE 

NO 

NO 
NO 

NO 

NO 

NO 

NO 
NO 

NO 

NO 

NO 
NO 

YES 

YES 

NO 

NO 
NO 

NA 

NA 

NO 
NO 

Maybe yes 

NO 

NO 

123 

NO 

NO 
NO 

NO 

NO 

NO 

NO 
NO 

YES 

YES 

NO 
NO 

NO 

NO 

NO 

NO 
NO 

NA 

NA 

NO 
NO 

Maybe yes 

NO 

Maybe yes 

Not relevant 

Not relevant 
NO 

NO 

NO 

YES 

Not relevant 
Not relevant 

Not relevant 

NA 

Not relevant 
NA 

NA 

NO 

NA 

Not relevant 
YES 

NA 

NA 

NO 
NO 

YES 

NO 

NO 

 
 
Slovenia 

Spain 
Sweden 
Source: Supporting study 

YES 

NO 
NA 

Not relevant 

NO 
NA 

YES 

NO 
NA 

YES 

NO 
NA 

YES 

NA 
NA 

The second step involved the assessment of costs. The quantification focused on the administrative costs related to Member State public administration. As 
said, the collection of such administrative costs was attempted via a survey of national bodies involved in the preparation of national recovery and resilience 
plans and/or their implementation. Specifically, the FTE and costs for external services were asked. Since the survey results are patchy and do not provide 
complete coverage of costs attributable to the various activities, with the only exception of national coordination bodies, the analysis focuses solely on the 
costs reported by these bodies. The figures provided by various coordination bodies should also be taken with caution since national coordination bodies 
can have different interpretations of FTE counting. Some have taken a restrictive approach, considering only the costs of coordinating bodies, while others 
(such  as  Portugal  and  Slovakia)  have  considered  the  staff  cost  of  various  other  bodies  involved in  the  relevant  activity.  A  fact-checking  process  with 
coordination bodies for the collected data was conducted after the submission of the draft final report by the external contractor to validate the data to the 
best extent possible. While some amendments and validation were received, not all coordination bodies responded, so the data validation remains partial. 
Additionally, some coordination bodies confirmed differences in understanding and time constraints in collecting data beyond their organisation.  

As for the assessment of actual benefits, quantifying and monetising them has proven to be not feasible. This is due to the wide and varied range of effects, 
most of which have not yet materialised. In the absence of a counterfactual, quantifying the ‘benefits’ of the RRF to compare them to the ‘costs’ currently 
requires estimations using macroeconomic models to predict the benefits of the RRF. A full cost-benefit analysis can only be conducted as part of the ‘ex-
post’ evaluation. 

Based on such model estimations, two sets of benefit-cost ratios at the Member State level and the EU level have been calculated. The first set concerns 
the benefit-cost ratio defined as the ratio between the absolute cumulative change in real GDP predicted by the NiGEM model to occur by 2041 as a result 
of the RRF (against the baseline) and the funding (both grants and loans) already disbursed (in real terms). The second set concerns the expected benefit-
cost ratios of the RRF funds once all funds are disbursed. In this case, the ratio is calculated as the absolute cumulative change in real GDP predicted by 
the NiGEM model to occur by 2041 as a result of the total RRF injection (relative to the baseline), i.e., the benefit, over the total funding (both grants and 
loans) in real terms, i.e., the cost. It is worth noting that the administrative costs were excluded from the benefit-cost ratio calculation due to their minimal 
impact compared to the funds disbursed/expected to be disbursed. 

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Macroeconomic modelling 

This evaluation makes use of stylised ex-ante assessments of the macroeconomic impact of NGEU and RRF investment to assess the RRF’s effect 
on the EU economies adjustment capacity and growth potential. Given the early stages of the investment supported by the RRF, there is limited data 
available to perform analysis, so the analysis relies on a model-based estimation approach. These model simulations do not provide an evaluation of the 
actual impact, but rather an ex-ante model prediction based on stylised assumptions and the planned investments put forward by the national recovery and 
resilience plans. The chosen modelling approaches focus only on investments and do not quantify the expected effect of structural reforms. 

The simulations presented build mainly upon the Commission’s QUEST model, complemented by simulations from the supporting study based 
on the NiGEM model. The QUEST assessments, comprising the whole NGEU initiative, have been conducted since 2020300 and have been updated with 
the most recent data on loan requests, inflation, and expected spending profiles as of September 2023301. The analysis employs a multi-country version of 
the QUEST model, encompassing all 27 EU Member States, as well as the rest of the world (as one big external country). While necessarily simplifying 
the full mechanics of NGEU, the setup distinguishes non-repayable support and loan allocations for each Member State. The macroeconomic analysis of 
the RRF reported in the supporting study was carried out using the National Institute Global Econometric Model (NiGEM). The following sections provide 
further explanations and details on the two models and the core technical assumptions. It is important to note that the two models (QUEST and NiGEM) 
do not factor in the impact of reforms, which can further increase the RRF’s long-term impact on GDP. 

The QUEST model results have been computed based on the whole NGEU umbrella and not only RRF investments. The RRF (loans and non-repayable 
support) encompasses approximately 90% of NGEU investments, with the remainder consisting of non-repayable support (grants). The model simulations 
assume  a  higher  additionality  for  non-repayable  support,  resulting  in  a  more  substantial  effective  difference.  For  modelling  purposes,  all  grant-type 
instruments (RRF non-repayable support and other NGEU funds) are treated the same way. 

300   For further information, see in particular, Pfeiffer P., J. Varga and J. in 't Veld (2023a) Quantifying spillovers of coordinated investment stimulus in the EU, Macroeconomic Dynamics (27), p. 1843–

1865. See also the ECFN Discussion Paper (2021): https://economy-finance.ec.europa.eu/publications/quantifying-spillovers-next-generation-eu-investment_en. 

301   The simulations consider country-specific expected RRF disbursement or spending profiles, as estimated by DG ECFIN.  

125 

 
 
Macroeconomic model NiGEM 

The macroeconomic analysis reported in the supporting study was carried out using the National Institute Global Econometric Model (NiGEM). NiGEM 
has been developed and maintained since 1987. NiGEM is a global macroeconomic model, used by both policymakers and the private sector for economic 
forecasting, scenario building and stress testing. It is used by several European central banks and international organisations such as the OECD. The model 
consists of individual country models for the major economies that are linked through trade in goods and services and integrated capital markets.  The 
individual country models within NiGEM incorporate long-run relationships grounded in economic theory with flexible lag structures that are fitted to the 
data. Because NiGEM is fitted to the data, it can be reliably used to calculate the magnitudes of the effects of various economic shocks. Specifically, a 
model such as NiGEM can provide an efficient way of assessing the development of national economies, disaggregated by demand and supply components, 
in response to RRF spending. In addition, because NiGEM is a global model with trade and financial linkages across countries, it can be used to examine 
spillovers: that is, the effects of RRF spending in one EU Member States on the rest of the European Union.  

NiGEM contains around 6,000 variables  and over 10,000 model equations, as several  variables have multiple equation options. Within  NiGEM some 
countries are represented with ‘full’ country models and some countries being represented with reduced form models. Within the European Union, NiGEM 
contains full country models for Austria, Belgium, Czechia, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, the Netherlands, Poland, 
Portugal, Romania, Spain and Sweden. It contains reduced country models for Bulgaria, Croatia, Estonia, Latvia, Lithuania, Slovakia and Slovenia. Cyprus, 
Luxembourg and Malta are not modelled separately within NiGEM.  

Figures A2.4 and A2.5 present a broad schematic overview of country models, distinguishing between the full model and reduced model specifications. As 
detailed in the figures, the key difference between the two is that in a reduced country model, there is no distinction between consumption and investment. 
That  is,  rather  than  split  domestic  demand  into  private  consumption,  private  investment,  stock-building,  government  consumption  and  government 
investment, only the split between private and public-sector spending is available and no measure of either private or public-sector capital. In both cases, 
output is demand determined in the short run and supply determined in the long run. For full country models, long-run supply is determined by population 
growth,  labour  force  participation,  the  equilibrium  unemployment  rate,  labour-augmenting  technological  progress,  and  the  capital  stock.  For  reduced 
country  models,  long-run  supply  is  simply  determined  by  trends  in  the  labour  force  and  labour-augmenting  technology.  Importantly  for  the  analysis 
contained in this report, full country models contain a link between government investment and long-run potential output and so can be used to analyse the 
long-run effects of RRF spending on investment projects. Unfortunately, this is not the case for reduced country models or for the three countries not 

126 

 
modelled separately in NiGEM, though, given these countries only represent less than four per cent of EU GDP, this should not make much of a difference 
to the overall results for the European Union. 

Figure A2.4: NiGEM Full country specification 

Source: Supporting study 

Figure A2.5: NiGEM Reduced country specification 

127 

 
 
Source: Supporting study 

Full details of the equations underlying NiGEM can be found in Handzsche et al. (2018) but the focus here is on the channels through which the RRF, by 
increasing public investment, may lead to higher EU GDP. It can be first noted that, for full country models within NiGEM, an increase in public investment, 
GI, will lead to an increase in GDP in the short run: 

Y = C + DS + PSI + GC + GI + XVOL – MVOL 

(1)  

128 

 
 
 
 
 
 
 
 
Where Y denotes GDP, C denotes household consumption, DS denotes stock-building, PSI denotes private-sector investment, GC denotes government 
consumption, XVOL denotes exports and MVOL denotes imports. The increase in GDP will depend on the size of the multiplier, which is itself determined 
by the general equilibrium responses of the other variables in equation (1). 

An increase in government investment will also lead to a higher public-sector capital stock, KG, in the future: 

KG = (1 – d) KG-1 + GI   

(2) 

And this higher capital stock itself leads to higher trend output, YCAP, and so can increase in GDP in the long run: 

YCAP = (KP + KG)1 – α – q (TECHL*ETRND) α (OIVOL*Y) q   

(3) 

Where KP denotes private-sector capital stock, TECHL denotes labour-augmenting technical progress, ETRND denotes trend employment and OIVOL is 
energy use as a share of GDP. 

These are the two channels through which an increase in public investment affects output in full country models. As reduced country models do not include 
investment or capital, for those countries the total government expenditure is shocked instead. This adds directly to domestic demand and, hence, raises 
GDP in the short run but it has no effect on potential output or GDP in the long run. 

Macroeconomic Model QUEST  

The macroeconomic analysis conducted by the Commission to ex-ante analyse the macroeconomic impact of the RRF, and reported in the Staff Working 
Document, was carried out using the QUEST model. It is a structural macro-model in the New-Keynesian tradition, based on the Dynamic Stochastic 
General Equilibrium approach, and with rigorous microeconomic foundations derived from utility and profit optimisation and including frictions in goods, 
labour and financial markets302. There are different versions of the QUEST model, estimated and calibrated, each used for specific purposes. The model 
version applied here distinguishes all 27 EU Member States and the rest of the world. Online Appendix B in Pfeiffer et al. (2023a)303 provides the full 

302   See https://economy-finance.ec.europa.eu/economic-research-and-databases/economic-research/macroeconomic-models/quest-macroeconomic-model_en  
303   Pfeiffer P., J. Varga, and J. in 't Veld (2023a) Quantifying spillovers of coordinated investment stimulus in the EU, Macroeconomic Dynamics (27), p. 1843–1865. 

129 

 
 
 
 
 
 
 
 
 
 
 
description. Although all regions are isomorphic, key country-specific features are accounted for, including trade openness, past public investment rates, 
and monetary-policy setting (i.e., participation in the euro area, the European Exchange Rate Mechanism (ERM-II), or independent national currencies). 

Overview of the QUEST model and key modelling assumptions applied in the NGEU simulations 

The analysis applies a rich, multi-region, dynamic general-equilibrium model, distinguishing all 27 EU Member States and the rest of the world304. 
The framework aims to incorporate the features relevant to fiscal-policy transmission, including price and wage rigidities,  detailed public-investment 
dynamics  with  time-to-build  delays  and  implementation  lags305,  and  (intertemporal)  government  budget  constraints.  Furthermore,  it  accounts  for  key 
country-specific features, such as trade openness and the monetary-policy setting. A detailed trade matrix explicitly accounts for bilateral trade linkages 
of all regions. The model captures linkages through cross-border value chains by including trade in intermediate inputs for tradable and non-tradable 
sectors. 

While necessarily simplifying the full mechanics of NGEU, the setup distinguishes grant and loan allocations for each Member State (based on 
the available information as of September 2023). In sum, the simulations consider NGEU funds of around 5% of EU GDP (2019)306. The approach fully 
takes into account the increase in EU debt associated with NGEU, which is assumed to be financed via GNI-based long-term contributions of the Member 
States. 

The simulation further applies the following technical assumptions: 

-  Spending composition: The simulations assume the full NGEU allocation is spent as productive public investment307. With focusing on the whole 
NGEU program, it is important to acknowledge that the QUEST model’s estimates exceed the effect of RRF investments on GDP, as the RRF only 
represents around 90% of NGEU investment. 

304   For related work on the QUEST model, see also https://economy-finance.ec.europa.eu/economic-research-and-databases/economic-research/macroeconomic-models/quest-macroeconomic-model_en  
305   Leeper, E. M., Walker, T. B., & Yang, S.-C. S. (2010). Government investment and fiscal stimulus. Journal of Monetary Economics, 57, 1000–1012. 
306   EUR 421billion in grants and EUR 293 billion in loans (in current prices). See also, https://commission.europa.eu/strategy-and-policy/recovery-plan-europe_en  
307   In national-accounts  terms,  spending on  education  and  training may  be  classified  as government  consumption,  but  for  modelling  purposes,  it  is  considered  productive  spending.  High productivity 

investment may – to some extent – also be considered as a stylised “stand-in” for reforms. 

130 

 
 
-  Grants: The simulations account for a total grant volume of EUR 421bn (in current prices), of which EUR 338bn are allocated to RRF grants. For the 
residual funds, the specific allocation key was employed where possible. Where no allocation key is given, such as with tender-based instruments, the 
RRF allocation key was used instead. 

-  Loans: The analysis considers loans of EUR 293bn, including additional requested loans with revision of RRPs (see Figure A2.6 below). 

-  Additionality: In line with previous QUEST modelling, the simulations assume that Member States use 100% of EU grants and 50% of EU loans for 
additional public investment. Only additional investments are considered in the simulations. Since the other half of loans finances general government 
spending, which is assumed to take place anyway (and thereby frees up resources), the impact on national debt is also 50%. Specifically, additionality 
in the context of the model simulations refers to investment generated by NGEU, beyond what would have been achieved through existing resources. 
In general, support from substitute the RRF cannot substitute for recurring national budgetary expenditure (unless in duly justified cases) in line with 
Article 5(1) of the RRF Regulation. Still, it has been argued, as, for example, in the  external mid-term evaluation, that loans from the RRF could 
replace some general government spending. The hypothetical simulation assumption of lower additionality in the modelling therefore implies a more 
conservative stance.   

-  Repayment: The repayment assumptions on RRF loans and contributions to the EU budget (to finance grants) remain as in Pfeiffer et al. (2023a).  

- 

Inflation: NGEU envelopes are nominal. Thus, high inflation rates reduce the real value of the NGEU grants. To take this into account, the simulations 
include information on actual and expected GDP inflation rates (based on the ECFIN forecast). 

-  Time profiles: The simulations consider country-specific expected RRF disbursement or spending profiles, as estimated by DG ECFIN. The estimated 

time profiles are more backloaded than the stylised even profile applied in previous QUEST simulations.  

-  Productivity: A central assumption concerns the productivity of public capital for which the empirical literature has not reached a consensus. The 
QUEST calibration is informed by the median estimate of a meta-study308. For robustness, the analysis also considers a low-productivity scenario.  

-  REPowerEU: The simulations do not include any additional financing coming from REPowerEU. 

Figure A2.6: Stylised allocation key for NGEU Grants and Loans (% of 2019 GDP) 

308   Specifically, the output elasticity of public capital is set to 0.12, in line with the median estimate reported by Bom and Ligthart (2014). The meta-study suggests that infrastructure investment has higher 
productivity effects on average (0.17). The QUEST low-productivity scenario illustrates the sensitivity of these assumptions by considering an elasticity of 0.05. Bom, P., and Ligthart, J. E. (2014). What 
have we learned from three decades of research on the productivity of public capital? Journal of Economic Surveys, 28, 889-916. 

131 

 
 
Notes: This figure reports the assumed grant and loan allocation used in the simulations. Note that this is a stylised representation for modelling purposes only; actual sums financed from NGEU are bound 
to differ. Grant instruments include RRF grants and additional resources such as ReactEU and the Just Transition Fund.  
Source: European Commission 

Modelling NGEU in the QUEST model: While necessarily simplifying the full mechanics of NGEU, the modelling approach distinguishes grant and loan 
allocations for each Member State based on the currently available information. Also, it fully takes into account the increase in EU debt associated with 
NGEU. A separate EU budget accounts for the new EU-wide debt financed via long-term contributions of the Member States.  

Modelling  public  investment:  A  central  assumption  is  that  public  investment  is  productivity-enhancing,  a  notion  broadly  supported  by  the  empirical 
literature (see Bom and Ligthart 2014)309, despite identification challenges. Formally, the model captures productivity effects by including public capital in 
the private sector’s production process.  igher public capital then increases output for given inputs (private capital and labour). A simplified representation 
of the private-sector production function is given by:  

309   Bom, P. and Ligthart, J.E. (2014) What Have We Learned From Three Decades Of Research On The Productivity Of Public Capital?, in Journal of Economic Surveys, 28, pages 889-916. 

132 

 
 
 
𝑌𝑡 = 𝑁𝑡

𝛼𝐾𝑡

1−𝛼(𝐾𝑡

𝐺)𝛼𝐺, 

𝐺 denote output, private capital, labour, the labour share, and effective public capital, respectively. The output elasticity of public 
where 𝑌𝑡, 𝐾𝑡, 𝑁𝑡, 𝛼 and 𝐾𝑡
capital 𝛼𝐺 ≥ 0, drives the medium and long-run GDP effects in the simulations. The QUEST model calibration follows the empirical literature to calibrate 
this parameter. These studies, however, have found different degrees of productivity, and there is no consensus. Bom  and Ligthart (2014) find a mean 
output elasticity of public capital of 0.12. For robustness, the simulations also consider 𝛼𝐺 = 0.05 as a low-productivity scenario. 

Public investment often faces delays in both implementation and construction. For example, projects need to be contracted. New infrastructure projects 
take time before benefiting their users (e.g., building highways or bridges). These features have two main implications. Firstly, government investment is 
not immediately productive, reflecting time-to-build lags. Thus, in contrast to the standard model, government investment does not translate directly into 
productivity-enhancing  public  capital.  Instead,  with  the  time-to-build  delay,  the  positive  supply-side  effects  materialise  later,  reducing  the  short-run 
multiplier. Nonetheless, they remain persistent as public capital depreciates only slowly. 

Besides its supply-side effects, public investment directly enters GDP in the national-account expenditure items.  

Other model elements:  

• 

International linkages: QUEST features a rich trade structure linking individual economies. While adding complexity, this approach captures the 
transmission of NGEU in the highly integrated EU economy. The model distinguishes tradable and non-tradable goods and services, and explicitly 
features imported intermediate inputs. The latter capture cross-border value chains and have significant implications for spillovers. 

•  Household  heterogeneity  and  sticky  wages:  QUEST  distinguishes  (optimising)  Ricardian  and  liquidity-constrained  households  (rule-of-thumb 
consumers). The latter households do not participate in financial markets and consume their entire disposable income in every period. Together with 
imperfect  labour  and goods markets,  this feature implies a higher sensitivity  of consumption to  income, generating Keynesian effects  of fiscal 
stimulus, in line with empirical evidence. 

•  Real  frictions:  As  typically  assumed  in  larger  DSGE  models,  goods  production  in  our  setup  also  features  variable  capacity  utilisation,  capital-
adjustment costs, and labour-adjustment costs. In line with estimated model versions, these model features help to capture the economy’s dynamic 
behaviour. 

133 

 
Model calibration: Model parameters that characterise the model’s steady state are calibrated based on national accounts, fiscal data, and trade data. Steady-
state aggregates (like private and public consumption; investment; trade openness; and trade linkages) are calibrated on region-specific data. The steady-
state import share in demand for tradables, and the share of intermediates in tradable and non-tradable-sector production are both based on input-output 
tables from the WIOD database. The shares of bilateral imports are based on the IMF Direction of Trade Statistics (DOTS) for goods trade and on Eurostat, 
OECD  and  WTO  data  sources  for  services.  The  baseline  government-debt-to-GDP  ratios  reflect  the  average  ratios  observed  over  the  last  decade. 
Behavioural parameters that govern the dynamic adjustment to shocks are based on earlier estimated QUEST model versions. Parameters for the adjustment 
of prices and wages, which determine the sensitivity of prices and wages to demand and supply shocks, are informed by evidence of average price and 
wage adjustment frequencies. Online Appendix C in Pfeiffer et al. (2023a) reports further details on the calibration strategy and data sources. 

Model uncertainty and sensitivity analysis: Besides the low-productivity scenario presented above, the Online Appendix in Pfeiffer et al. (2023a) helps to 
assess the robustness of the results and understand how variations in key parameters can impact the outcomes, such as assumptions on fiscal and monetary 
policy, labour supply elasticity and speed of NGEU fund disbursement. 

Model robustness 

To assess the robustness, it is helpful to position the QUEST simulation results relative to other macroeconomic research on the potential impacts of NGEU. 
In general, while simulation results can quantify potential macroeconomic impacts, they depend on the modelling choices and features of the framework. 

•  The QUEST simulations do not account for the potentially significant benefits of reforms, which are fundamental to the RRF. Quantifying these 
benefits, especially in advance, is challenging. In related work, however, Pfeiffer, Varga, and in ‘t Veld (2023b) illustrate the potential long-run 
gains of economic reforms.310 

•  European Central Bank (‘ECB’) research (Bańkowski et al., 202 )311 estimates that, by 2026, NGEU could boost the euro area's GDP by as much 
as 1.5%, with more pronounced effects in the main recipient nations. For instance, in Italy and Spain, which are among the major beneficiaries, the 
ratio of public debt to GDP could decrease by over 10 percentage points by 2031.  

310   See  Pfeiffer,  P.,  Varga,  J,  and 

in  ‘t  Veld,  J.  (2023b)  Unleashing  Potential:  Model-Based  Reform  Benchmarking 

for  EU  Member  States,  available  at:  https://economy-

finance.ec.europa.eu/publications/unleashing-potential-model-based-reform-benchmarking-eu-member-states_en. 

311   Bańkowski, K., Bouabdallah,  ., Semeano, J. D., Dorrucci, E., Freier, M., Jacquinot, P., Modery, W., Rodríguez-Vives, M., Valenta, V., & Zorell, N. (2021), The economic impact of Next Generation 

EU: a euro area perspective, in Occasional Paper Series (No. 291). European Central Bank. 

134 

 
 
•  While both studies, ECB and QUEST analyses, find substantial growth effects in the EU, there are differences in assumptions and approaches. First, 
compared to the QUEST modelling, the ECB authors consider illustrative reforms (mark-up shocks) and include stylised risk premium reductions312. 
Second, compared to the benchmark scenario used in the Commission ‘s simulations, the ECB estimates are based on (more pessimistic) assumptions 
on additionality and productivity313. Finally, the country and programme coverage are more limited than in the QUEST simulation, which covers all 
27 EU Member States and other NGEU funds beyond the RRF. 

•  The external mid-term evaluation supporting study applies the NiGEM model to simulate the effects of NGEU, finding smaller multipliers than the 
QUEST simulations. Notably, the long-run government investment multipliers appear to be substantially below the estimates presented in Table 
A2.6. below314. The  authors  explain these results by more pessimistic productivity assumptions and the fact  that, for some  Member States, the 
NiGEM model applies a simplified model structure315. As a result, the simulated long-run EU GDP effects are considerably smaller in the order of 
0.3% of GDP. In other aspects, the approach is broadly in line with the QUEST simulations, emphasising, for example, the role of positive spillover 
effects. 

• 

It  is  important  to  acknowledge,  that  the  provided  model-based  simulation  strongly  hinge  on  the  concept  of  additionality.  The  authors  of  the 
supporting study argue that the additional investment stimulated by the RRF was limited due to the short period allocated for implementation and 
the overlap with projects fundable by Cohesion Policy instruments. If only 25% (Northern and Western Europe) and 60% (other countries) of non-
repayable support and loans were spent on additional investment, the GDP gains are reduced by a little over a quarter. 

•  The NiGEM simulations also include reforms, which, however, are illustrative since the assumed shock sizes (e.g., changes in  macroeconomic 

indicators) remain unrelated to concrete RRF reforms. 

312   The NGEU's effect on sovereign risk premia is inferred from the drop in bond spreads within three  weeks of the May 2020 Franco-German recovery fund announcement. This implies that without 
NGEU, the spread increase from March 2020 would have continued otherwise. Although factors like the ECB’s PEPP and SURE could account for the spread decline, it's wholly attributed to NGEU. 
Moreover, the assessment assumes enhanced financing conditions also for households and firms. 

313   Moreover, the ECB simulations assume 80% of spending is investment, and the remainder is non-productive spending (transfers, other expenditure). The assumed output elasticity for public investment 
is also below the median estimate reported by Bom and Ligthart (2014) and applied in the (high-productivity scenario of the) QUEST simulation. The simulation presented in DG ECFIN’s 2020 autumn 
forecast also considered a low-additionality scenario. See European Commission (2020). Macroeconomic effects of Next Generation EU, in European Economic Forecast: Autumn 2020, Special Issue 
3.2’. Institutional Paper  3 , pp.   -70. 

314   Other model-based estimates also suggest higher multipliers. See, Bozou, C., & Creel, J. (2023). Comparing different features of a fiscal stimulus in the euro area Sciences Po OFCE Working Paper No. 

05/2023. 

315   Essentially, for these countries, all government expenditures are categorised as “consumption”, and thus, the model does not include any benefits from higher public capital. 

135 

 
 
Table A2.6. shows that the cumulative multipliers are in the (lower) range of the estimates in the macroeconomic modelling literature, as reported by Ramey 
(2021, p. 239)316. The alternative (low productivity) scenario highlights the importance of high-quality investment projects to generate high fiscal multipliers. 

Table A2.6.: Long-run multipliers 

QUEST simulation 

Ramey (2021) 

Government consumption 

Government investment  (high productivity, 
undiscounted) 

Government  investment  (low  productivity, 
undiscounted) 

Government  investment  (low  productivity, 
discounted) 

- 

6.5 

3.1 

1.7 

0.9 

4.9 to 9.8 

2.9 to 5.4 

1.7 to 3.2 

Notes: This table compares the simulated QUEST long-run multipliers to those reported in Ramey (2021, New-Keynesian model). In the last row, the same discount factor as Ramey (4% p.a., ex-post) was 
applied. Multipliers correspond to the ratio of the integrals of the GDP gains and the NGEU funds. 
Source: European Commission 

Methodology to report on estimated expenditures under each pillar 

In line with Article 29(3) of the RRF Regulation, the Commission has developed a methodology to report on the contribution of the RRPs to each of the 
Facility’s six pillars.  

The indicative break-down of disbursements by policy pillar is calculated as follows: 

316   Ramey, V. A. (2021). The macroeconomic consequences of infrastructure investment. In E. L. Glaeser & J. M. Poterba (Eds.), Economic Analysis and Infrastructure Investment (pp. 219-268). University 

of Chicago Press, available at https://www.nber.org/system/files/chapters/c14366/c14366.pdf. 

136 

 
 
 
1.  Bearing in mind that RRF disbursements are linked to the satisfactory fulfilment of milestones and targets and not to the actual costs incurred, the 
unit value of milestones and targets is calculated by dividing the total allocation of a national plan by the number of milestones and targets contained 
in the plan. Therefore, each milestone and target have the same unit value, allowing to report on both investments and reforms, even if reforms have 
usually no or very low cost. 

2.  The Commission, in consultation with the Member States, assigns two policy pillars to each measure included in the recovery and resilience plans. 
Since each milestone and target is linked to a measure, milestones and targets are indirectly linked to the two policy pillars assigned to the measure 
they belong to. Hence, a disbursement based on the satisfactory fulfilment of 44 milestones and targets, would correspond to 88 assignments of 
policy pillars (see also example below).  

3.  The number of assignments under the same pillar is multiplied by the unit value of milestones and targets calculated in step 1. For instance, if there 
are 18 green transition pillar assignments out of 88 milestones and targets (see below), and the unit value of each milestone and target in the plan 
concerned is EUR 20.2 million, the contribution of the disbursement to the green transition pillar would be 18 x 20.2 = EUR 364 million.  

4.  The share of value of milestones and targets per pillar is calculated by dividing the contributions to each pillar (step 3) by the sum of contributions 
to the six pillars. For example, if the value of the milestones and targets linked to the green transition pillar is EUR 364 million, and the sum of the 
value of all milestones and targets under one instalment is EUR 1.781 billion, the share of the value of milestones and targets linked to the green 
transition pillar is 364 /1.781 = 20.45%. 

5.  The estimate of the contribution of a disbursement to each pillar corresponds to the share of the disbursement linked to the value of milestones and 
targets per pillar. For instance, if the share of the value for the green transition pillar is 20.45% and the disbursement corresponds to EUR 804.5 
million, the expenditure related to the green transition pillar is (804.5 million/100) x 20.45 = EUR 164.57 million. 

For example:  

Total allocation: EUR 3,461,398,824  

Total number of milestones and targets in the plan: 171 

Unit value of milestones and targets: total allocation/ total number of milestones and targets = EUR 20,242,098  

Payment request: EUR 804,597,701  

137 

 
Number of milestones and targets linked to the first payment: 44 

Figure A2.7.: Methodology 

Source: European Commission 

Assessment of the supporting study 

The work carried out by the external contractor delivered on the objectives and tasks set in the Terms of Reference and followed the work plan agreed with 
the ISSG.  

138 

 
 
Although the supporting study had to be performed within a short timeframe (March-November 2023), the consultants carried out all the expected tasks as 
planned: they delivered an extensive literature review, they performed the interviews as planned and carried out diverse surveys, they analysed the RRF 
implementation in Member States and conducted eight in-depth case studies, covering the six pillars defining the scope of the Facility (one case study per 
pillar), as well as two case studies on two important themes for the RRF implementation (the support of cross-border projects and a comparison between 
the RRF and cohesion). They also performed a macro-economic analysis to assess the impact of the RRF on EU GDP, using the NiGEM model. Only the 
survey targeted to National Parliaments did not bring the expected results, given the very low response rate, and was therefore not used for the supporting 
study. 

The supporting study Is overall of good quality. The results are triangulated with various sources of information to ensure the conclusions are robust. The 
consultants made their best efforts to identify the impact on the ground, searching for data available at national level to assess the impact of the reforms 
and  investments  implemented  on  the  ground.  The  supporting  study  is  neutral  and  well  balanced,  presenting  the  facts,  the  diverse  views  of  relevant 
stakeholders and identified both the positive and negative aspects of the Facility. 

Overall, the report is rich of information and well-written. Furthermore, the consultants provided translations of the executive summary into DE and FR. 

Data limitations 

Table A2.7: Methods applied and limitations – an overview 

Method 

Overview 

Literature 
review 

Databases 

The literature review is presented 
in Annex III of the supporting 
study, while its Annex IV of the 
supporting study lists the literature 
reviewed.  
There are two main databases that 
were developed for the purposes 
of the study: 
- 

Primary database, using 
Commission data on RRF 
monitoring 

Limitations 

Input into the 
evaluation 
All evaluation criteria  While the literature review contributed to answering the evaluation questions, most of the available 
literature  to  date  presents  the  expectations  for  the  RRF,  rather  than  offering  a  review  of  its 
implementation. This is natural considering the stage of implementation of the RRF, but diminished 
the usefulness of the available literature. 

Primary database – 
Effectiveness criterion. 
All evaluation criteria 
for the secondary 
database 

The primary database has proved very useful in identifying the status of disbursements, milestones 
and targets, and common indicators. A limitation of this data is that it does not go beyond available 
monitoring data. Another limitation is that considering the current status of implementation of the 
RRF, it is not possible to reach conclusions on the effectiveness along the six RRF pillars (as noted 
in  the  Effectiveness  section,  the  state  of  implementation  of  the  milestones  and  targets  per  pillar 
ranges from 8% to 13%). Furthermore, the common indicators themselves offer specific challenges: 
they cover very broad aspects of the RRP measures (making disentangling their specific origin and 

139 

 
Public 
consultation 

Surveys 

- 

Secondary  database,  which 
incorporates  interview  input 
and  data  on  results  gathered 
at  national  level.  In  view  of 
protecting  the  anonymity  of 
the  interviewees,  in  Annex 
V, only the data on results is 
provided. 

The public consultation was 
conducted from 16 March 2023 to 
8 June 2023. A total of 172 
responses were received 
Two 
surveys  were 
targeted 
launched  at  the  end  of  May  2023 
and closed on the 7th of July. The 
first survey addresses key national 
stakeholders 
the 
programmes’  implementation,  the 
the 
selection, 
projects’ 
and 
monitoring 
reporting 
and 
procedures.  The  second  survey 
targets  members  of  national 
parliaments 
in 
committees  linked  to  areas  of 
reform  identified  in  the  national 
Recovery and Resilience Plans. 

involved 

involved 

in 

All evaluation criteria 

Effectiveness, 
Efficiency, Coherence, 
EU added value (for 
the national 
stakeholder survey) 

Interviews 

interviews  were 

Targeted 
a 
cornerstone  of  our  stakeholder 
consultation  and  allowed  us  to 
gather  particularly  qualitative  and 

All evaluation criteria 

contribution to RRF objectives difficult); given the stage of RRP implementation, for some of them 
there have been limited reporting by Member State; and they do not have target values. 
Considering  these  limitations,  the  secondary  database  was  established,  trying  to go beyond  the 
available  data  and  cover  broader  results  of  RRF  reforms  and  investments  and  qualitative 
information.  However,  there  are  also  limitations  to  the  secondary  database  are:  1)  large 
heterogeneity of information retrieved across Member States, in part also due to the different status 
of  implementation  of  the  national  plans;  2)  particularly  for  investments,  it  still  presents  largely 
expectations  rather  than  actual  effects,  but  this  is  due  to  the  status  of  RRF  implementation;  3) 
heterogeneity of available information at national level on the implementation of RRF measures (for 
some Member States the availability of academic literature on the RRF related measures is very 
high, while in others much less).  
A major limitation of the public consultation is the relatively limited number of responses received 
and  the  large  share  received  from  one  Member  State:  Portugal.  In  this  context,  the  consultation 
results have been used with particular care, triangulating also with other consultation tools, and no 
findings were based solely on public consultation input. 
The survey with national RRF stakeholders was filled in by 40, out of 60 invited, which is a very 
good response rate. While the survey provided useful input across most evaluation criteria, some 
limitations emerged: 
- Since the survey had to cover a wide range of evaluation questions, it could not delve deeply into 
certain aspects that would have required more detailed ad hoc inquires, such as the collection of 
administrative costs. Thus, for administrative costs of Member States, additional information was 
requested through the RRF expert group (five Member States provided responses); 
- As most respondents were national coordination bodies, they could not provide the same level of 
detail  for  all  questions.  For  example,  gathering  details  on implementation  costs  was  challenging 
because implementation is often delegated to line ministries. 
- Due to the short evaluation timeframe, the survey and interview program ran concurrently, limiting 
the potential for synergies and a thorough assessment of information gaps 

Despite the large number of invitations sent (1,800) and the translation of  the questionnaire in all 
official  EU  languages  (except  Gaelic  and  Maltese)  the  survey  with  members  of  national 
parliaments  received  only  five  responses.  Thus,  its  results  were  not  incorporated  into  the 
evaluation. 
Overall,  the  response  rate  for  the  semi-structured  interviews  has  been  very  high.  The  inherent 
limitation of this methodology is linked to the specific knowledge of the interviewee. This limitation 
has been largely compensated by the large consultation carried out with different stakeholders with 
whom different aspects of the evaluation questions were investigated. 

140 

 
 
bodies, 

total,  156 

in-depth  information  on  the  RRF. 
In 
semi-structured 
interviews  (of  which  88  in  the 
context  of  case  studies)  were 
national 
with 
conducted 
coordination 
the 
Commission, the EP, the EFC and 
EPC chairs, the EU social partners, 
the  EESC,  the  CoR,  NGOs  and 
policy experts.  
Eight case studies have been 
conducted. Six focused on specific 
policy areas related to the RRF six 
pillars: (a) Energy efficiency 
buildings; (b) digitalisation of 
healthcare; (c) support to SMEs; 
(d) active labour market policies; 
(e) rule of law reforms; and (f) 
early childhood education and 
care. Two specific case studies 
have been added, one on cross-
border projects and one on the 
interaction between other EU 
Cohesion Policy and the RRF. 
The analysis of costs and benefits 
has been structured into the 
following steps: cost mapping; 
assessing costs; assessing benefits; 
concluding on the benefit/cost 
ratio.  

Case studies 

Analysis of 
costs and 
benefits 

Efficiency 

Macroeconomic 
model 

The macroeconomic analysis 
reported in the main body of the 
supporting study was carried out 
using the National Institute Global 

Effectiveness and 
Efficiency 

All evaluation criteria 

The  main  limitation  of  the  case  study  approach  is  related  to  the  different  levels  of  depth  of  the 
analysis related to the two main factors: 1) availability of data on results due to different stages in 
the  measures’  implementation  and  different  types  of  measures  (reforms  or  investments);  2) 
difficulties encountered especially in the consultation with stakeholders in different case studies. 
While not being a data limitation per se, it should also be acknowledged that the case studies findings 
cannot be considered as representative for all Member States or for the overall Facility. They provide 
a deep dive into some selected area, looking at selected Member States. 

The two major limitations are:  
i) the reliance on a survey of national stakeholders to collect cost data. While it was the best available 
option  in  this  context,  collecting  administrative  costs  typically  requires  multiple  rounds  of 
interactions with various entities involved in the governance and implementation of an investment 
program;  
ii) Quantifying and monetising the benefits has proven to be not feasible). This led to the decision 
to calculate the benefit-cost ratio of the RRF as the ratio between the absolute cumulative change 
in real GDP predicted by the macroeconomic model and the funding (both grants and loans). 
The  limitations  and  assumptions  of  the  models  are  presented  in  the  text  of  the  supporting  study 
where relevant, and include: i) GDP per capita data was only available up to 2022; ii) NiGEM model 

141 

 
Econometric Model (NiGEM). 
The SWD also draws on the 
QUEST model, developed and 
maintained by the Commission. 

limitations317; iii) the fact that the model does not take into account the impact of reforms under the 
RRF.  
The  limitations  of  the  QUEST  model  relate  to  model  specifications  and  assumptions  outlined  in 
Annex II just above this table.  n top of the models’ assumptions, the results are influenced by some 
important caveats: With focusing NGEU, the QUEST model’s estimates exceeds the effect of RRF 
investments on GDP, as the RRF only represents 90% of NGEU investment. At the same time, it 
provides a structural under-estimation of the RRFs GDP effects due to the missing effect of RRF 
reforms. 

Whilst such limitations have undoubtedly had a bearing on the exercise, they do not impact on the robustness or reliability of the overall mid-term evaluation 
conclusions which serve as a useful basis for reflections on the RRF. Overall, the conclusions reached on the achievements of the RRF at the mid-term 
point can be considered strong. The process has benefitted from the independence of the external evaluator and the expertise of informed stakeholders 
during the validation workshop. Finally, the skills and knowledge of the ISG have supported the quality assurance of the external report and the SWD mid-
term evaluation. 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION) 

Table A3.1: Evaluation Matrix and questions by criterion 

Evaluation questions 

Judgement criteria 

Indicators 

Main sources 

Evaluation tools 

  Overall RRF functioning  

s
s
e
n
e
v
i
t
c
e
f
f

E

EQ1: To what extent has the 
RRF been effective in providing 
financial support to Member 

Timely (i.e., no lags) analysis and 
disbursement of the requests for 

• 

Timelines of the payment 
requests (in line with the 
original planning) 

Primary database and stakeholder 
consultations 

Descriptive statistics of: 

• 
Speed of disbursement 
•  Value of disbursements 

317   Three Member States – Cyprus, Luxembourg and Malta – are not modelled separately in NiGEM, results for these countries could not be obtained. For a number of other countries, specifically Bulgaria, 
Croatia, Estonia, Latvia, Lithuania, Slovakia and Slovenia, all government spending is treated as ‘consumption’ and so does not add to the economy’s capital stock, which is the main way that government 
investment raises GDP in the long run. As a result, the multipliers for these countries calculated by NiGEM were much smaller than expected. Finally, even for those countries in NiGEM where public 
investment is modelled separately to consumption and does add to the nation’s capital stock, raising long-run GDP, NiGEM assumes constant returns to scale, perfect substitutability between private 
and public capital and no productivity spillovers from public capital to private capital. As a result, the multipliers on public investment calculated using NiGEM are at the low end of estimates for these 
spillovers in the literature. Dealing with these limitations would require constructing what would essentially be a new macroeconomic model. In a way, QUEST is already that model; so, NiGEM can 
be thought as providing an independent ‘sanity check’ for the QUEST results.  n the data side, assumptions made about interest payments, disbursements and the timing, extent and additionality of RRF 
spending that may turn out to be incorrect. 

142 

 
 
 
  
  
  
  
  
  
 
States (cf. pre-financing, speed 
of disbursements) 

pre-financing and instalments 
requests 

• 

Time lag between 
disbursement requests – 
approval or rejection – actual 
disbursement 

• 

Pre-financing value 

Opinion on the effectiveness of the 
provision of financial support 

EQ2: To what extent has the 
RRF been effective in enabling 
the implementation of reforms 
and investments respectively, as 
set out in the respective Council 
Implementing Decisions (CIDs)? 

EQ2.1: Given the current state of 
play of the Facility’s 
implementation, which outputs 
(milestones and targets) and 
results have already been 
achieved? 

EQ2.2: To what extent did the 
achievement of milestones and 
targets translate into the 
successful implementation of 
reforms and investments? 

EQ2.3: How effective has the 
RRF been in supporting reforms 
that address the CSRs (as the 
support for implementing 
reforms is a key feature/novelty 
of the instrument)? 

EQ3: Was the Commission’s 
communication (including 
information discussions 
preceding the formal submission 
of RRPs/payment requests, 
timing and availability of 
guidance) effective to support 
the timely implementation of the 
RRF? 

Summative question (answer to be provided on the basis of the sub-questions below) 

Fulfilment of milestones and 
targets  
Extent of progress on the common 
indicators 

Results of investments and reforms 
are aligned to the expectations. 

Degree of granularity of targets 
and clarity of milestones and 
capacity to trace investments and 
reforms implementation 

Alignment between reforms and 
CSRs  

Values of milestones and targets 
Common indicator values 

Primary database and Recovery 
and Resilience Scoreboard 

Descriptive statistics and literature review 
(reports on the RRF implementation) 

Identified results of investments 
Identified results of reforms 
Qualitative assessment of 
targets/milestones granularity and 
clarity vis-à-vis national decision-
making processes 

For the results of 
investments/reforms – secondary 
database, stakeholder 
consultations, and case studies 

•  Case Studies 
• 
Survey 
• 
Semi-structured interviews 

Qualitative interviews and 
comparative synoptic tables 
State of implementation of the 
CSRs 

Secondary database and 
stakeholder consultations 
Commission CSRs database[1] 

Semi-structured interviews 

• 
•  Descriptive statistics 

Timely and available information 
communication on RRF 
procedures (e.g., submission of 
RRPs, payment requests, reporting 
etc.)  

• 

Timeliness of issuing 
guidance documentation 

•  National authorities’ 

perception of Commission 
communication effectiveness 
and impact on the plans’ 
implementation 

Stakeholder consultation (in 
particular the survey with national 
coordination bodies) 
Review of guidance documents 

• 
• 
• 

Semi-structured interviews 
Survey 
Literature review (on guidance 
documents) 

143 

 
  
  
  
  
  
  
  
  
  
RRF objectives’ accomplishment 
EQ4: To what extent has the RRF been effective in: 

EQ4.1: cushioning the social and 
economic impact of the crisis, in 
particular on women 

Identified contribution to 
cushioning the social and 
economic impact of the crisis on 
women 

Primary database and Recovery 
and Resilience Scoreboard 

Stakeholder consultations 

•  Descriptive statistics 
•  Case studies  
• 
•  Descriptive statistics 
• 
Literature review 

Semi-structured interviews 

Common indicators, disaggregated 
by gender and the Scoreboard:  
• 

researchers working in 
supported research facilities;  
participants in education or 
training;  
people in employment or 
engaged in job searching 
activities;  
young people aged 15-29 
receiving support.  

• 

• 

• 

EQ4.2: supporting the economic 
recovery  

Identified contribution to positive 
economic recovery trends 

Qualitative and quantitative 
references related to the United 
Nations Sustainable Development 
Goal 5 on gender equality and the 
European Pillar of Social Rights. 

Macroeconomic indicators (i.e. 
GDP, employment, productivity, 
government debt) 

EQ4.3: enhancing social and 
territorial cohesion 

EQ4.4: increasing health, 
economic, social and 
institutional resilience 

EQ4.5: supporting the green 
transition 

• 

• 

• 

• 

Enactment of reforms and 
investments to address social 
and territorial cohesion 

•  Allocation of RRF funds 

between and within Member 
States 

Enactment of reforms and 
investments to support health, 
social and institutional 
resilience 
Progress and expected 
progress of the relevant 
common indicators 

Enactment of reforms and 
investments to support the 

•  Milestones and targets 
related to resilience 

•  Relevant common indicators: 
Number of users of new and 
upgraded public digital 
services, products and 
processes; Capacity of new 
or modernised health care 
facilities 

•  Milestones and targets 

related to the green transition 

144 

National Institute of Economic 
and Social Research’s Global 
Econometric Model – NiGEM 
QUEST model 

Primary database  
Stakeholder consultations 

Primary database and Recovery 
and Resilience Scoreboard 

Secondary database, incl. on 
stakeholder consultations 

•  Descriptive statistics 
•  Quantitative (macroeconomic) 

analysis of impacts – both by 
QUEST and through NiGeM 

•  Case study on modernisation of 
labour market institutions  

Semi-structured interviews 

•  Descriptive statistics  
• 
•  Case study on justice reform 
• 
Semi-structured interviews 
•  Descriptive statistics on the 
common indicators progress 

Primary database and Recovery 
and Resilience Scoreboard 

•  Green transition case study 
• 
• 

Surveys  
Semi-structured interviews 

 
  
  
  
  
  
  
EQ4.6: supporting the digital 
transition 

EQ4.7: fostering smart, 
sustainable and inclusive – 
economic growth and 
employment potential within the 
Union 

Secondary database, incl. on 
stakeholder consultations 

•  Desk research, incl. on the 

alignment to the DNSH principle 

•  Descriptive statistics on the 
common indicators progress 

Primary database and Recovery 
and Resilience Scoreboard 

Secondary database, incl. on 
stakeholder consultations 

Surveys; 
Semi-structured interviews 

•  Digital transition case study; 
• 
• 
•  Desk research  
•  Descriptive statistics on the 
common indicators progress 

Primary database and Recovery 
and Resilience Scoreboard 

Secondary database, incl. on 
stakeholder consultations and 
macroeconomic imbalance trends 

•  Case study on smart, sustainable 

and inclusive growth; 
• 
Surveys; 
• 
Semi-structured interviews 
•  Descriptive statistics on the 
common indicators progress 

green transition in the 
Member States.  
Progress on the relevant 
common indicators 

• 

•  Compliance with the DNSH 

principle is ensured by the 
existing procedures 

• 

• 

• 

• 

Enactment of reforms and 
investments to support digital 
transition in the Member 
States 
Progress on the relevant 
common indicators 

Enactment of reforms and 
investments to support 
inclusive economic growth 
and employment in the 
Member States 
Progress and expected 
progress of the relevant 
common indicators 

•  Green common indicators: 1) 
Savings in annual primary 
energy consumption; (2) 
Additional operational 
capacity installed for 
renewable energy; (3) 
Alternative fuels 
infrastructure 
(refuelling/recharging 
points) 
Information on procedures 
and application of the DNSH 
principle by beneficiaries 

• 

•  Milestones and targets 

related to the digital 
transition 

•  Digital  common  indicators: 
5) Additional dwellings with 
internet  access  provided  via 
very high-capacity networks; 
6)  Enterprises  supported  to 
develop  or  adopt  digital 
products, 
and 
application  processes;  7) 
Users  of  new  and  upgraded 
public 
services, 
digital 
products and processes 
•  Milestones and targets 

services 

related to fostering smart, 
sustainable and inclusive – 
economic growth and 
employment potential 

•  Relevant common indicators: 
8) Researchers working in 
supported research facilities; 
9) Enterprises supported (of 
which small – including 
micro, medium, large); 10) 
Number of participants in 
education or training; 11) 
Number of people in 

145 

 
  
  
  
  
EQ4.8: supporting policies for 
next generation 

EQ4.9: mitigating the long-term 
risks stemming from the 
COVID-19 crisis 

EQ.4.10: contributing to 
REPowerEU objectives 

• 

• 

Enactment of reforms and 
investments to support Early 
Childhood Education and 
Care, Education policies and 
Youth integration in the 
labour market 
Progress of the relevant 
common indicators 

•  Reduction in spreads of 

• 

• 

Member States 
positive effects on the 
Member States’ GDP 
Expected contribution of 
reforms and investments to 
replace Russian fossil fuels 
and providing clean, 
affordable and secure energy 
to households and businesses 
across Europe. 

employment or engaged in 
job searching activities 
•  Milestones and targets 

related to policies for the 
next generation 

•  Relevant common indicators: 
13) Classroom capacity of 
new or modernised childcare 
and education facilities and 
14) Number of young people 
aged 15-29 years receiving 
support 
•  MS spreads 
•  GDP effects 

•  Revised plans including 
REPowerEU chapters as 
approved by the cut-off date 

•  Number of measures in the 
REPowerEU chapters 
implemented (if any);  
•  REPowerEU objectives 
pursued in the respective 
chapters 

Primary database and Recovery 
and Resilience Scoreboard 

Secondary database, incl. on 
stakeholder consultations 

•  Case study on policies for the next 

generation 
• 
Surveys 
• 
Semi-structured interviews 
•  Descriptive statistics on the 
common indicators progress 

NiGEM, QUEST model 

Literature review 

• 
•  Quantitative analysis of impacts 
(macroeconomic modelling) 

Desk research of REPowerEU 
chapters 

•  Desk research 
• 

Semi-structured interviews 

Stakeholder consultations 

RRF implementation obstacles 
and unexpected effects 

EQ5.1: To what extent did 
external factors have an impact 
on the RRF roll-out? How this 
may have had an impact on the 
Facility’s effectiveness in 
reaching its objectives? 

Delays in or partial fulfilment of 
Milestones and Targets due to 
external factors (cf. war in 
Ukraine, exceptionally high 
inflation, supply shortages, labour 
shortages, energy crisis, other) 

EQ5.2: To what extent did the 
absorption capacity of Member 
States affect the RRF 
effectiveness? 

Extent to which absorption 
capacity represents a factor in the 
RRF progress 

Indicators related to external 
factors, e.g. inflation, energy prices 

Primary database – data on 
disbursements 
Contextual data on external 
factors, e.g. inflation, energy 
prices, labour shortages etc. 

Semi-structured interviews 
Surveys 

• 
• 
•  Descriptive statistics 
• 
Literature review 

Evidence of problems related to 
absorption capacity 

Stakeholder consultations 

•  Desk research 
• 

Semi-structured interviews 

146 

 
  
  
  
  
  
  
  
  
  
EQ5.3: Have any positive/or 
negative unexpected effects been 
identified? 

RRF and EU Funding 
Instruments 
EQ6: How does the effectiveness 
of the RRF compare with that of 
other EU programme and 
instruments, notably cohesion 
funds?  

Exploratory question, i.e. no criteria / indicators 

•  Benchmarking RRF degree of 
achievement of targets and 
milestones with Cohesion 
Policy financing 

RRF public visibility and 
contribution to strengthen the 
Union 

• 
Perception (positive/negative) 
•  Communication strategy and 
funding visibility and 
acknowledgement 

• 

Types and number of RRF 
‘common indicators’ aligned 
with the ones of other 
programmes and funds 
(Cohesion Policy funds in 
particular) 
Stakeholder perception on 
the RRF effectiveness in 
comparison with the 
Cohesion Policy financing 
•  Awareness of the RRF by 

• 

the general public 
•  Outreach statistics 
•  Media coverage 

Primary database – data on the 
progress of milestones / targets / 
common indicators 

Data on other programmes (e.g. 
Cohesion Policy) 

Stakeholder consultations 

• 
• 

Eurobarometer  
Public consultation  

•  Case study on other instruments 
• 
Semi-structured interviews 
• 
Survey 
•  Case study 
•  Descriptive statistics 

•  Analysis of the Eurobarometer 

• 

survey results 
Public consultation results of 
citizens 

EQ7: How visible has the 
Recovery and Resilience Facility 
been to the public? How was the 
instrument perceived by the 
public, by Member States and by 
beneficiaries? 

Overarching question 
EQ8: What have been so far the 
most effective aspects of the RRF 
(cf.  speed  of  disbursements, 
long-
implementation 
standing/awaited/difficult 
reforms?) What has been the least 
effective? 

of 

•  Answers to the previous 

questions 

No specific indicators 

Response to the above EQs 

Qualitative assessment based on the 
answers to the previous questions 

E
I
C
I
F
F
E

Y
C
N

EQ9: How do the cost (inputs) of 
the Facility compare with the 
RRF outputs, results and impact? 

• 
• 

(Positive) benefit-cost ratio 
(Positive) general assessment 
on the proportionality of costs 
/ achievements 

•  Administrative costs – FTEs 
and total costs in EUR 
Stakeholder opinion on the 
proportionality of the costs 
and achievements 

• 

Information/reports from Member 
States on procedures and costs 

•  Desk research 
• 
• 
•  Descriptive statistics 

Semi-structured interviews 
Survey 

147 

 
  
  
  
  
  
  
 
  
EQ9.1: To what extent has the 
RRF – as a new instrument – 
created significant “entry-costs” 
for both national administrations 
and EU institutions (to become 
familiar with the functioning of 
the RRF)? 

EQ9.2: To what extent, did these 
“entry costs” evolve over time 
with the implementation of the 
instrument? How did the costs 
for the preparation of the Plans 
compare with those for the 
implementation of the plans? 

EQ10: To what extent has the 
RRF – as a new instrument – 
created significant “entry-costs” 
for both national administrations 
and EU institutions (to become 
familiar with the functioning of 
the RRF)? 

EQ11: How do the costs/burden 
of the RRF compliance compare 
with those of other instruments, 
notably cohesion funds, also 
taking into account the costs of 
audits and controls, as well as of 
data collection? 

EQ12: Can any unnecessary 
administrative burden and 
complexity be identified? To 
what extent is there scope for 
simplification? 

EQ13: To what extent have there 
been efficiency gains from 
pursuing reforms and 

(Positive) stakeholder opinion on 
the proportionality of costs 

•  New administrative 
procedures created 

Information/reports from Member 
States on procedures and costs 

•  New units/organisms created 

(e.g., audit, control, 
monitoring/reporting, 
coordination) 

Stakeholder consultations 

•  Desk research 
• 
• 

Semi-structured interviews 
Survey  

Exploratory question, i.e., no indicators / judgement criteria 

Information/reports from Member 
States on procedures and costs 

•  Desk research 
• 
• 

Semi-structured interviews 
Survey  

Level of proportionality of actual 
and perceived administrative costs 
of RRF as compared to cohesion 
funds in all the phase of the 
programming cycle (design, 
negotiation, information, 
implementation, funds 
disbursement, monitoring, 
reporting, audit and control) 

Identified potential for 
simplification 

Shared perception of efficiency 
gains 

Exploratory question, i.e., no 
indicators / judgement criteria 

Available reports/information on 
administrative costs / burden 

•  Desk research 
• 
• 

Semi-structured interviews 
Survey 

Stakeholder consultations 

List of areas with unnecessary 
burden, administrative complexity 
and for potential simplification 

Stakeholder consultations 

•  Desk research 
• 
• 

Semi-structured interviews 
Survey 

Stakeholder 
the 
efficiency  gains  resulting  from  the 

opinion 

of 

Stakeholder consultations 

•  Desk research 
• 
• 

Semi-structured interviews 
Survey 

148 

 
  
  
  
  
  
investments together under one 
instrument? 

EQ14: To what extent was the 
RRF coherent with the Technical 
Support Instrument? 

EQ15: To what extent has the 
RRF been integrated into the 
broader country-specific 
surveillance under the European 
Semester? To what extent have 
National Reform Programmes 
been used as a reporting tool for 
the RRF? 

EQ  : To what extent have EU’s 
priorities guided the reforms and 
investments put forward by 
Member States in their recovery 
and resilience plans?  

E
C
N
E
R
E
H
O
C

EQ17: To what extent have 
complementarity effects and 
synergies between the RRF with 
other EU programmes and 
instruments (such as Cohesion 
Policy funds) been identified and 
exploited? 

coordination  of  different  policy 
areas 

Objectives, achievements, and 
timing of broad Union policies 
(e.g., in the green and digital 
sector) 

Objectives, achievements, and their 
timing of the Technical Support 
Instrument 
Share of RRF-linked projects in the 
TSI portfolio 

RRF regulation (and related acts) 

TSI-related documents (e.g., 
Decisions, portfolio) 

•  Desk research 
• 
Semi-structured interviews 
•  Descriptive statistics on the TSI 

portfolio 

Actual inclusion of the RRPs 
reporting in the Semester  

RRF reporting within the 
European Semester (biannual) 

•  Desk research 
• 

Semi-structured interviews 

Level of coherence in terms of 
objectives and implementation 
with broad Union policies (e.g., in 
the green and digital sector) and 
the Technical Support Instrument 
Complementarity of specific 
activities 

Level of integration of the RRF in 
the Semester cycle 2021-2022 and 
2022-2023 via the National 
Reform Programme 

The objectives defined in the EU 
Regulation as well as in the CSRs 
and the other EU initiatives (e.g., 
Child Guarantee, Youth 
Guarantee, Social Pillar, EU Green 
Deal etc) mentioned in the 
Regulation did guide the drafting 
of the RRF plans 

Mechanisms put in place to exploit 
synergies and complementarities 
and avoid overlapping and 
displacement effects 

•  National and EU authorities’ 
perception of the guidance of 
EU objectives in the drafting 
phase of the RRF 
•  Alignment between EU 
priorities defined in the 
CSRs but also in other EU 
initiatives and RRF reforms 
and investments 
•  Guidelines and formal 

indications about how to 
exploit synergies. 
•  Mechanisms reported by 

stakeholders and programme 
managers on how to exploit 
synergies and their effects 

Key EU policy documents 
describing the EU priorities on 
twin transition, resilience, COVID 
response. 

•  Desk Research 
• 
•  Case studies 

Semi-structured interviews 

Description of existing 
mechanisms 

Stakeholder consultation 

•  Case study on other EU funds 
•  Desk Research 
• 
• 

Semi-structured interviews 
Survey 

EQ18: To what extent were 
RRF/RRPs 

Mechanisms put in place to ensure 
coherence with Member States’ 

•  Guidelines and formal 

indications about how to 

Description of other existing 
Member States’ instruments 

•  Desk Research 
• 

Semi-structured interviews 

149 

 
 
  
  
  
  
  
coherent/complementary with 
relevant Member States’ 
instruments aiming to support 
the economic recovery after the 
COVID crisis? 

instruments related to the COVID 
crisis 

aiming at support the economic 
recovery after the COVID crisis 
and mechanism to ensure 
consistency and complementarity 

• 
• 

Survey 
IMF database  

exploit synergies with other 
Member States’ instruments 
to cope with the COVID 
crisis; mechanisms reported 
by stakeholders and 
programme managers on 
how to exploit synergies and 
their effects;  

•  Quantitative data on crisis 

response measures 
•  Degree of alignment with 
Member States’ fiscal 
measures 

•  Degree of complementarity 
between RRPs and the 
existing national post-
pandemic recovery strategies 

EQ19: To what extent have 
reforms and investments in the 
plans been complementary and 
mutually reinforcing? 

Alignment between reforms and 
investments vis-à-vis country-
specific needs as identified in the 
Country Reports 

- 

Case studies 

•  Case studies 
•  Desk research 
• 

Semi-structured interviews 

Overarching question: EQ20: What has the RRF provided over and above what Member States actions and funding could have achieved?  
In particular: 

E
U
L
A
V
D
E
D
D
A
U
E

EQ20.1: Have substitution 
effects with national 
policies/programs and/or with 
other EU funded programmes 
been identified and if so, to 
which extent? 

EQ20.2: To what extent have the 
EU’s advantageous borrowing 
conditions and the impact that 
the RRF had on reducing spreads 
of EU Member States at its 
creation, contributed to the 
benefits of the RRF? 

Evidence / extent of substitution 
effects with national policies / 
programmes 

•  Data / information of 

Stakeholder consultation 

transferring investments 
from other national / EU 
programmes to the RRPs 

Semi-structured interviews  

• 
• 

Evidence / extent of impact on 
spreads 

•  Actual spreads vs under 

Eurostat/ECB statistics 

•  Macroeconomic modelling (QUEST 

counterfactual 

•  Borrowing rates / conditions 
(maturities, yield on govt 
bonds etc.) 

and NiGeM) 

•  Desk research 

150 

 
 
 
 
  
  
  
EQ20.3: To what extent did the 
Facility contribute to the 
implementation and further 
development of multi-country 
projects? 

Evidence of implementation / 
development of multi-country 
projects 

•  Numbers and types of multi-

country projects 

•  Numbers and types of multi-
country projects financed by 
EU funds (e.g., Interreg) 

Primary database – data on the 
multi-country projects  

Databases on other multi-country 
projects 

Semi-structured interviews 

•  Desk Research 
• 
•  Descriptive statistics 
•  Case study on cross-border projects  

EQ20.4: To what extent did the 
RRF contribute to maintaining 
the level-playing field and 
strengthening the Single Market? 

- 

Crisis response measures by 
individual Member States would 
have been more disruptive/would 
have caused divergence in the 
single market in the absence of the 
RRF 

EQ21: To what extent did the 
simultaneous implementation of 
reforms and investments across 
Member States create EU added 
value? 

RRF plans used to plan reforms 
together with investments that 
would otherwise not be 
implemented due to financial, 
technical or political constraints 

EQ22: To what extent, could 
similar results/impact be 
achieved with a different 
instrument at Union level (e.g., 
budget support) or by Member 
States? 

Identification or lack of evidence 
that RRF objectives could have 
been achieved via other EU level 
instruments or Member States 
actions 

•  National policy makers 

acknowledge the EU added 
value of the RRF instrument 
to implement together 
reforms and investments 
overcoming existing 
obstacles 

• 

•  Uptake of longstanding 
CSRs in reforms 
Existing EU and Member 
States’ instruments/funds 
dedicated to achieving 
similar objectives to the RRF 

Case studies 

•  Desk research 
•  Case studies 

Stakeholder consultation 

Semi-structured interviews  

• 
•  Case studies 

Primary database – data on the 
progress of milestones / targets / 
common indicators 

Stakeholder consultation 

• 
Semi-structured interviews  
• 
Survey 
•  Case studies 
• 

Secondary database with RRP 
results 

C
N
A
V
E
L
E
R

E

Overarching question: EQ23: To what extent does the RRF continue to be relevant in view of its objectives and how well do these objectives correspond with current needs within the EU? 

EQ23.1: To what extent did the 
initial allocation key remain 
relevant over the period?  

Allocation key reflects the 
evolving needs 

•  Allocations data 
• 

Indicators used to calculate 
the allocation key (e.g., 
GDP, employment) 

Primary database – data on 
allocations (current and original) 

•  Descriptive statistics 

151 

 
  
  
  
  
  
  
  
  
  
  
 
  
  
EQ23.2: To what extent have the 
initial RRPs remained 
relevant/feasible to implement 
until 2026 (i.e., scope of changes 
made to the RRPs till the cut-off 
date)? 

EQ24: To what extent is the 
instrument sufficiently 
flexible/agile to adjust to 
changing circumstances (cf. 
REPowerEU)? 

EQ25: What was the rationale 
behind Member States’ decisions 
to apply – or not apply – for 
loans under the RRF? 

RRPs remain relevant and feasible 
until the cut-off date 

Timely changes in the instrument 
to changing circumstances 
Existing mechanisms for changes 
in the instrument 

Use of the loan compartment is in 
line with what could be expected 
based on market developments, 
level of debt burden of individual 
Member States and size of 
allocations 

•  Milestones and targets 
compared to the 
implementation status; 
•  Qualitative judgement on 

forward looking (until 2026) 
part. 

• 

Identification of changing 
circumstances 

•  Qualitative judgement based 
on REPowerEU experience 

Primary database – data on the 
progress of milestones / targets / 
common indicators 

Assessment of effectiveness (and 
the expectations for the future) 

Analysis on changing 
circumstances and corresponding 
changes in the instrument 

•  Uptake of loans  
•  Rationales for using/not 
using loan compartment 

 verview of Member States’ loan 
requests[2] 

• 

Semi-structured interviews  

•  Desk research including (Review of 

REPowerEU chapters) 
Semi-structured interviews 

• 

•  Descriptive statistics 
•  Analysis on borrowing conditions 

(interest), indebtedness (debt/GDP) 
and loan uptake 
Semi-structured interviews  

• 

[1] The full database can be found at: https://ec.europa.eu/economy_finance/country-specific-recommendations-database/  
[2] https://commission.europa.eu/system/files/2023-09/01092023-Final-overview-of-MS-loan-requests-under-the-RRF_en.pdf  

Effectiveness 

EQ1: To what extent has the RRF been effective in providing financial support to Member States (pre-financing, speed of disbursements) 

Overall, the RRF has been effective in disbursing quickly post-crisis, notably thanks to pre-financing. Close to EUR 225 billion have been disbursed by 1 
February 2024, including EUR 157.2 billion disbursed upon the submission of payment requests and satisfactory fulfilment of milestones and targets, EUR 
56.7 billion in the form of RRF pre-financing, and EUR 10.4 billion in the form of REPowerEU pre-financing. EUR 144.0 billion of the total amount 
concerns non-repayable support and EUR 80.2 billion concerns loans. The planned and the disbursed financing in the first two years of operation of the 
RRF (2021-2022) are almost aligned.  

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The speed of disbursement is considered as one of the most effective features of the RRF318, also in comparison with disbursements made under Structural 
Funds319. The validity of comparing disbursement speed under Structural Funds with that under the RRF is however limited. This is because of, first, the 
larger amount of pre-financing over the total allocation under the RRF to date, second, the different disbursement mechanisms and, third, given that a larger 
share of reforms compared to investments has been implemented during the first years of the RRF implementation, which is therefore not comparable to 
cohesion funding320. However, overall, the RRF features, with substantial pre-financing and payments also linked to preparatory and intermediate steps of 
measures  implemented  on  the  ground,  have  enabled  quicker  disbursement  to  Member  States  than  instruments  where  payments  have  been  linked  to 
expenditure already incurred, including Structural Funds, and thus have been effective in creating fiscal space in Member States in the aftermath of the 
COVID-19 crisis.  

The speed of disbursement in the first two years of operation of the RRF has followed the indicative yearly timetable for disbursements stemming from the 
operational arrangements321. Approximately 27% of the RRF budget was paid out via pre-financing and regular payments in the period 2021-2022, which 
is almost aligned with what was foreseen at the time of adoption of the plans (28% of budget was planned for the same period)322. Similarly, Member States 
have largely adhered to the planning of the first payments in 2021 and 2022, requesting their payments at the time initially foreseen, reinforcing close 
alignment between planned and disbursed financing in the first two years of the RRF.  

The revisions of the RRPs and the addition of REPowerEU chapters, in response to the war in Ukraine, have impacted the disbursement schedule of RRF 
funds  in  2023,  creating  delays  between  actual  disbursements  and  initially  planned  disbursements  for  2023.  The  first  half  of  the  year  2023  has  seen  a 
slowdown in the submission of payment requests, with Member States focusing their efforts on the revision of plans and the addition of REPowerEU 
chapters. As a result, many Member States with a payment request indicatively planned for the first part of 2023 have pushed back the indicative timing by 
one to three quarters. As detailed in Section 3, the revisions of the RRPs (not only to factor in the updated maximum contribution, but also the impact of 

318   See page 268 of the supporting study. 
319   Zorell, N., and Tordoi, S. (2021)  Towards an effective implementation of the EU’s recovery package, ECB Economic Bulletin, Issue 2/2021 available at:  https://www.ecb.europa.eu/pub/economic-

bulletin/focus/2021/html/ecb.ebbox202102_07~7050ed41dd.en.html.  

320   See case study on the functioning of the RRF and other EU funds included in the supporting study. 
321   Evidence in this paragraph is sourced from pages 48 to 54 of the supporting study. 
322   According to the supporting study, see page 52. 

153 

 
 
inflation and supply chain disruptions) and the addition of REPowerEU chapters (as a  response to the war in Ukraine and energy crisis) are the direct 
consequences of external factors, which have affected the implementation of the Facility.  

As the revisions of the RRPs advanced, the submission of payment requests significantly picked up pace in the second half of 2023. Between May and 
December 2023, 26 payment requests were submitted and EUR 60.9 billion disbursed following the satisfactory fulfilment of milestones and targets. With 
most revised RRPs having been adopted, this catching-up effect is expected to continue as Member States have continued to implement the measures of 
their RRP. For example,  8 payment requests have been submitted very swiftly after the plans’ revisions and were being assessed by the Commission in 
January 2024. It is therefore a challenging, but still an achievable task to catch up on the delays experienced in the first half of 2023 in the time available 
until the end-2026 deadline.  

Within the overall progress in the disbursement of RRF funds explained above, the situation varies across Member States. Notably, to date, three Member 
States have not yet submitted a payment request (Hungary, the Netherlands and Sweden). No pre-financing requests were received in 2021 from any of 
these three Member States, as a result of the late adoption of these Member States’ CIDs in 2022, after the legal deadline for pre-financing of 31 December 
2021. Hungary has however received REPowerEU pre-financing in December 2023. In contrast, eight Member States have already submitted three or more 
payment requests. In line with the performance-based nature of the RRF, payments can only be made where concrete progress towards the achievement of 
reforms and investments, and thereby towards the RRF’s specific objective, has been made. 

EQ2: To what extent has the RRF been effective in enabling the implementation of reforms and investments respectively, as set out in the respective 
Council Implementing Decisions (CIDs): 

EQ2.1: Given the current state of play of the Facility’s implementation, which outputs (milestones and targets) and results have already been 
achieved? 

As of 1 February 2024, 18% of all planned milestones and targets have been assessed by the Commission as fulfilled (or 1,153 out of 6,266). An additional 
20% of all planned milestones and targets (or 1,238 out of 6,266) have been reported by Member States as completed, which, when taken together, indicates 
that 38% of all planned milestones and targets (or 2,391) are either assessed by the Commission as fulfilled or reported by Member States as completed. 
Despite this progress and the fact that the speed of disbursement in the first two year of operation of the RRF has followed the indicative timeline, the 
revisions of the RRPs and the addition of REPowerEU chapters have impacted the disbursement schedule of RRF funds in 2023, creating delays between 

154 

 
actual disbursements and initially planned disbursements. The first half of the year 2023 has seen a slowdown in the submission of payment requests, with 
Member States focusing their efforts on the revision of plans and the addition of REPowerEU chapters. As a result, many Member States with a payment 
request indicatively planned for the first part of 2023 have pushed back the indicative timing by one to three quarters. As the revisions of the RRPs advanced, 
the submission of payment requests significantly picked up pace in the second half of 2023. Between May and December 2023, 26 payment requests were 
submitted and EUR 60.9 billion disbursed. With most revised RRPs having been adopted, this catching-up effect is expected to continue as Member States 
have continued to implement the measures of their RRP. For example, 18 payment requests have been submitted very swiftly after the plans’ revisions and 
were being assessed by the Commission by 1 February 2024. It is therefore a challenging, but still an achievable task to catch up on the delays experienced 
in the first half of 2023 in the time available until the end-2026 deadline. 

The fulfilled milestones and targets cover all six pillars of the RRF. The pillars of smart, sustainable and inclusive growth (approximately 21%) and health, 
and economic, social and institutional resilience have the highest percentages of fulfilled milestones and targets (20%) out of the planned milestones and 
targets linked to these pillars, followed then by the pillar of green transition and of policies for the next generation (both at 17%). The digital pillar has the 
lowest percentage fulfilled out of all milestones and targets linked to the pillar (15%). 

An important caveat to note is that the number of “fulfilled” milestones and targets only consider those covered in payment requests submitted to and 
assessed by the Commission, not the progress made by Member States in implementing and completing milestones and targets. As it becomes clear in the 
bi-annual reporting from Member States, the implementation of milestones and targets is progressing while some payment requests are being delayed: by 
1 February 2024, 1,238 additional milestones and targets are self-reported by Member States as completed, even though they have not yet been submitted 
to  the  Commission  as  part  of  a  payment  request.  This  represents  an  additional  20%  of  planned  milestones  and  targets  reported  by  Member  States  as 
completed but not yet assessed by the Commission. 

The RRF has progressed along  all fourteen common  indicators. Noteworthy  achievements include:  28.2  million  MWh/year savings in  annual  primary 
energy  consumption,  5.6  million  additional  dwellings  with  internet  access,  over  500,000  enterprises  supported,  8.7  million  supported  participants  in 
education or training, 5.8 million young people (aged 15-29) receiving support. For some common indicators (e.g. additional dwellings with internet access, 
population benefitting from protection measures against natural disasters, and capacity of new or modernised health care facilities) only 7-9 Member States 
have reported achievements so far. It has to be acknowledged that investments in infrastructure usually require time until they become operational and can 
be reported.  

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EQ2.2: To what extent did the achievement of milestones and targets translate into the successful implementation of reforms and investments? 

Even though milestones and targets largely measure input and output indicators at this intermediate stage, their implementation has in some cases already 
translated into results linked to the RRPs measures. The RRF has in particular triggered the implementation of major reforms across a wide range of policy 
areas:  labour  market  (Spain),  social  protection  and  pensions  (Croatia,  Spain),  civil  and  criminal  justice  (Italy,  Spain,  Croatia)  public  administration, 
including digitalisation (Italy, Slovakia, Germany), spending review and public finance governance (Belgium, France), anti-money laundering framework 
(Ireland, Sweden, Luxembourg), licensing simplification reforms to boost the investments in renewables (Greece, Portugal, Spain), roll-out of renewable 
energy and sustainable transport (Croatia, Romania), introduction of 5G (Belgium), structural reform of the education system (Spain, Croatia) as well as 
research and innovation (Spain).  

By contrast, only a few investments are completed and have already produced tangible results. This is to be expected, given the early stage of this evaluation. 
The implemented investments are still in the early stages, with milestones capturing first steps in the implementation: investments included in the RRPs 
are spread over the RRF timeline, but most are planned to be completed in 2025/2026. 

EQ2.3: How effective has the RRF been in supporting reforms that address the CSRs (as the support for implementing reforms is a key 
feature/novelty of the instrument)? 

The  reforms  indicated  by  Member  States  address  all  or  a  significant  subset  of  challenges  identified  in  the  European  Semester’s  Country-Specific 
Recommendations. Overall, there is unanimous agreement between Member States and the various EU institutions, including the European Parliament323 
and the ECA324, that the RRF has been effective in supporting CSR-related reforms325. The literature326 confirms the views of the European Parliament and 
of the ECA in recognising that the RRF contributed effectively to the support of reforms that otherwise would not have been implemented. The strength of 

323   See European Parliament resolution of 10 May 2023 with observations forming an integral part of the decisions on discharge in respect of the implementation of the general budget of the European 
Union for the financial year 2021, Section III – Commission and executive agencies (2022/2081(DEC)), available at: https://www.europarl.europa.eu/doceo/document/TA-9-2023-0137_EN.html.  
324   European  Court  of  Auditors  (2022)  Special  Report:  The  Commission’s  assessment  of  national  recovery  and  resilience  plans:  Overall  appropriate  but  implementation  risks  remain,  available  at: 

https://www.eca.europa.eu/Lists/ECADocuments/SR22_21/SR_NRRPs_EN.pdf.  

325   See pages 251 to 252 of the supporting study. 
326   See pages 251 to 252 of the supporting study. 

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the link between CSRs implementation and financial support is particularly important for Member States that receive a larger size of the financial support: 
those that receive a proportionally bigger financial envelope are more likely to commit to and implement structural reforms. 

The RRF has significantly accelerated policy action to address the CSRs, which, in the past, was considered weak327. The European Court of Auditors328 
found that, over the 2011-2017 period, only 1.6 % of CSRs were deemed to have been ‘fully implemented’ within one year after issuance, and that only 
26 % of the CSRs have been implemented over the full 2011-2018 period. In the two years preceding the RRF, the share of 2016-2017 CSRs reaching at 
least ‘some progress’ increased by only six percentage points from  3% in 20 8 to  9% in 2020. In comparison, the share of CSRs reaching at least ‘some 
progress’ increased by    percentage points from  2% in 202  before the RRF to almost 69% in 2023, after two years of RRF implementation. Member 
States have made most progress on access to finance and financial services, followed by labour market functioning, anti-money laundering and business 
environment. At the same time, progress has been less visible in the areas of the single market, competition and State aid, housing, long-term care and 
pension systems. Progress in the implementation of the recommendations adopted in 2022 has also been substantial. Member States have made at least 
‘some progress’ in almost  2% of the recommendations addressed to them in July 2022. 

The financial incentives provided by the RRF’s performance-based approach reinforce the implementation of the CSRs329. The fact that financial support 
is conditional upon the implementation of reforms is recognised by interviewees, stakeholders and external evaluators as the most relevant factor explaining 
the RRF's success in introducing long-awaited structural reforms that address the Semester’s CSRs. The strength of the linkage between implementation of 
CSR-related reforms and financial support is particularly important for Member States that receive a larger size of the financial support: those that receive 
a proportionally bigger financial envelope are more likely to commit to and implement structural reforms.  Finally, the RRF serves as an  incentive for 
Member States to internally steer the political debate and overcome resistance against long-awaited reforms. When the national governments’ ownership 
of their RRPs is high, the RRF has been presented as an “external steer” that incentivises Member States to abide by the measures indicated in their RRPs330. 

327   See pages 251 to 252 of the supporting study. 
328   Special report 16/2020 of the European Court of Auditors. 
329   Evidence in this paragraph is sourced from the supporting study, see pages 74 to 76. 
330   See pages 74 to 76 of the supporting study. 

157 

 
 
EQ3: Was the Commission’s communication (including information discussions preceding the formal submission of RRPs/payment requests, timing 
and availability of guidance) effective to support the timely implementation of the RRF? 

The Commission's communication in the drafting phase of the RRPs was considered timely and clear by the majority of Member States. Still, two aspects 
that could be improved have been indicated by Member States. The first regards the DNSH guidance, which arrived, according to stakeholders331,–– late in 
the drafting phase of the RRPs, thus creating some additional burden for administrations. The second regards the perceived low interaction among Member 
States, especially on cross-border projects, which – according to Member States themselves – could have been well coordinated by the Commission. 

Some concerns have been raised about the Commission’s communication in the implementation of the RRPs. In particular, Member States mentioned some 
unclarity with respect to the role of control and audits and the lack of sufficient flexibility in the interpretation of milestones and targets. With respect to 
the  latter,  Member  States  raised  concerns  with  respect  to  the  assessment  of  milestones  and  targets  and  the  payment  suspension  methodology.  The 
Commission Communication of February 2023 has been broadly welcomed as a positive step to clarify the assessment criteria for the payment requests or 
(partial)  suspension  and  the  milestones  and  targets’  satisfactory  fulfilment.  The  framework  is  considered  to  be  overall  satisfactory  by  all  national 
coordination bodies when it comes to investments, while some discretion and unclarity are still reported by Member States regarding reforms. 

EQ4: To what extent has the RRF been effective in: 

EQ4.1: cushioning the social and economic impact of the crisis, in particular on women 

Member States are progressing with the implementation of measures with a focus on gender equality and equal opportunities for all. The 27 plans adopted 
contain  134  (sub-)measures  with  a  focus  on  gender  equality,  and  many  reforms  and  investments  that  are  explicitly  aimed  at  contributing  to  equal 
opportunities in general332. Of the 256 milestones and targets with a focus on gender equality in the 27 RRPs, 83 are already reported as completed or 
assessed as fulfilled by 1 February 2024, representing a 32% progress rate (13% positively assessed). 

331   See page 77 of the supporting study. 
332   For 

information, 

further 

see  European  Commission 
https://commission.europa.eu/publications/recovery-and-resilience-facility-annual-report-2023_en.  

(2023)  Recovery 

and  Resilience  Facility  Annual  Report 

2023 

(COM(2023) 

545 

final/2), 

available 

at: 

158 

 
 
The effectiveness of the RRF in cushioning the impacts of the crisis on women is expected to vary among Member States and depends on various factors, 
including the share, topic areas and quality of gender-related measures, the extent of gender mainstreaming and male employment bias, and the actions that 
have been and will be taken during the RRF’s implementation, monitoring, and evaluation.  verall, some stakeholders have a more critical stance on the 
performance of the RRF regarding gender equality, while others rather underline the strengths and many efforts taken to ensure an inclusive recovery and 
mitigate the effects of the crisis on women in a challenging context. 

Looking at the effectiveness overall, three of the four common indicators that have been disaggregated by gender show that more women than men were 
supported by the RRF so far. Many relevant gender-related CSRs have also been reported to have at least a degree of progress. On the other hand, three ex-
ante national gender impact evaluations on the RRF investments are rather critical about the gendered impact of some RRPs. Analysed gender-flagged 
measures indicate that relevant outputs have been achieved already, and relevant results and impacts are expected. Many results and impacts have, however, 
not yet materialised, depend on further implementation and are generally (especially reforms) difficult to measure. 

EQ4.2: supporting the economic recovery 

The RRF has contributed to preserving public investment in the EU and is expected to boost it going forward. The EU’s aggregate public investment ratio 
is expected to rise to 3.4% of GDP in 2024, having increased from 3.0% in 2019 to an expected 3.3% in 2023, according to the Commission’s 2023 Autumn 
Forecast333.  In contrast with previous macroeconomic shocks, public investment hence remained robust during the COVID-19 pandemic and the energy 
crisis. The 2023 Autumn Forecast also finds that around half of the increase in public investment between 2019 and 2025 is related to investment financed 
by the EU budget, particularly by the RRF. By the end of the forecast horizon, in most EU Member States national budgets are projected to devote more 
resources to investment than they did prior to the pandemic, with Slovenia, Portugal and Italy expected to record the largest increases. On the contrary, 
Hungary, and to a lesser extent the Netherlands, are set to reduce their nationally financed investment compared to 2019. 

333   See  European  Economic  Forecast  –  Autumn  2023,  available  at:  https://economy-finance.ec.europa.eu/economic-forecast-and-surveys/economic-forecasts/autumn-2023-economic-forecast-modest-

recovery-ahead-after-challenging-year_en.  

159 

 
 
Simulations  with  the  Commission’s  QUEST  model  estimate  sizable  macroeconomic  effects  of  NGEU  investment334.  The  model’s  results  predict  that 
NGEU335 has the potential to increase EU real GDP by up to 1.4% in 2026 above a no-NGEU scenario336. According to the estimations, the peak GDP effect 
for the EU would materialise in 2026. The model simulations also suggest a sizeable, short-run increase in EU employment (by up to 0.8%). Moreover, the 
results predict persistently higher real wages in the medium term, reflecting potential productivity gains of productive investment337. 

RRF loans, if used to finance additional projects, contribute to the positive real GDP impact. These gains are largest for Member States that requested large 
additional loans (as of 2023), while all Member States can benefit from other Member States’ investment through spillover effects.  

The estimated results of the NiGEM model broadly confirm the magnitude of these results, albeit with some noticeable differences. Overall, both modelling 
approaches find a substantially positive impact of NGEU/RRF. The NiGEM analysis includes a reduction in spreads and government borrowing costs, 
which is a further benefit of the RRF. At the same time, the productivity gains of public investment appear to be lower in the NiGEM model (partly due to 
the model’s assumptions)338.  

The NiGEM simulations suggest that the initial disbursements lowered unemployment in the European Union by around 0.2 percentage points relative to 
what it would have been in the absence of the RRF. The overall fall in unemployment is found to be driven by large falls in the southern European Member 
States of Greece, Italy, Portugal, and Spain. 

334   To estimate the macroeconomic impact of the RRF, the European Commission has produced stylised ex-ante assessments of the macroeconomic impact of NGEU investment. These model simulations 
are not an ex-post evaluation of the actual impact, but rather an ex-ante model prediction based on stylised assumptions. Nonetheless, the simulations presented here integrate up-to-date information on 
loan requests, inflation, and expected spending profiles. They focus on investments as the macroeconomic effects of structural reforms is much more challenging to model. For further information, see 
in particular, Pfeiffer P., J. Varga, and J. in 't Veld (2023a) Quantifying spillovers of coordinated investment stimulus in the EU, Macroeconomic Dynamics (27), p. 1843–1865. See also the ECFN 
Discussion Paper (2021): https://economy-finance.ec.europa.eu/publications/quantifying-spillovers-next-generation-eu-investment_en. 

335   The QUEST model results have been computed based on NGEU and not RRF investments. However, the investments (loans and non-repayable support) based on the RRF make up for around 90% of 

NGEU investments. 

336   Please see Annex II for a detailed discussion of the assumptions and model specifications. 
337   Note that because the simulations focus on public investment (without accompanying labour-market reforms), the employment effects are relatively short-lived and real wage increases reflect most 
medium and long-run labour market benefits in the simulations. By contrast, reforms targeting labour markets and increasing participation can lead to large employment gains in the medium and long 
run. 

338   As acknowledged in the evaluation report, the long-run GDP gains from government investment multipliers appear to be below the QUEST estimates, partly because government investment is “treated 

as ‘consumption’ and so does not add to the economy’s capital stock, which is the main way that government investment raises GDP in the long run” (see p.2  of the evaluation report). 

160 

 
 
The  importance  of  positive  cross-country  spillovers  as  well  as  reductions  in  interest  rate  spreads  are  central  to  these  overall  findings.  The  joint 
implementation of investment by all Member States generates an added value for the EU that amounts to between one-fourth and one-third of the total 
impact of the RRF (hereafter referred to as spillovers). These positive spillover effects have confirmed in the QUEST assessments and are also relevant in 
the NiGEM simulations. Moreover, the NiGEM estimations yield that reducing spreads has been an important positive side effect, which potentially helped 
mitigate risks of financial fragmentation at the time of the COVID shock.  

EQ4.3: enhancing social and territorial cohesion 

In total, 1,360 (sub-)measures encompassing investments and reform are contained within the social and territorial cohesion pillar (390 reforms and 970 
investments). The largest number contribute to territorial infrastructure and services (602) and to social protection (246). A significant number of (sub-) 
measures contribute to adult learning and skills validation (238), the development of rural and remote areas (118), and the modernisation of labour market 
institutions (96). The rest of the (sub-)measures contribute to social housing and other social infrastructure (71) and on (non-youth) employment support 
and job creation (68). Looking at the distribution across Member States, significant variation in the number of measures in the social and territorial cohesion 
pillar is observed. The Member State with the highest number of measures is Spain. In terms of progress by 1 February 2024, 876 of the 2,590 milestones 
and targets contributing to social and territorial cohesion are already reported as completed by Member States or assessed as fulfilled by the Commission, 
representing a 34% progress rate (15% assessed in payment requests). 

The contribution of the RRF to the social and territorial cohesion within Member States has been the object of a broad debate: in most Member States, the 
impact on territorial and social cohesion can often be measured only indirectly, as disadvantaged groups and regions may benefit from reforms with a 
lasting effect as well as investments, without the measures targeting them directly or explicitly. Social and territorial cohesion figures in the several RRPs, 
yet with different approaches across Member States. For instance, the Italian, Spanish and Croatian plans do not include a strategy to enhance social and 
territorial cohesion whereas other Member States do not feature a vast range of related measures in their RRPs. 

The  case  study  on  the  modernisation  of  labour  market  institutions,  specifically  active  labour  market  policies,  provides  more  detailed  insights  into  the 
effectiveness of the RRF in supporting social and territorial cohesion in four Member States: France, Italy, Spain and Croatia. What emerges is that social 
and territorial cohesion are targeted by Active Labour Market Policy measures to varying extents. 

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On the EU level, the RRF clearly supports economic convergence and cohesion among Member states. With its allocation key, the RRF was designed to 
support lower-income and more vulnerable Member States, which had also been hit the hardest by the pandemic. The RRF’s allocation of funding thus 
helps counteract the economic divergence, fostering economic stability and growth where it is most needed.  

The macroeconomic model simulations also provide relevant analysis regarding economic convergence and cohesion among Member states. Given the 
allocation key, the Member States with below-average GDP per capita are estimated to experience the largest boost to GDP levels because of the significant 
RRF investments. For the benchmark (high productivity) model calibration, the increase in output reaches almost 4.5% in Greece, more than 4% in Croatia, 
and around 3.5% in Spain and Bulgaria compared to the EU average impact of 1.4%. Spillover effects reinforce the positive impact. The model-based 
analysis does not cover reforms, which can further lay the groundwork for long-term economic convergence within the EU. 

Simultaneous implementation by all Member States of their RRPs generates sizable positive spillover effects. In line with the estimates based on QUEST339, 
the  absence  of  joint  and  coordinated  action  (counterfactual)  would  have  substantially  reduced  the  average  GDP  impact.  While  all  Member  States  are 
estimated to benefit from sizable cross-border spillover effects because of rising demand across the integrated EU economy, the RRFs joint investment 
impulse is also supporting the upward economic convergence in the EU. The results show that Member States with below-average GDP specifically gain 
from the enhanced economic activity and cross-border trade spurred by these spillover effects. Compared to the domestic effects induced by the national 
plan, spillover effects account for most of the GDP impact for small open economies with smaller non-repayable support allocations and high-income 
levels. Even in larger economies with deep trade integration, spillovers account for a sizable share of the total GDP effect. This analysis is reinforced from 
simulations undertaken using the NiGEM model340. It shows that the collective effect on EU GDP is greater than the sum of the direct effects of RRF 
spending  if  each  Member  State  (counterfactually)  implemented  the  investments  on  its  own.  The  NiGEM  simulations  also  suggest  that  the  initial 
disbursements lowered unemployment in the European Union by around 0.2 percentage points relative to what it would have been in the absence of the 
RRF. 

339   See  Pfeiffer,  P.,  Varga,  J,  and 

in  ‘t  Veld,  J.  (2023b)  Unleashing  Potential:  Model-Based  Reform  Benchmarking 

for  EU  Member  States,  available  at:  https://economy-

finance.ec.europa.eu/publications/unleashing-potential-model-based-reform-benchmarking-eu-member-states_en. 

340   See pages 82 to 85 of the supporting study. 

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EQ4.4: increasing health, economic, social and institutional resilience 

The RRF Regulation defines resilience as ‘the ability to face economic, social and environmental shocks and/or structural changes in a fair, sustainable 
and inclusive way’ (Article  2.5). There are 1173 (sub-)measures that contribute to  resilience (that  is,  (sub-)measures that contribute to  the ‘health and 
Institutional resilience’ pillar ( 8  reforms and  88 investments).  ver two third of (sub-)measures in this pillar contribute to improving the effectiveness 
of public administrations (498) and to strengthening healthcare systems (290). Other important areas of intervention are tax measures (81), efficiency of 
the judicial systems (74), fiscal policy (72) and fraud prevention (68).  

By 1 February 2024, 962 of the 2,317 milestones and targets contributing to health, and economic, social and institutional resilience are already reported 
as  completed  by  Member  States  or  assessed  as  fulfilled  by  the  Commission,  representing  a  42%  progress  rate  (over  20%  assessed  as  fulfilled  by  the 
Commission). It is too early to reach final conclusions as regards the effectiveness of these interventions, but there is some evidence of results achieved so 
far. Two common indicators are related to pillar 5 (resilience): the number of users of new and upgraded public digital services, products and processes 
and  the  capacity  of  new  or  modernised  healthcare  facilities  supported  by  RRF  measures.  With  respect  to  the  first,  21  Member  States  have  reported 
approximately 308 million users of new or upgraded public digital services resulting from RRF measures (see EQ2.1). As regards the increase in healthcare 
capacity, additional capacity for a total of over 45 million has been reported. However, only nine Member States have reported upon this indicator. 

The RRF also supports structural reforms aimed at strengthening and guaranteeing rule of law and, in particular judicial independence. These structural 
reforms outlined in the Semester CSRs are relevant to strengthen the business environment in the Member States concerned and are expected to have an 
impact  on  its  growth  potential341.  For  example,  Hungary,  Romania  and  Poland  have  included  in  their  RRPs  reforms  aimed  at  strengthening  judicial 
independence. Whilst it is too early to assess the results of these reforms, particularly since the content of these reforms has not yet been notified to or 
assessed by the Commission by February 2024, the mere fact of having adopted them can be considered as a positive step342. This view is supported by 
academic authors343 who discuss the potential role of the European Semester and the RRF to address rule of law issues and conclude that the RRF has 
become a powerful tool to make progress to protect the rule of law. 

341   See Council (2023) European Semester 2023: country-specific recommendations agreed, available at: https://www.consilium.europa.eu/en/press/press-releases/2023/06/16/european-semester-2023-

country-specific-recommendations-agreed/. 

342   This is confirmed by the findings of the supporting study, see page 92 of the study. 
343   Fromont, L.; and Van Waeyenberge, A. (2021) Trading rule of law for recovery? The new EU strategy in the post-Covid era, available at: https://doi.org/10.1111/eulj.12426.  

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EQ4.5: supporting the green transition 

The green transition is a key focus of the RRF and has been allocated a significant amount of RRF funding across all Member States. The total number of 
(sub-)measures contributing to the green transition is 1,421 (sub-)measures (291 reforms  and 1,130 investments), including over 2,600 milestones and 
targets.  The biggest expenditure supporting  the  green transition  has been allocated to  sustainable mobility  (31%) in  all the  RRPs, followed by energy 
efficiency (29%) and renewable energy and networks (14%). The same policy areas are the most popular also in terms of the number of measures.  

In addition, all Member States’s RRPs have exceeded the target of 3 % of total allocation set in the RRF Regulation, with the total estimated climate 
expenditure amounting to EUR 2   billion or over 40% of the total plans’ allocations. Several Member States are even dedicating over half of their total 
allocation to climate objectives, such as Austria, Bulgaria, Denmark, Estonia, Luxembourg, Malta, and Finland. 

As for the types of measures that Member States implement under the green transition pillar, the balance between investments and reforms varies across 
policy areas: 

•  With  regards  to  sustainable  mobility,  investments  focus  on  zero  or  low  emissions  vehicles,  the  development  of  urban  public  transport,  the 
infrastructure for recharging and the modernisation of railway infrastructure which makes up the majority of funding at EUR 42 billion. Reforms 
included in some RRPs aim at changing the regulatory framework in view of enabling the roll out of zero emission mobility and support sustainable 
urban mobility, and establishing taxation regimes. 

•  Under the energy efficiency policy area, accounting for 29% of the total expenditures under the green transition pillar, Member States have included 
in  their  plans  large  investments  in  energy  renovations  of  private  and  public  buildings  and  in  the  construction  of  new  highly  energy  efficient 
buildings. The majority of investments concern the energy efficiency of residential buildings (at EUR 31 billion), which typically targets a reduction 
in primary energy consumption of 30% or more. Beyond buildings, investments in other sectors will help to decarbonise the production processes 
in SMEs, larger enterprises and district heating systems, for instance by promoting the integration of cleaner and more efficient technologies for 
manufacturing processes and centralised heat production. To this end, some RRPs also include reforms to tackle barriers for energy efficiency, 
such as amendments to the regulatory framework or the harmonisation of support mechanisms through one-stop shops. 

•  With view to renewable energy and networks, investments focus on renewable energy generation, both in already mature renewable technologies 
as well as innovative solutions (EUR 24 billion). Furthermore, they aim at constructing and upgrading energy networks and infrastructure (EUR 
11 billion). Increasing the share of renewables also requires an ambitious reform agenda. To this end, the reforms included in the plans aim to 

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create a stable regulatory environment and appropriate synergies between public and private investment, simplify administrative procedures and 
to adopt new or prolong existing support schemes. 

•  With  respect  to  R&D&I  into  green  activities  (6%  of  total  expenditures  under  the  green  transition  pillar),  investments  focus  on  strengthening 
research in the fields of circular economy, the decarbonisation of the industry and clean technologies, including the industrial value chain for the 
hydrogen transition and energy storage. Reforms in some RRPs complement those efforts by changes in the regulatory framework, with a focus 
on improving the conditions for developing hydrogen technologies and transitioning to a circular economy model. 

• 

For measures labelled with climate change adaptation, investments and reforms aim to advance the sustainable management of water (supply) and 
forests and increase the resilience towards risks stemming from climate-related disasters, in particular with regards to forest fires and flooding. 
Action under this policy area often overlaps and complements measures under the sustainable use and protection of water and marine resources, 
and the protection and restoration of biodiversity and ecosystems. 

Progress in implementing measures related to the green transition has been overall good. Over a third of milestones and targets have been reported as 
completed or assessed as satisfactorily fulfilled by the Commission by 1 February 2024. Specifically, 908 of 2,625 milestones and targets related to the 
green transition are already reported as completed by Member States or assessed as fulfilled by the Commission, which yield a progress rate of 35% (17% 
assessed in payment requests). Given that final effects will only materialise in the longer term, it is  too early to assess the RRF’s impact on the green 
transition overall and to gauge the impact of green-transition measures more specifically. Nonetheless, the already fulfilled ‘green’ milestones and targets 
have helped increase momentum for green transition344. For example, as regards reforms, Slovakia has approved legislation to improve waste management 
in the construction and demolition sector. Greece introduced a reform to streamline and digitize the licencing framework for renewables and passed a law 
to implement the Guarantees of Origin system supporting renewable energy for households. Denmark introduced a reform which entails higher taxation on 
greenhouse  gas  emission  incentivizing  lower  emissions  from  Danish  businesses  as  well  as  tax  deductions  fostering  green  investments.  In  terms  of 
investments,  Bulgaria  introduced  investments  to  support  green  and  efficient  public  transport  services  as  well  as  a  reform  to  further  the  green  energy 
transition. Czechia invested in sustainable transport by completing road and railway safety projects and by renovating railway bridges and tunnels. Croatia 
has introduced investments to construct and renovate public water supply networks. Spain has put in place mechanisms to support investments to deploy 
renewable energy sources in buildings and in industrial processes and to supported initiatives carried out by energy communities. 

344   See pages 92 to 97 of the supporting study. 

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Data on the common indicators345 point to positive results in the areas of energy savings and deploying renewable energy infrastructure. Member States 
have reported  already achieving about  28.3 million Megawatt-hours of savings in  annual  primary energy  consumptions and over  54,000  Megawatt of 
capacity for renewable energy production, as well as installing over 530,000 new or upgraded refuelling and recharging points for clean vehicles.  

Looking into measures addressing energy efficiency in buildings, implementation speed appears to vary across the four Member States examined in the 
supporting study346 (i.e. Bulgaria, France, Latvia and Romania). Evidence from a case study demonstrates that whilst France and Romania are making good 
progress towards their milestones and targets for energy efficiency in buildings, Latvia is experiencing some delays, and Bulgaria is lagging behind. Energy 
efficiency measures are  long-term  construction projects  by nature, and it is  too  early to  draw firm  conclusions about  energy savings impacts.  Various 
outputs have however been achieved in all four Member States studied, such as published calls for tender, applications to energy-efficiency calls for tender, 
and a number of granted projects. Other examples illustrate how RRF supported measures are having an impact on the ground. For instance, with the aim 
to develop clean mobility solutions to decarbonise the transport sector, Germany adopted a reform on a ten-year tax exemption for purely electric vehicles. 
Data from the German Federal Motor Transport Authority347 demonstrates that there has been already a steady growth in pure electric vehicles in Germany, 
suggesting that the measure is delivering good results in this sector in Germany. 

Member States recognise the Do No Significant harm (‘DNS ’) principle as a new feature that has strengthened the ‘green’ dimension of RRF reforms 
and investments and helps achieve the RRF’s green objectives, according to the results of the public consultation and a survey of key RRF stakeholders348. 
EU and national respondents expressed their satisfaction with the novelty of the principle and its potential to shape investments in line with the European 
Green  Deal  objectives,  noting  that  the  principle  could  have  positive  “spillover  effects”  into  national  policy  systems  and  improve  the  environmental 
sustainability of Member States’ public investments.  

In general, the RRF has been successful in emphasising the need to introduce reforms and invest in fostering the green transition. It is too early to assess 
the overall impacts of the RRF as most measures are still under implementation and the final effects will only materialise in the longer term. The vast 
majority of respondents to the public consultation think that the RRF has contributed or will contribute to the green transition (62%) and the European 

345   See data on common indicators (1), (2), and (3) amongst others. 
346   Evidence in this paragraph is sourced from the supporting study (see pages 92 to 97) and from the associated case study on the green transition. 
347   See Box 3 on ‘German reform on ten-year tax exemption for purely electric vehicles’ on pages  9 and  0 of the supporting study. 
348   See page 97 of the supporting study. 

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Green Deal (64%) to some or large extent. However, fewer respondents are confident about the role of the RRF in contributing  to the EU Biodiversity 
Strategy, with less than half of them thinking the RRF contributes to the Strategy to some or large extent. 

EQ4.6: supporting the digital transformation 

The RRF supports various measures contributing to the digital transformation in the Union. RRPs cover a range of measures, including deployment of next 
generation  digital  infrastructures  and  advanced  technologies,  digital  skills  development  for  the  population  and  the  workforce,  and  support  to  the 
digitalisation of enterprises as well as of public services349. Member States have exceeded the target of 20% of total allocation set in the RRF Regulation, 
with the total estimated digital expenditure amounting to EUR  30 billion or 2 % of the total plans’ allocations. 

Out of 1,106 (sub-)measures classified as “digital transformation” (2   reforms and 8 0 investments), the largest number contribute to E-Government, 
Digital Public Services (including Digitalisation of Transport) and Local Digital Ecosystems (563). These (sub-)measures account for over one-third of the 
digital funding, equivalent to 37% of the pillar. A significant number of measures contribute to Human Capital in Digitalisation (198), Digital Capacities 
and Deployment of Advanced Technologies (120), and Digitalisation of Businesses (119). The rest of the (sub-)measures focus on Connectivity (63) and 
Digital-Related Measures in Research, Development and Innovation (42). A high variation can be observed among the Member States regarding the number 
of  measures  put  forward  as  part  of  the  digital  transformation  pillar.  The  Member  States  with  the  highest  number  of  (sub-)measures  in  the  digital 
transformation pillar are Croatia and Romania, with 104 and 95 (sub-)measures respectively. 

As for the types of measures that Member States implement under the digital transformation pillar, the balance between investments and reforms varies 
significantly across policy areas: 

•  Under the Connectivity label, investments focus on improving and expanding digital communication networks to enhance connectivity. These 
projects aim to develop, upgrade, or expand various types of communication infrastructure to provide faster, more reliable, and widespread 
access to digital services and data transmission. Reforms aim to improving and advancing digital connectivity, especially in the context of 
broadband and high-speed internet access.  

349   For 

further 

see  European  Commission 
https://commission.europa.eu/publications/recovery-and-resilience-facility-annual-report-2023_en.  

(2023)  Recovery 

information, 

and  Resilience  Facility  Annual  Report 

2023 

(COM(2023) 

545 

final/2), 

available 

at: 

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•  With respect to Digital Capacities and Deployment of Advanced Technologies, investments focus on advancing digital technologies and 

infrastructure, while reforms aim to modernise infrastructure, enhance cybersecurity, improve data management, foster innovation, and create a 
conducive environment for the deployment of advanced technologies to drive economic growth and efficiency.  

• 

The investments indicated under Digitalisation of Business aim to support various sectors of the economy, with a particular focus on SMEs, 
innovation, and the use of financial instruments to support businesses in their digital journey, while reforms intend to promote digitalisation 
within the business environment.  

•  When it comes to Research, Development & Innovation, investments and reforms aim at advancing digital research, development, and 
innovation, with a focus on collaboration, financial support, specific sectors, and the promotion of research infrastructure and talent 
development. 

• 

E-government investments aim to leverage digital technologies to improve public services, enhance efficiency, promote economic growth, and 
ensure inclusivity and accessibility for citizens and businesses, while reforms intend to harness digital technologies and strategies to enhance 
government services, improve governance, and promote digital innovation and accessibility.  

•  Human capital investments in digitalisation focus on addressing the challenges and opportunities posed by the digital age by promoting digital 

skills development, education, and inclusion, with a focus on various segments of the population and partnerships between different 
organisations and sectors.  

• 

Finally, multi-country projects, key to the “Path to the Digital Decade”350 policy programme which aims to help the EU achieve digital objectives 
including resilience, digital sovereignty, and competitiveness, were introduced to the Member States during the RRF negotiations. This allowed 
the Member States to include these in their RRPs. Examples of such projects are based around: Security Operation Centres, MediaInvest, 
European Blockchain Services Infrastructure, EuroQCI, 5G Corridors, Common European Data Infrastructure, Processors and Semiconductor 
chips, Connected Public Administration, Genome of Europe, Digital Skills. 

Member States have made significant progress in implementing measures related to the digital transformation and nearly a third of related milestones and 
targets are reported as complete or assessed by the Commission as fulfilled. 721 of 2,297 milestones and targets related to the digital transformation are 

350   See  https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/europe-fit-digital-age/europes-digital-decade-digital-targets-2030_en.  The  framework  for  Multi-country  projects  has  been 

further developed in the Decision (EU) 2022/2481 establishing the Digital Decade Policy Programme 2030, see https://eur-lex.europa.eu/eli/dec/2022/2481/oj.  

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already reported as completed by Member States or assessed as fulfilled by the Commission, which yield a progress rate of 31% (approximately 15% 
assessed in payment requests).  

Data on the common indicators351 point to positive results related to the digital transformation. Seven Member States reported that an additional 5.6 million 
dwellings had received internet access via high-capacity networks with support received under the RRF. In addition, 21 Member States reported that the 
number of users of new or upgraded public digital services had increased to almost 309 million people, although it cannot be excluded (because of data 
limitations) that the same person has used the service multiple times. 

Some of the measures implemented in the digitalisation of health are already having an impact on the ground352. The digitalisation of health has been a top 
priority for the EU in recent years and many Member States – Belgium, Croatia, Czechia, Denmark, and Estonia amongst others – have already implemented 
measures related to the digitalisation of national healthcare systems as part of their RRPs. These measures include eHealth services, telemedicine solutions, 
and improvements in healthcare data management. Evidence from the case study353 shows that they have been effective in achieving their objectives, such 
as  empowering  patients,  optimising  healthcare  delivery,  and  fostering  innovation.  As  aforementioned,  these  measures  have  also  positively  impacted 
healthcare systems, including the use of e-consultations and digital tools to improve patient care and access to specialists in Croatia and in other Member 
States354. 

While investments in the digital sector are still in the early stages, a number of reforms supporting the digital transformation have been implemented and 
are starting to have an impact on the ground. For example, Romania adopted a reform to accelerate the national roll-out of 5G networks, in accordance 
with security regulations, and to provide broadband coverage for white areas (small rural municipalities, isolated localities, disadvantaged inhabited 
areas), tackling the rural-urban digital divide, reducing the administrative burden and streamlining procedures and fees, creating the prerequisites for 
equal access to digital services and internet access. Belgium’s  G reform introduced in 202 , and supported by the RRF, led to a significant increase in 
5G traffic in 2022355. 

351   See data on common indicators (5), (7), and (10) amongst others. 
352   Evidence in this paragraph is sourced from the case study on the digitalisation of healthcare included in the supporting study. 
353   Evidence in this paragraph is sourced from the case study on the digitalisation of healthcare included in the supporting study. 
354   See section above on ‘on improving the resilience, crisis preparedness, adjustment capacity and growth potential of the Member States’ 
355   See Box 4 ‘Introduction of  G reform in Belgium’ on pages  0 and    of the supporting study. 

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EQ4.7: fostering smart, sustainable and inclusive economic growth and employment potential within the Union 

The  review  of  the  measures  included  in  the  RRF  indicates  that  they  contribute  to  fostering  smart,  sustainable,  and  inclusive  economic  growth  and 
employment potential within the EU. Under the pillar, 1,535 (sub-)measures have been identified (509 reforms and 1,026 investments). Regarding the 
policy areas under the smart, sustainable and inclusive growth pillar, (sub-)measures contributing to research, development and innovation (RDI) are the 
most  common  (271),  followed  by  (sub-)measures  contributing  to  regulatory  change  for  smart,  sustainable  and  inclusive  growth  (256)  and  to  building 
renovation and construction (241).  

The measures also support the green and digital transitions, crucial elements for achieving sustainable growth. Beyond the need for regulatory changes in 
Member States to promote and enhance economic growth and employment, a considerable amount of the measures included under the smart, sustainable 
and inclusive growth pillar target the twin transition. Out of the 1,535 identified (sub-)measures under the pillar, 437 have a specified climate, green or 
digital component. As regulations play an imperative role in driving the green and digital transition in Member States356, it is unsurprisingly reflected in the 
RRP of Member States. The pillar on smart, sustainable, and inclusive growth has one of the highest percentage (%) of milestones and targets reported as 
completed by the Member States or assessed as fulfilled by the Commission: 1,152 milestones and targets out of 2,780 or 41%  (and 21% assessed in 
payment requests). As such, the implementation of the pillar seems to be advancing comparatively well. 

The common indicators report that in terms of results, the following have been achieved: 1) over 1.9 million enterprises have been supported based on 
numbers reported by 26 Member States (over 530,000 are SMEs); 2) specifically, over 580,000 SMEs were supported across 15 Member States in mainly 
adopting and to some extend developing digital products, services and processes; 3) over 17,000 researchers have been supported under the RRF across 17 
Member States; 4) over 1.3 million people have been supported in employment or job searching activities based on numbers reported by 13 Member States, 
and 5) over 8.7 million have participated in education and trainings to improve their skills in 20 Member States. 

The RRF has helped in addressing social, economic and territorial challenges, in line with the relevant European Semester’ CSRs. For instance, Spain, 
France, Italy and Croatia have included Active Labour Market Policies (‘ALMP’) that address a number of key labour market challenges in line with their 
CSRs in 2019 and 2020. Evidence from the case studies357 demonstrates that some Member States even utilised this opportunity to develop a forward-

356   See European Commission (2022) A green and digital future: 7 insights from strategic foresight, available at: https://joint-research-centre.ec.europa.eu/jrc-news-and-updates/green-and-digital-future-7-

insights-strategic-foresight-2022-06-30_en.  

357   Evidence in this paragraph is sourced from the supporting study (see pages 86 to 89) and from the associated case study on Active Labour Market Policies. 

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looking approach to address future labour market challenges and to strengthen the labour market situation of vulnerable groups or address regional inequality 
in service provision, which enhances social and economic cohesion. However, the case studies also showed that the labour market situation of vulnerable 
groups could have been addressed more comprehensively in France and Croatia, and the impact of ALMP on social and territorial cohesion is mixed. All 
milestones and targets associated with ALMP measures up to June 2023 have been either fulfilled or completed in the Member States analysed in the case 
study. In Spain, all reform-related milestones and targets have been adopted and the implementation of the investment in activation policies is ongoing. In 
Italy and France, take-up of ALMP measures is exceeding the interim targets, partially because higher targets were set at national level. In Croatia however, 
whilst milestones and targets were introduced according to the timeline envisioned, take-up patterns are mixed: while take-up of vouchers is high, there is 
limited progress with regard to new active labour market policies. 

Based  on  survey  data358,  business  organisations  had  an  overall  positive  view  of  the  EU’s  efforts  in  addressing  the  post-COVID  economic  challenges. 
However, RRP measures designed to bolster economic recovery and resilience, while overall relevant, have demonstrated varying degrees of relevance for 
addressing SME needs. The case study also demonstrates that progress implementing SME-related measures varies across Member States, with some SME 
stakeholders raising the issue of slower payments to the ultimate recipients of RRF support. 

EQ4.8: supporting policies for next generation 

In total, 373 (sub-)measures contribute to policies for the next generation, children and youth (121 reforms and 252 investments). Of these, the vast majority 
contribute to the policy area of general, vocational and higher education (313), while a much smaller number of (sub-)measures contribute to early childhood 
education  and  care  (43)  and  youth  employment  support  and  youth  job  creation  (22).  Member  States  whose  RRPs  include  the  most  (sub-)measures 
contributing to this pillar are Romania (42), followed by Slovakia and Belgium (both with 32 (sub-)measures) and Italy (31). There is a large variation in 
the number of (sub-)measures by Member State, with only one measure in Estonia or no measure in Denmark and Luxembourg.  

Progress is tangible for the milestones and targets contributing to policies for the next generation, children and the youth, such as education and skills. So 
far, 222 of 636 milestones and targets are already reported as completed by Member States or assessed as fulfilled by the Commission, which yield a 
progress rate of 35% (17% assessed in payment requests). 

358   See the case study on SME included in the supporting study. 

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The analysis conducted for the case study on policies for the next generation, which focuses on early childhood education and care, provides more detailed 
insights  on  the  effectiveness  of  the  RRF  in  supporting  policies  for  the  next  generation.  The  analysis  shows  that  the  RRF  investment  is  expected  to 
significantly increase the coverage of childcare services in all five Member States selected for the case study. Significantly, the measures included in the 
RRPs will also contribute to the reduction of existing territorial gaps in the offer of affordable childcare services. Another important effect of the expansion 
of childcare services, is the increase in access to employment opportunities for women. In some Member States, stronger growth in public/subsidised places 
will happen in territories where female unemployment is higher, potentially contributing to reduced gender disparities in the labour market. Despite progress 
in the expansion of childcare services in the Member States selected, some potential barriers have emerged throughout the implementation of measures. 
For instance, the tight  timetable for developing projects  has discouraged a number of local  authorities, which are usually responsible for applying for 
funding. In addition, a lack of prioritisation towards the most disadvantaged territories in the assignment of funds together with the impetus to advance 
funding to start infrastructural work, might have also stopped municipalities with limited financial means from applying for funding. Increasing costs for 
infrastructural works due to inflation have increased the financial burden on municipalities, leading to a need for government intervention to fill financial 
gaps.  

EQ4.9: mitigating the long-term risks stemming from the COVID-19 crisis 

With its massive size and quick initial roll-out, the RRF has allowed for an effective EU policy response to the unprecedented economic crisis linked to 
COVID-19 and subsequent economic challenges. Through its pre-financing feature, the RRF swiftly provided fiscal space in the aftermath of the COVID-
19 crisis. Since then, the RRF has contributed to sustaining public investment in the EU. In contrast to previous macroeconomic shocks, public investment 
in the EU has increased in the aftermath of the COVID shock. 

A key innovative feature of the RRF is its ability to support the implementation of structural reforms, which will have a long run effect on the EU’s growth 
potential. Making the approval of RRPs and subsequent disbursements conditional upon the inclusion and gradual implementation of key reforms has 
created significant incentives to carry out structural reforms. Thanks to the RRF, implementation of CSRs has significantly advanced, and much more than 
in years preceding the RRF. Moreover, combining complementary reforms and investments in a single plan – and under one instrument – is beneficial and 
can increase their impact since, for example, certain enabling reforms can make subsequent investments more effective. 

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For a small number of  Member States, the RRF has a particularly noticeable long-run effect, either because the RRF payments represent  a significant 
fraction of their GDP, or the elasticity of output with respect to capital is particularly large, or both. This effect is larger for southern European Member 
States, which were also particularly badly affected by the COVID-19 pandemic.  

EQ4.10: contributing to REPowerEU objectives 

Most Member States have already added specific chapters to their national recovery and resilience plans in order to finance key investments and reforms 
which will help achieve the REPowerEU objectives. So far, 23 Member States have seen their REPowerEU chapters adopted by the end of 2023, while the 
remaining four are expected to be adopted in 2024. It is too early to assess the implementation of REPowerEU chapters as payment requests related to these 
chapters will start in 2024. It is however expected that the measures will help Member States move to a more reliable, secure, and sustainable energy supply. 
More than EUR 60 billion from the approved REPowerEU chapters is allocated to contribute to save energy, substitute fossil fuels and address immediate 
security of supply needs, while diversifying away and reducing dependency on Russian fossil fuels. 

The REPowerEU chapters are expected to contribute to the REPowerEU objectives of enhancing the resilience, security and sustainability of the European 
Union´s energy system. This should be achieved by reducing reliance on fossil fuels and diversifying energy sources across the EU through measures to 
boost the uptake of renewables, to improve energy efficiency and to expand energy storage capacity. Overall, the REPowerEU chapters aim at allowing for 
the enabling of at least 20 Gigawatt of renewable energy by 2026, on top of 40 Gigawatt in the existing plans. In addition, the revised plans include long-
lasting energy efficiency interventions which, once implemented, will reduce energy bills for at least one million households. More than EUR 12 billion 
will be made available to decarbonise our industry, including EUR 2.5 billion for renewable hydrogen production. Strategic clean-tech investments in 
electrolysers, batteries and solar panels will be fostered, together with dedicated green skills training of more than 100,000 individuals. 

Save Energy 

One of the main objectives of REPowerEU is to save energy and enhance energy efficiency as the cleanest and cheapest way to address the energy crisis. 
Relevant investments are expected to support the delivery of national ambitions to reduce (by 30%, in most cases) energy consumption from buildings and 
industry359  and  to  reduce  the  climate  impact  as  much  as  possible  by  accelerating  the  transition  from  fossil  fuels  (by  complementing  energy  efficiency 

359   See for example the REPowerEU chapters of Belgium, Croatia, Czechia, Denmark, France, Greece, Hungary, Lithuania, the Netherlands, Portugal, Romania, Slovakia, and Sweden. 

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renovation with solar rooftops, heat pumps and phasing out of fossil fuels in heating)360. Energy efficiency will also protect households from higher bills 
and provide targeted support to help energy poor and vulnerable consumers361. One-stop-shops are expected to bridge the gap between the fragmented 
supply and demand side to facilitate the delivery of energy efficiency measures362. 

Diversifying Energy supplies and enhancing the resilience of energy networks 

REPowerEU investments are expected to strengthen energy infrastructure, address immediate needs of security of supply and bottlenecks in both internal 
and cross-border transmission and distribution networks. Limited support363 is provided to targeted infrastructure for tackling the immediate security of gas 
supply and for reducing dependency on Russian fossil fuels. Moreover, REPowerEU also contributes to the EU´s energy independence by supporting the 
manufacturing of strategic net-zero technologies such as electrolysers, batteries and solar panels364. 

Fast forwarding the clean energy transition 

The REPowerEU chapters aim to increase the share of renewables by delivering 8.4 Gigawatt of power from offshore/onshore wind and solar by 2026365, 
speed up the permitting procedures366 and secure appropriate grid connections367 by investing in smarter, more flexible, digitally enabled grids368 to unleash 
the full potential of renewable energy sources. Electricity storage369 and biomethane/renewable hydrogen generation370 are expected to be rolled out and 
scaled  up  rapidly.  On  green  skills,  the  revised  plans  include  measures  to  ensure  that  qualifications  are  in-line  with  labour  market  needs  by  mapping, 

360   See for example, the REPowerEU chapters of Denmark, Greece, Italy, and Poland. 
361   See for example, the REPowerEU chapters of Romania. 
362   See for example, the REPowerEU chapters of Czechia, Romania. 
363   See for example, the REPowerEU chapters of Croatia, Italy and Poland. 
364   See for example, the REPowerEU chapter of Portugal. 
365   See for example, the REPowerEU chapters of Czechia, Hungary, Lithuania, Poland, Portugal, Romania, and Slovenia. 
366   See for example, the REPowerEU chapters of Austria, Belgium, Czechia, France, Portugal, Romania, Slovakia, Slovenia, and Spain. 
367   See for example, the REPowerEU chapters of Belgium, Czechia, Greece, and Poland. 
368   See for example, the REPowerEU chapters of Czechia, Italy, Poland, and Romania. 
369   See for example, the REPowerEU chapters of Greece, Hungary, Malta, Poland, Portugal, and Spain. 
370   See for example, the REPowerEU chapters of Belgium, Croatia Estonia, Italy, France and Spain. 

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reviewing, and updating them. A system of accessible, tailored training aligned with market needs should ensure that specialised workforce is available to 
meet the challenge of the transition to net zero economy371. 

Following the adoption of most REPowerEU chapters in the final months of 2023, Member States will have three years to implement the relevant measures. 
In view of the careful selection of measures for inclusion in the chapters, Member States are optimistic about the timelines for implementation, as evidenced 
by interviews and surveys372. The limited remaining lifetime of the RRF however, which expires on 31 December 2026, has restricted the types of investment 
projects that Member States have selected in their plans, particularly regarding the deployment of technologies and infrastructures that requires a longer 
timeframe. 

EQ5.1: To what extent did external factors have an impact on the RRF roll-out? How this may have had an impact on the Facility’s effectiveness in 
reaching its objectives? 

External factors had a significant impact on the RRF implementation, with implications in terms of revision of the RRF Regulation (with REPowerEU) and 
of revision of the national RRPs which both affected the RRF implementation speed.  

Since the inception of the RRF Regulation in 2021, a range of unforeseeable external factors have made the implementation of the RRF more challenging. 
Russia’s war of aggression against Ukraine led to a spike in energy prices in 2022 and has driven inflation to high levels. Inflation, issues in global supply-
chains and labour shortages have all affected the implementation of many RRF measures across the Member States. More generally, these external factors 
have had an impact on the implementation of the RRF, both as concerns implementation speed and the need to use the Facility to tackle emerging challenges.  

The REPowerEU Plan, presented by the Commission in May 2022 as the EU’s response to the energy crisis, paved the way for an amendment of the RRF 
Regulation less than two years after its entry into force. The RRF became a key tool to deliver on the REPowerEU objectives. It increased the amount of 
EU funds made available to the Member States through the RRF, and enabled Member States to adjust their RRPs by putting forward additional reforms 
and investments  to  rapidly phase-out  the EU’s dependence on Russian fossil fuels,  accelerate the clean energy transition,  support the reskilling of the 
workforce, and address energy poverty. 

371   See for example, the REPowerEU chapters of Czechia, Italy, Poland, Romania. 
372   Evidence in this paragraph is sourced from the supporting study, see pages 114 to 116. 

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Faced with costs increase, supply chain shortages, uncertainty and the need to divert administrative resources to tackle external emergencies, Member 
States found that they could not implement some of the measures as initially planned in their RRPs. This impacted the speed of implementation of the 
Facility and generated a need to introduce targeted revisions to the RRPs (under Article 21 of the RRF Regulation). The revisions of the RRPs (to factor-
in the impact of inflation and supply chain disruptions) and the addition of REPowerEU chapters (as a response to the war in Ukraine and energy crisis) 
are the direct consequences of external factors, which have affected the implementation of the Facility. The first half of the year 2023 has seen a slowdown 
in the submission of payment requests, with Member States focusing their efforts on the revision of plans and the addition of REPowerEU chapters. As a 
result, many Member States with a payment request indicatively planned for the first part of 2023 have pushed back the indicative timing by one to three 
quarters. 

EQ5.2: To what extent did the absorption capacity of Member States affect the RRF effectiveness? 

The risk of negative impact of Member State absorption capacity on the RRF effectiveness has been recognised right from the start of the instrument. When 
the RRF was adopted, several observers373 pointed to the risk of absorption capacity of the significant RRF funding, which would come in addition to the 
remaining EU Structural Funds from the 2014-2020 period, and the new Structural Funds for the 2021-2027 period. The actual payments of structural funds 
depend on the ability of beneficiaries to use the funds, which vary significantly across Member States374. Under the RRF, as payments are made upon the 
fulfilment of milestones and targets (related to both investments and reforms – performance-based approach), the absorption capacity is closely linked to 
the administrative capacity of Member States to implement the pre-agreed agenda of reforms and investments. In this context, the Committee of the Regions 
stressed that many Member States did not sufficiently strengthen administrative capacity at local and regional levels, which  is a precondition to ensure 
proper implementation of the plans and an adequate take-up of the RRF funds. 

In a number of Member States, notably those with pre-existing low absorption rates of EU funds, preliminary findings show that administrative capacity 
remains a significant factor affecting the effectiveness of the RRPs. Member States took action to mitigate the risk via training, reforms and investments 
that aim at modernising the public administration. Yet the results linked to such measures are expected to materialise only in the medium to long term. 
They  also  made  extensive  use  of  the  Technical  Support  Instrument  which  helped  them  build  administrative  capacity  needed  for  the  preparation  and 

373   See Darvas, Z. (2020) Will European Union countries be able to absorb and spend well the bloc’s recovery funding?, available at : https://www.bruegel.org/blog-post/will-european-union-countries-be-
able-absorb-and-spend-well-blocs-recovery-funding; and Alcidi, C., Gros, D., Corti, F. (2020)  Who will really benefit from the Next Generation EU funds?, available at:  https://www.ceps.eu/ceps-
publications/who-will-really-benefit-from-the-next-generation-eu-funds/. 

374   See page 265 of the supporting study. 

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implementation  of  the  RRPs.  The  Commission  also  organised  dedicated  sessions  in  the  RRF  Expert  Group,  supporting  Member  States  to  strengthen 
administrative capacity for the implementation of their RRPs. 

EQ5.3: Have any positive or negative unexpected effects been identified? 

Based on the information provided through surveys and interviews with national and EU authorities, both negative and positive specific unexpected effects 
have been identified. 

Negative unexpected effects  

Since the inception of the RRF Regulation in 2021, a range of unforeseeable external factors have markedly changed the economic and geo-political context 
in the EU and made the implementation of the RRF more challenging. Russia’s war of aggression against Ukraine led to a spike in energy prices in 2022, 
exposing the vulnerabilities linked to the dependence on Russian fossil fuels. It has also driven inflation to levels unseen in decades, increasing price levels 
for all Member States and causing ‘cost of living’ difficulties for many households. The RRF has not been unscathed by the current global events, with 
inflation, issues in global supply-chains and labour shortages affecting the implementation of many RRF measures across the Member States. 

In response to inflation and supply-chain issues, Member States have reacted by (i) using national resources or additional RRF funding to bridge the gap 
between the actual current cost of their measure and what their initial RRF envelope is able to cover, (ii) adapting the targets to the increased costs, (iii) 
replacing investment projects that are no longer feasible from their plans, and/or (iv) postponing the initially foreseen timeline for the implementation of 
milestones and targets. At the same time, applying these changes to the RRPs programming takes some time and the implementation of some measures has 
been put on hold, resulting in delays and an overall slow-down of the implementation. It is important to note however that delays in the submission of a 
payment request  do not  necessarily translate into implementation  delays. The Member States’ on-the-ground implementation  of most investments and 
reforms has continued, as evidenced375 by the number of milestones and targets reported as ‘completed’ by Member States even though not yet assessed 
by the Commission under a formal payment request, even if the submission of a payment request has not followed the indicative timeline. 

Another unexpected effect regards the relation between the RRF and Cohesion Policy funds. While one may argue that several Cohesion Policy experts 
pointed already to the risk of displacement or substitution effect when the RRF was first discussed, this was only partially considered by Member States at 

375   According to data reported by Member States as part of the RRF bi-annual reporting exercise. 

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the phase of drafting the RRPs. Not all Member States adopted ex-ante strategies to create synergies between the two EU funds. It followed a prioritisation 
of the RRF, where mature projects (expected to be implemented under 2021-27 Cohesion Policy programmes) were shifted into the RRPs (for instance, in 
Spain, Greece, Italy and Romania – see EQ 20.1). In addition, some Member States (e.g., Slovenia) have redirected staff previously dealing with Cohesion 
Policy to the RRP coordination and implementation bodies to accelerate RRP implementation, delaying the implementation of Cohesion policy (although 
Slovenia’s absorption of Cohesion Policy has always been low in initial years of a new multi-annual financial framework).  

According to national coordination bodies, the RRF was initially expected to be a more flexible and agile instrument compared to Cohesion Policy funds, 
especially due to the new performance-based approach. However, the majority of national stakeholders observe that the RRF has generated an increase in 
the workload of administrations at both national and local levels. Despite efforts to strengthen administrative capacity, Member States did not systematically 
manage to mitigate this increase. Member States that experience administrative and staff shortages have noted that the administrative burden has resulted 
in delays affecting RRP implementation. 

Moreover, the fixed composition of each instalment has been reported to slow down RRF disbursements. The RRF Regulation requires Member States’ 
RRPs to propose a combination of reforms and investments and link them to instalments. The purpose is to avoid “cherry picking” and ensure a balanced 
progress of both reforms and investments, including when political challenges emerge ahead of difficult structural reforms. Stakeholders however report 
that Member States avoid submitting payment requests before all milestones and targets envisioned for the specific instalment have been fully completed, 
which can lead to significant delays in payments if only one or a few of the milestones and targets are pending376. During the stakeholder interviews, 
national authorities accompanied this problem description with a call for more flexibility in  (re)grouping milestones and targets for a specific payment 
request. At the same time, it also has to be noted that in February 2023, the Commission published a methodology for partial  suspension of payments, 
which provides more transparency on the suspended amounts. The suspension procedure thus gives more flexibility to Member States who can (and do) 
now submit payment requests where not all milestones and targets have been fulfilled (yet). 

Finally, the administrative work required at national and sub-national level to implement the RRF is higher than initially expected by Member States377. 
Some Member States have not been able to mitigate the increase in the workload of administrations observed at both national and local levels378. Overall, 

376   See page 54 of the supporting study. 
377   See pages 124 to 125 of the supporting study. 
378   See page 125 of the supporting study. 

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Member  States  that  experience  administrative  and  staff  shortages  have  noted  that  the  administrative  burden  has  resulted  in  delays  affecting  RRP 
implementation.  Research379  illustrates  how  low  administrative  capacity,  especially  at  local  level,  can  affect  the  implementation  of  RRF-supported 
investments. The authors analysed the implementation of investments supported by the RRF in ‘Early Childhood Education and Care’ in four Member 
States (Italy, Spain, Germany and Portugal), which are traditionally run at local level. They found that two key obstacles in implementation relate to (i) the 
lack of support/technical assistance to local authorities to develop projects’ proposals; and (ii) the lack of personnel especially at local level. 

Positive unexpected effects  

In terms of unexpected positive effects, the results of the surveys show that the RRF has contributed (partially or to a large extent) to improving inter-
institutional coordination in the design of national reforms (72% of respondents) as well as in the design/quality of investments (84%). For instance, in 
Slovenia, the RRP implementation led to unforeseen benefits, such as heightened stakeholder focus on performance and efficient implementation within 
tight timeframes. In Austria, the RRP set a benchmark for national initiatives, particularly with respect to performance-based funding, serving as a valuable 
case study for the Member State's initiatives. In addition, relying on national implementing bodies with experience in EU funds proved more useful than 
expected. Stakeholders also conveyed that the performance-based approach brought predictability and accountability, resulting in a “cultural shift” in policy 
planning and implementation.  

The implementation of the RRF has also triggered some positive effects in terms of EU governance. With the RRF, the Commission and Member States 
have established a regular dialogue, based on the bottom-up nature of the instrument. This engagement has been built on more than ten years of European 
Semester experience, while becoming more comprehensive, detailed and practical in the context of the Commission’s responsibilities for assessing RRPs 
and  the  related  payment  requests.  Overall,  stakeholders  conveyed  that  the  Facility  has  brought  a  deeper  engagement  between  Member  States  and  the 
Commission on investments and reforms compared to the pre-2021 European Semester. 

Another external, though not fully unexpected effect: researchers assign the RRF a positive effect on reducing the risks associated with sovereign-bank 
loops in the context of the COVID-19 crisis. Stylised simulations380 show that the crisis response policies of the EU strongly mitigated the risks associated 

379   Corti,  F.,  Marobito,  C.,  Ruiz,  T.,  and  Luongo,  P.  (2022)  The  role  of  the  Recovery  and  Resilience  Facility  in  strengthening  childcare  policies,  available  at:  https://feps-europe.eu/wp-

content/uploads/2022/07/RECOVERY-WATCH-Childcare-Policy-PP-1.pdf. 

380   See Quarterly Report on the Euro Area (QREA), Vol. 20, No. 3 (2021), available at: https://economy-finance.ec.europa.eu/publications/quarterly-report-euro-area-qrea-vol-20-no-3-2021_en.  

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with sovereign-bank loops381 in euro area countries in connection to the COVID-19 crisis. Together with the monetary policy measures taken by the ECB, 
the RRFs coordinated policy response contributed to macro financial stability in the aftermath of the COVID-19 pandemic, providing a structural policy 
commitment and financial safety net that avoided heightened market pressure on public finances and potential financial risks. 

EQ6: How does the effectiveness of the RRF compare with that of other EU programme and instruments, notably cohesion funds?  

The current early stage of implementation of the RRF limits the possibility of drawing strong conclusions about its effectiveness in comparison to other 
EU programmes and instruments, notably Cohesion Policy funds. A comparison of early data on common indicators and levels of disbursement under the 
RRF and Cohesion Policy offers some insights presented in the case study dedicated to this topic in the supporting study. However, a more complete 
assessment inevitably requires evidence deriving from the effects generated over time by the RRF.  

At the same time, it is possible to identify factors that influence the RRF’s effectiveness in a different and more marked way than Cohesion Policy. These 
are: a stronger link with reforms; a generally higher prioritisation from the political level (although not in all Member States); a deeper scrutiny by the 
media.  

Under Cohesion Policy, the importance of linking investments to enabling frameworks and structural reforms was already embedded, for instance, through 
the  necessary  fulfilment  of  ex-ante  conditionalities  (evolved  into  enabling  conditions)  as  a  prerequisite.  However,  Cohesion  Policy  does  not  finance 
structural reforms (with some exception of targeted public administration reforms with an associated cost)382. Interviewees from a broad range of institutions 
(among which national authorities, the Committee of the Regions and the Economic and Social Committee) recognised the RRF support for structural 
reforms as a crucial asset of the RRF and highlighted that it effectively filled a gap compared to the status quo383.  

381   See  Fontana  A.  and  S.  Langedijk  (20 9),  ‘The  Bank-Sovereign  Loop  and  Financial  Stability  in  the  Euro  Area’  in  JRC  Working  Papers  in  Economics  and  Finance  2019/10,  available  at 

https://data.europa.eu/doi/10.2760/81563.  

382   Such as the targeted reforms of labour market institutions and services under the ESF+ if they have an associated cost. 
383   See the case study on the functioning of the RRF and other EU funds included in the supporting study. 

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EQ7: How visible has the Recovery and Resilience Facility been to the public? How was the instrument perceived by the public, by Member States 
and by beneficiaries? 

Results of the Eurobarometer survey (in December 2022) show that across the EU around 51% of the respondents were aware of a Recovery Plan for their 
Member State to support economic recovery and 33% have seen, heard or read something about NGEU. Around 36% of the respondents think that their 
Member State’s RRP is financed partially through NGEU and about one in six think the plan is entirely financed through NGEU. More than 90% of all 
respondents of the public consultation indicated that they are aware of the existence of the RRF, but a majority overall suggests that the financing has only 
been somewhat visible. There is a range of factors influencing its visibility, such as the size of the plan, political ownership, government communication, 
and stakeholder involvement. 

EQ8: What have been so far the most effective aspects of the RRF (cf. speed of disbursements, implementation of long-standing/awaited/difficult 
reforms?) What has been the least effective? 

The RRF’s ability to support the implementation of reforms is considered as one of the most effective features of the instrument by most stakeholders and 
has proven to be a key tool to deliver on the European Semester’s CSRs. There is unanimous agreement between Member States and the various EU 
institutions,  including  the  European  Parliament  and  the  ECA,  that  the  RRF  has  been  effective  in  supporting  CSR-related  reforms.  Most  stakeholders 
interviewed also confirm that the RRF contributed to putting on the agenda long-awaited reforms linked to the CSRs, that would have otherwise had little 
chance of being enacted and implemented. The RRF has significantly accelerated policy action to address the CSRs, which, in the past, was considered 
weak.  

The conditionality of payments upon fulfilment of milestones and targets rather than costs incurred and the definition of a clear timeline for reforms and 
investments – at the core of the RRF performance-based approach – is also considered as an effective aspect of the RRF. A high level of ownership is 
indicated as a positive aspect in increasing the RRF effectiveness, especially when it comes to reform implementation. Moreover, the RRF has been effective 
in disbursing its funds quickly post-crisis, notably thanks to pre-financing. Member States also recognise the ‘Do No Significant harm’ (‘DNS ’) principle 
as a new feature that has strengthened the ‘green’ dimension of RRF reforms and investments and helps achieve the RRF’s green objectives. 

Regarding the less effective aspects: Member States have conveyed that aspects reducing the efficiency of the Facility’s implementation sometimes also 
reduce the RRFs’ effectiveness. For example, Member States reported on the high workload stemming from different audit and control requirements related 

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to the RRF, where administrative costs linked to RRF implementation are reported to exceed those initially expected by some Member States. Audit and 
control  procedures  are  considered  complex  by  stakeholders  and  there  is  a  perceived  overlap  between  controls  and  audits  by  national  authorities,  the 
Commission and the ECA. Consultation responses suggest that this requires the allocation of resources that could otherwise have been dedicated to the 
swift implementation of the plans, thereby hampering an effective implementation of the RRF. Member States therefore see room for simplifying control 
and audit procedures, ensuring better coordination among the actors involved and avoiding multiple checks.  

Member States also stress that the specific design of the RRF has led to less flexibility in the implementation than initially expected. The RRF Regulation 
requires a detailed definition of milestones and targets  in  the design  phase and subsequent  revisions of RRPs, leaving  little room for flexibility  in the 
Commission’s assessment of milestones and targets. 

Efficiency 

EQ9: How do the cost (inputs) of the Facility compare with the RRF outputs, results and impact? 

In the absence of a counterfactual, quantifying the ‘benefits’ of the RRF to compare them to the ‘costs’ requires using macroeconomic models to estimate 
the benefits of the RRF. The results of the macro-economic simulations, both in the evaluation study (NiGEM model) and by the Commission (QUEST 
model), provide  estimates of the benefits that can be expected. However, it is too early to go further at this stage and a full cost-benefit analysis will be 
conducted as part of the ‘ex-post’ evaluation. 

Under the QUEST scenario (i.e. 100% additionality for grants and 50% additionality on loans), the analysis using NiGEM shows that the cumulative impact 
on EU GDP by 2041 of the RRF funds disbursed up to end July 2023 is expected to be almost twice as large as the value of these disbursed funds. The 
analysis suggests further that the cumulative impact on EU GDP by 2041 of the entire RRF package of grants and loans has the potential to exceed twice 
the total RRF funds. Both the non-discounted and discounted values of the benefit-cost ratios calculated at the EU level and considering all the planned 
RRF funds are a little over two. However, if different assumptions on additionality are considered, the benefit-to-cost ratio would change. Under a scenario 
where 60% of RRF funds are used for additional public investment within the Southern and Eastern Member States with lower GDP, but only 25% of RRF 
funds are used for additional public investment in the Northern and Western Member States with higher GDP, the benefit-cost ratio falls below one; that is 
the cumulative effect on EU GDP becomes lower than the total RRF funds disbursed. However, these simulations do not account for the long-run GDP 

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effects of the structural reforms within Member States’ RRPs, which are hard to measure at this point in time, particularly given the length of time over 
which the benefits will come to fruition, but which could potentially be substantial. 

As concerns administrative costs, there are significant variations across Member States in full-time employment (FTE) declared by coordination bodies 
both for one-off activities and recurrent activities. No clear trends emerge. Indeed, the variations are influenced by several concurrent factors related to the 
availability of data, the governance of the RRF and the degree of outsourcing. 

In many Member States, the FTEs working on plan amendments (including the REPowerEU chapters) are comparable and in some cases even higher than 
the FTEs for drafting the actual RRPs. According to most respondents (72%) in the survey, the costs linked to the RFF implementation have increased over 
time, while only 28% reported stable costs. The majority of respondents attribute the cost increase to more stringent application of requirements (particularly 
in reporting, control, and audit) than expected.  

EQ10: How did the instrument’s governance affect the efficiency of the RRF, including the reporting/performance management systems? 

Two main factors explain the impact of national RRF governance structures on the efficiency of the instrument: the degree of centralisation of the decision-
making process and the reporting/performance management system.  

While the RRF is implemented with the help of centralised governance structures  in all Member States, differences emerge in the governance settings 
which affect the efficiency of the RRF. The first difference regards the involvement of the Prime Minister’s office, which tends to be correlated with a 
smoother implementation  of the plans due to  increased political  ownership and enhanced capacity to  steer internal  decision-making processes. This is 
particularly the case for reforms. . The second difference regards the involvement of social partners, especially when it comes to the labour market or social 
policy reforms, where their involvement played a key role in speeding up the adoption process. Third, the different degree of involvement of sub-national 
authorities in the drafting and implementation of the plans affects the efficiency of the implementation of the plans, in particular investments.  

EQ11: How do the costs/burden of the RRF compliance compare with those of other instruments, notably Cohesion Policy funds, also considering the 
costs of audits and controls, as well as of data collection? 

Some stakeholders (mostly national authorities) consider the cost/burden associated with RRF compliance to be as, or even more, demanding than other 
programmes. While the RRF could, in principle, be expected to lead to a reduced administrative burden compared to Cohesion Policy funds (especially 

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through its performance-based approach), there is currently no conclusive evidence supporting this claim. Overall, the administrative costs/burden of the 
RRF are considered to be comparable to those of the Cohesion Policy funds. This perception however varies across Member States. This is because, while 
Member States need to demonstrate the fulfilment of milestones and targets (as disbursements are based on performance) – a process that is perceived as 
very demanding by Member States – Member States are still required to collect evidence of the expenditure incurred, as well as data on final recipients and 
RRF funds paid under the RRF, for audit and control purposes. This may be exacerbated by the coexistence of the two EU funding instruments (RRF and 
structural funds) with two different approaches (performance-based and costs-based). Many Members States have explained during the consultations that 
they finally have to gather both evidence (on the fulfilment of milestone and target and on costs incurred). According to the national authorities, these 
requirements to protect the financial interests of the Union lead to a similar administrative burden of other EU funds based  on costs, such as Cohesion 
Policy funds. More generally, the administrative costs linked to RRF implementation are reported to exceed those initially expected by some Member 
States, notably because of audit and control and reporting obligations.  

EQ12: Can any unnecessary administrative burden and complexity be identified? To what extent is there scope for simplification? 

Feedback from stakeholders suggests that the various reporting requirements under the RRF (reporting on the achievement of milestones and targets; bi-
annual reporting; reporting in the context of audits; reporting on the common indicators) affects the efficiency of the instrument, with some Member States 
calling for simplification. Member States argue there is room for simplifying bi-annual reporting by removing the requirement to report when a Member 
State already submits two payment requests per year.  

Stakeholder consultation suggests that several national coordination bodies consider that the common indicators, while anchored in the Regulation, have 
limited added value as they are not directly linked to tracking results of reforms and investments.  

Member  States  also  conveyed  a  perception  of  rigidity  in  the  interpretation  of  milestones  and  targets  fulfilment  by  the  Commission,  even  though  the 
Communication of February 2023 was acknowledged as an important step to clarify the margins of manoeuvre for Member States, especially when it comes 
to investments. The procedure for amending RRPs is also seen as burdensome and overly complex by some stakeholders. 

Stakeholder  consultation  suggests  that  complex  audit  and  control  systems  negatively  affect  the  efficient  implementation  of  the  RRF,  with  calls  for 
simplification. In stakeholder consultations, Member States reported on the high workload stemming from different audit and control requirements related 
to the RRF. At the same time, audit and control procedures are considered complex by stakeholders and there is a perceived overlap between controls and 

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audits  by  national  authorities,  the  Commission  and  the  ECA.  Consultation  responses  suggest  that  this  requires  the  allocation  of  resources  that  could 
otherwise have been dedicated to the implementation of the plans. Member States therefore see room for simplifying control and audit procedures, ensuring 
better coordination among the actors involved and avoiding multiple checks. 

Finally, in the view of the Member States, simplification of the informal dialogue process with the Commission can come from accelerating the time to 
provide answers and reducing the rounds of comments from the Commission to Member States on the documentation submitted for payment requests. 

EQ13: To what extent have there been efficiency gains from pursuing reforms and investments together under one instrument? 

While it is generally considered premature to assess the overall efficiency gains resulting from the simultaneous pursuit of reforms and investments within 
a single instrument, 59% of survey respondents believe that combining reforms and investments in one instrument leads to some or significant efficiency 
gains. This is because coordinating the two becomes simpler when planned in one document and encourages Member States to undertake reforms that will 
enhance the impact of investments.  

Coherence 

EQ14: To what extent was the RRF coherent with the Technical Support Instrument? 

There is a high level of coherence between the RRF and the Technical Support Instrument (TSI). The TSI offers both general and thematic support, covering 
horizontal  areas  important  for  RRP  implementation,  such  as  project  management,  reporting,  governance  structures,  and  policy-specific  interventions. 
Coherence between the RRF and the TSI is due to built-in synergies between the two instruments and the alignment of their assessment criteria. The RRF 
Regulation actively promotes synergies between the RRF and TSI by enabling Member States to allocate up to 4% of their total allocation to technical 
support in RRP implementation, an option used by four Member States. The alignment of the assessment criteria of the RRF and of TSIs emphasise that 
both instruments have the same policy objectives and that their priorities are aligned. For example, the relevance of CSRs is one of the assessment criteria 
used both for selecting TSI projects and for approving RRPs. The coherence of the two instruments is evident in the fact that over 400 projects approved 
under the TSI are linked to the preparation or implementation of Member States’ RRPs, highlighting the crucial role of TSIs in the Facility. 

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EQ15: To what extent has the RRF been integrated into the broader country-specific surveillance under the European Semester? To what extent 
have National Reform Programmes been used as a reporting tool for the RRF? 

The implementation of the RRF has been integrated in the European Semester, with reporting processes streamlined to limit the administrative burden both 
at national and Commission level. The European Semester and its national reform programmes offered a platform for the bi-annual reporting under the 
RRF. The national reform programmes have been used by all Member States – with few exceptions – to report on the implementation of the RRPs. Yet, 
important differences emerge across Member States in the level of details of reporting. At the same time, the European Semester, and in particular the 
Country  Reports,  have  been  the  key  tool  for  the  European  Commission  to  regularly  report  on  the  monitoring  of  RRP  implementation,  making  the 
implementation  of  the  RRF  a  key  part  in  EU  economic  coordination  and  surveillance.  The  2022  and  2023  European  Semester  both  focused  on  the 
implementation of the RRPs, with CSRs focusing on the implementation of each Member States’ RRPs. In that sense, the RRF has been implemented in 
full coherence with the European Semester, limiting to the extent possible the increase in administrative burden that reporting on RRF implementation 
places on both national administrations and the EU.  

The RRF is in line with the European Semester priorities and has provided a novel and significant incentive to reinforce the implementation of CSRs. First, 
the European Semester provides a framework for the preparation of RRPs. In turn, the RRF offered financial incentives to implement the policy advice 
given under the Semester and has reinforced the implementation of the CSRs. In other words, the RRF contributed to strengthening the link between EU 
funds and the European Semester, which in turn contributed to bringing long-awaited structural reforms into fruition, across a wide range of policy areas. 

EQ16: To what extent have EU’s priorities guided the reforms and investments put forward by Member States in their recovery and resilience plans? 

The scope of the RRF (defined along the six pillars) supports the implementation of reforms and investments in areas that have been identified as EU 
priorities, notably the green and digital transitions and the European Pillar of Social Rights. The binding climate and digital targets for the RRPs ensure 
that a large part of funds is dedicated to fostering the green and digital transitions. 

The European Semester provided a framework for the preparation of RRPs. RRPs were “expected to contribute to effectively addressing all or a significant 
subset of challenges identified in the relevant country-specific recommendations” adopted in the context of the European Semester. All RRPs were assessed 
against this criterion and needed to reach the highest (‘A’) rating for their plan to be approved. In this sense, EU priorities – tailored to Member States’ 
needs – guided the reforms and investments put forward in RRPs.  

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EQ17: To what extent have complementarity effects and synergies between the RRF with other EU programmes and instruments (such as Cohesion 
Policy funds) been identified and exploited? 

Member States have put in place four approaches to demarcation between RRF and Cohesion Policy funds: (i) a thematic demarcation; (ii) a territorial 
demarcation; (iii) a demarcation based on the typologies of beneficiaries; and (iv) a temporal demarcation. The most frequently adopted approach has been 
of thematic nature, but Member States have de facto adopted a mix of demarcation approaches.  

While demarcation strategies are key to avoiding overlaps between the two instruments, they can, but do not necessarily ensure synergies. In this regard, 
obstacles consist, among other things, in the thematic overlap; the implementation of RRPs being prioritised over 2021-2027 Cohesion Policy funds, to 
ensure rapid absorption of EU funds in general; in some cases, different governance systems. There is however a large potential for synergies between the 
RRF and Cohesion Policy and a number of Member States have seized the possibility to use the two funds  to support different segments of the same 
investment or to support complementary measures. Synergies can also be achieved when reforms supported by the RRF benefit investments supported by 
structural funds (or national funds). 

As the implementation of the RRF progresses, synergies and complementarities between RRF-supported reforms and Cohesion Policy investments will 
come into focus. Sectoral, structural or enabling reforms supported by the RRF innovate the context in which public investments, including those funded 
by Cohesion Policy, are embedded. In turn, the Cohesion Policy makes financial resources available to put the revised framework to good use, promoting 
investments on the ground. 

EQ18: To what extent were RRF/RRPs coherent/complementary with relevant Member States’ instruments aiming to support the economic recovery 
after the COVID-19 crisis? 

The RRPs were implemented in coherence with Member States’ national recovery strategies. Coherence/complementarity has been largely ensured by three 
factors: 1) in Member States that had already put in place a post-pandemic recovery plan by the time the RRF was created, the RRP built on, or integrated, 
the already planned measures and either replaced or further expanded them (since the RRF allowed to support measures that started from 1 February 2020); 
2) in Member States that did not yet have a recovery plan in place at that time, the RRPs became the national plans for the recovery after the pandemic; 3) 
in both cases, the relatively short time span during which the RRPs were drafted by most Member States together with the medium-term horizon of the 

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RRF implementation (until 2026), allowed national authorities to develop RRPs that were coherent with the already existing or planned investments and 
reforms. 

EQ19: To what extent have reforms and investments in the plans been complementary and mutually reinforcing? 

The RRPs also provided for a coherent set of reforms and investments. The internal coherence of the measures put together by Member States in their RRPs 
was a criterion evaluated by the Commission when assessing the plans. The overall Commission assessment on the coherence of RRPs is very positive 
(high extent – Rating A), with the exception of the Belgian, Czech and Estonian RRPs who received a rating of B. The findings are in large part corroborated 
also by the analysis carried out in the case studies, with a zoom on a selected sample of Member States to assess the degree of complementarity between 
reforms and investments in the RRPs. The combination of reforms and investments under one sole instrument is considered by stakeholders as one of the 
most effective aspects of the RRF. 

EU Added Value 

Overarching question: EQ20: What has the RRF provided over and above what Member States actions and funding could have achieved?  

In the absence of a counterfactual, the additionality of the RRF is difficult to quantify. However, at the mid-term point, qualitative evidence already provides 
a first hint regarding the EU added value of the instrument.  

The unprecedented scale of the RRF’s financial support (up to EUR 723.8 billion in total for 2021-2026 and additional REPowerEU resources with EUR 
20 billion in new non-repayable support and EUR 2.1 billion of funds from the Brexit Adjustment Reserve) is an important element to take into account 
when assessing the additionality of the instrument.  

With its pre-financing, the RRF also provided Member States with significant fiscal space in the aftermath of the COVID-19 pandemic, thereby playing a 
stabilising effect at that critical juncture. Unlike other crises, the level of public investment has been preserved in the EU post-COVID and has increased 
in a number of Member States (see Section 4.1.4). Moreover, although reducing spreads was not per se one of the objectives of the RRF, it has been an 
important positive side effect, which helped mitigation risks of financial fragmentation. 

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The additionality of the RRF in individual Member States is correlated to the size of the financial support provided. A relevant proxy is the RRP allocation 
as a share of GDP, which varies from 16.68% in Greece to 0.11% in Luxembourg. For Member States where the RRF represents an important share of 
GDP, the RRF provided additional fiscal space to implement investments that would otherwise have been unlikely. More generally, the additionality of the 
RRF highly depends on Member States’ specific situations, in particular on whether the Member State already had in place a national recovery plan when 
the RRF entered into force. 

By design, the RRF is expected to strengthen economic convergence in the EU. With its allocation key, the RRF was designed to support lower-income 
and more vulnerable Member States, which had also been hit the hardest by the pandemic. The RRF is also expected to trigger spillover effects that are 
benefiting the Single Market. With its large financial support, the effects of RRF spending in one EU Member State have positive spillover effects in the 
rest of the European Union (intra-EU trade).  

Cross-border projects also contribute to increasing potential spill-over effects fostered by the RRF. Corti et al. (2022)384 consider that these spillover effects 
are particularly relevant in the areas of green transition and digitalisation as neighbouring Member States benefit from investments in transport or digital 
infrastructure or other aspects concerning digital transformation, such as broadband expansion and 5G. While the RRF contributed to the implementation 
of multi-country projects, some authors consider that the impact and full potential of such projects could have been better exploited. An analysis of selected 
cross-border projects focusing specifically on IPCEIs provides some more evidence towards challenges in the implementation of multi-country projects 
due to the coordination efforts they imply. It should be noted that cross-border projects, particularly IPCEIs, contribute to the Union’s objectives and their 
importance is specifically reflected in providing a comparative advantage to European companies by pooling skills and know-how. Due to their cross-
border nature, as well as their strategic role in fostering cooperation in strategic industrial sectors and potential contribution to green and digital transition, 
they hold potential to strengthen the resilience of industrial ecosystems and deepen the Single Market. 

With its large financial envelope, the RRF provided substantial funding to advance the implementation of common EU policies. The binding climate and 
digital targets for the RRPs, which required Member States to allocate respectively 37% and 20% of RRF funds to projects supporting the climate and 
digital transitions, ensure that at least half of RRF funds are dedicated to fostering the green and digital transitions, among other priorities. The RRF also 
contributes to the implementation of the European Pillar of Social Rights, which is one element of the RRF general objective: the scope of the RRF includes 

384   Corti, F., Gros, D., Liscai, A., Ruiz, T., Kiss-Galfalvi, T., Gstrein, D., Herold, E., Dolls, M., and Fuest, C. (2022) The European added value of the Recovery and Resilience Facility: An assessment of 

the Austrian, Belgian and German plans, available at: https://www.europarl.europa.eu/RegData/etudes/STUD/2022/699513/IPOL_STU(2022)699513_EN.pdf 

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social cohesion and policies for the next generation, and social aspects are also covered by the country-specific recommendations that Member States are 
addressing in their RRPs, ensuring that measures supported by the RRF also support this EU priority. The RRF has helped speed up the implementation of 
long-standing and politically challenging reforms. In particular, the RRF supported the implementation of reforms that had been the subject of long-standing 
CSRs in the context of the European Semester, i.e. they were recommended by the Council as the most important reforms to be tackled in each Member 
State. Progressing on these EU priorities represents EU value added. This has included reforms that would have most likely not have taken place without 
the RRF, such as rule of law reforms and structural reforms (e.g. long-standing CSRs such as long-term care in Slovenia and the reform concerning regulated 
professions  in  Portugal).  The RRF brought  a new dimension to  EU funding  instruments  by  making the financing  of investments  conditional upon the 
implementation of reforms.  

The RRF provided EU added value as it enabled the simultaneous implementation of reforms and investments across the EU, which created additional 
impact. The simultaneous implementation of the RRPs in each Member State created additional impact with spillover effects. Along the same lines, the 
simultaneous implementation of structural reforms that were tailored to  Member States needs creates additional impact,  as the overall impact of these 
individual reforms is economically more beneficial when conducted by several/all Member States (e.g. labour markets reforms) than when conducted in 
isolation. The RRF amplified this joint and coordinated response.  

EQ20.1: Have substitution effects with national policies/programs and/or with other EU funded programmes been identified and if so, to which 
extent? 

Some risks of substitution effects between RRF and Cohesion Policy have materialised. The risk of possible substitution effects between the RRF and 
Cohesion Policy was only partially considered by Member States when drafting their RRPs. Evidence of substitution effects generated by the RRF to the 
detriment of Cohesion Policy was not found with regard to 2014-20 programmes, as they were already well underway at the time the RRF was launched. 
Interviewees, however, highlighted substitution effects for 2021-27 programmes. When RRPs were submitted in 2021, most Operational Programmes under 
Cohesion for the period 2021-2027 were not designed yet. Several Member States did not adopt ex-ante strategies to create synergies between the two EU 
funds. Some more mature projects (e.g. in Spain, Greece, Italy and Romania) that were previously planned under Cohesion instruments were moved into 
the RRPs. The reverse was also the case, with examples of some investments, initially introduced in the RRPs, moved to Cohesion instruments during the 
RRPs revisions. In addition, some Member States (e.g. Slovenia) have redirected staff previously working on Cohesion Policy to the RRP coordination and 
implementation bodies to accelerate RRP implementation, further delaying the implementation of Cohesion Policy (Slovenia’s absorption of Cohesion 
Policy has always been low in initial years of a new multi-annual financial framework).  

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EQ20.2: To what extent have the EU’s advantageous borrowing conditions and the impact that the RRF had on reducing spreads of EU Member States 
at its creation, contributed to the benefits of the RRF? 

The funding strategy to finance the RRF, and NextGenerationEU (‘NGEU’) more generally, is outside the scope of this evaluation. 

Although reducing spreads was not per se one of the objectives of the RRF, it has been an important positive side effect. The announcement of the RRF 
has  contributed  to  reducing  sovereign  bond  spreads  in  the  EU  at  the  time  of  the  COVID  shock,  which  in  turn  helped  mitigating  risks  of  financial 
fragmentation  and  supporting  the  recovery.  To  examine  the  effects  of  the  announcement  on  spreads  of  NGEU  and  its  core  instrument,  the  RRF,  the 
supporting study385386 measured the impact on spreads as ‘the initial decline in sovereign bond spreads that was recorded within three weeks of the 18 May 
2020 announcement of the initial Franco-German proposal for a recovery fund’ (taken at the moment announcing the upcoming NGEU). The results show 
that a reduction in the spread of benchmark bond yields over the benchmark, being German Bundesanleihen, between 15 May 2020 (April for monthly 
data) and 5 June 2020 (June for monthly data) for almost all EU Member States387. There was a reduction of between 50 and 100 basis points for those 
Member States higher borrowing costs. 

Specifically, the reduction in spreads has led to an improvement in the public finances in some EU Member States and, by improving financing conditions 
for the household and corporate sectors, it will likely lead to increased investment and GDP in the future. At the same time, the reduction in spreads helped 
to mitigate the risk that the COVID shock would lead to financial fragmentation with borrowing rates varying more widely across EU Member States.  

Furthermore, by using RRF loans to finance spending that would otherwise have been financed domestically, those Member States with relatively high 
borrowing costs have been able to take advantage of  lower borrowing conditions to reduce the costs associated with the increased borrowing that has 
resulted from the COVID shock.  

385   Following the approach by Bankowski, K., Bouabdallah, O., Domingues Semeano, J., Dorrucci, E., Freier, M., Jacquinot, P., Modery, W., Rodríguez-Vives, M., Valenta, V., and Zorell, N. (2022) The 

economic impact of NextGenerationEU: a euro area perspective, available at: https://www.ecb.europa.eu/pub/pdf/scpops/ecb.op291~18b5f6e6a4.en.pdf.  

386   Evidence in this paragraph is sourced from the supporting study, see pages 177 to 178. 
387   excluding Estonia (for data availability reasons) and Germany (where the spread is zero by definition). 

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EQ20.3: To what extent did the Facility contribute to the implementation and further development of multi-country projects? 

An overview of RRPs shows that numerous RRPs include measures participating in a number of multi-country projects388, with most projects contributing 
to the green and digital transition. More than half of the RRPs include measures contributing to multi-country projects or cross-border initiatives related to 
the  green  transition,  with  the  IPCEI  on  hydrogen  exhibiting  the  highest  uptake.  The  second  biggest  contribution  is  seen  in  the  area  of  the  digital 
transformation,  where  most  RRPs  also  include  measures  contributing  to  multi-country  projects  or  cross-border  initiatives.  Here,  the  IPCEIs  on 
microelectronics  (12  RRPs)  and  cloud  technologies  (six  RRPs)  are  amongst  the  multi-country  projects  with  the  highest  take-up  in  RRPs.  Further 
contributions  towards  the  digital  transformation  are  also  seen  in  cloud  technologies  (with  six  RRPs  including  IPCEI  measures),  the  European  Digital 
Innovation Hubs (eight RRPs), 5G corridors (seven RRPs) and quantum communication (four RRPs).  

The support from RRF funds enabled a widened pool of Member States implementing multi-country and cross-border projects. There is a growing number 
of  Member  States  participating  in  multi-country  projects  (most  noticeably  IPCEIs),  especially  in  Central  and  Eastern  Europe389.  The  scope  of  IPCEIs 
(notably hydrogen) would have likely been lower in the absence of the RRF funds and the Facility has provided a source of funding for Member States and 
an  opportunity  to  integrate  IPCEIs  in  national  programmes390.  The  availability  of  RRF  funds  has  enabled  greater  participation  levels  in  multi-country 
projects, with the inclusion of Member States who would not have participated otherwise391. 

However, while theoretically cross-border projects carry huge potential for advancing the competitiveness of the European economy, Corti et al392 argue 
that only a minor share of RRF-supported cross-border projects had so far an effective cross-border impact. This can mainly be attributed to the complexity 
of cross-border projects, which require more time in design and see more challenges in implementation due to the multi-partner component. Specifically, 

388   European Commission (2022) Report from the Commission to the European Parliament and the Council on the implementation of the Recovery and Resilience Facility (COM(2022) 75 final), available 

at: https://commission.europa.eu/system/files/2022-03/com_2022_75_1_en.pdf.  

389   Eisl,  A.  (2022)  Important  Projects  of  Common  European  Interest  (IPCEIs)  as  a  New  Form  of  Differentiation:  An  Analysis  of  Their  Challenges  for  the  European  Single  Market,  available  at: 

https://euidea.eu/wp-content/uploads/2022/03/euidea_pp_18.pdf.  

390   According to stakeholders interviewed as part of the case study on cross-border and multi-country projects, with specific focus on IPCEIs; see pages 145 to 149 of the supporting study and the case study 

on cross-border and multi-country projects, with specific focus on IPCEIs. 

391   See Dias, C., Grigaitè, K., and Cunha, I. (2021) Recovery and Resilience Plans – Thematic overview on cross-border projects, available at: 

https://www.europarl.europa.eu/RegData/etudes/IDAN/2021/689472/IPOL_IDA(2021)689472_EN.pdf; and Eisl, A. (2022) Important Projects of Common European Interest (IPCEIs) as a New Form 
of Differentiation: An Analysis of Their Challenges for the European Single Market, available at: https://euidea.eu/wp-content/uploads/2022/03/euidea_pp_18.pdf. 

392   See Corti, F., Gros, D., Liscai, A., Ruiz, T., Kiss-Galfalvi, T., Gstrein, D., Herold, E., Dolls, M., and Fuest, C. (2022) The European added value of the Recovery and Resilience Facility: An assessment 

of the Austrian, Belgian and German plans, available at: https://www.europarl.europa.eu/RegData/etudes/STUD/2022/699513/IPOL_STU(2022)699513_EN.pdf. 

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IPCEIs typically present challenges in fostering cooperation beyond the conventional value stream with supply partners or customer partners due to antitrust 
rules that restrict the sharing of processes and developments with competitors. 

EQ20.4: To what extent did the RRF contribute to maintaining the level-playing field and strengthening the Single Market? 

While  it  is  too  early  to  draw  clear  conclusions  on  the  extent  to  which  the  RRF  has  contributed  to  maintaining  a  level-playing  field  in  the  EU  and  to 
strengthening the Single Market, a few relevant considerations can be made.  

First, the RRF supports the implementation of reforms that strengthen the Single Market, such as reforms issued in the context of the European Semester 
to support the business environment or competitiveness, as well as reforms on regulated professions (for example in Portugal). The RRF’s support for 
measures addressing SMEs needs also plays a role in strengthening the Single Market.  

Second, the implementation of all measures in the RRPs has to be performed by Member States in line with EU law, thus supporting the spillover impact 
of national plans, as EU business have access to all Member States. 

Third, the RRF support for cross border projects, and notably through the IPCEI projects included in RRPs, also plays an important role in supporting the 
Single Market. In particular, researchers393 argue that the RRF contributes to significantly lowering the entry barriers for Member States to participate in 
IPCEIs by giving smaller Member States with comparatively fewer budgetary capacities an opportunity to completely finance or at least co-finance IPCEIs 
with European money instead of having to rely exclusively on their national budgets.  

EQ21: To what extent did the simultaneous implementation of reforms and investments across Member States create EU added value? 

The simultaneous implementation of reforms and investments across Member States created EU added value notably by increasing the scale and level of 
ambition of the implemented measures. As noted in EQ19, there has been complementarity and coherence between reforms and investments in the RRPs, 
which is illustrated in the case studies. Constructing a counterfactual scenario at EU/national level where so many reforms and investments are not pursued 
simultaneously is not attainable. Nevertheless, the five Member State authorities that provided answers to this question on EU added value via the additional 

393   See  Eisl,  A.  (2022)  Important  Projects  of  Common  European  Interest  (IPCEIs)  as  a  New  Form  of  Differentiation:  An Analysis  of Their  Challenges  for  the  European Single  Market,  available  at: 

https://euidea.eu/wp-content/uploads/2022/03/euidea_pp_18.pdf.  

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request  for  input,  have  unanimously  stated  that  even  if  most  of  the  RRP  measures  had  already  been  planned  and  had  been  included  into  government 
programmes, the combination of reforms and investments, which is pursued by the RRF, allowed them to: make the measures more ambitious in scale; 
likely increased the speed of implementation; and solidify the planned governmental measures and implementation of the CSRs. The increased ambition in 
scale is valid particularly for investments, while for reforms the RRF has brought EU added value mostly in terms of strengthening the incentives to perform 
CSRs, ensuring continuity of policies, and speeding up some politically challenging reforms. 

EQ22: To what extent could similar results/impact be achieved with a different instrument at Union level (e.g., budget support) or by Member States? 

It is difficult to provide robust answers to this evaluation question, due to the hypothetical nature and the absence of a counterfactual. For example, some 
measures were planned because it was known that the RRF was in the making. So while we can observe that 13% (150) of the 1,153 milestones and targets 
fulfilled have been implemented before the date of the official submission of the RRPs, this does not mean that these would have happened anyways, as 
Member States knew that the RRF allows some form of retroactivity (measures could be included with implementation as of February 2020, in order to 
avoid postponing needed reforms and investments in the first months of the pandemic) and the poor implementation of country-specific recommendations 
before the RRF was set up also contradicts the idea that similar results could have been achieved without the RRF.  

The general assessment of the stakeholders on the RRF additionality has been positive, yet about a quarter of the participants in both the national coordinator 
survey and the public consultation expressed a negative opinion on the extent to which the RRF supported measures would not have been implemented by 
Member States. Similar mixed sentiments were expressed during the performed interviews, but nevertheless, they revealed reported cases of rule of law 
and structural reforms, which would not have taken place in the context of budget support measures. The reviewed examples show the added value of the 
RRF, in particular in terms of politically challenging reforms. 

Relevance 

Overarching question: EQ23: To what extent does the RRF continue to be relevant in view of its objectives and how well do these objectives correspond 
with current needs within the EU? 

The relevance of the RRPs is widely acknowledged and is ensured by the following factors: the reforms and investments are linked to the CSRs, which are 
linked to strategically important reforms and investments; the twin transition (green and digital), which is an overarching EU-wide policy for years to come, 

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is at the heart of the RRF and consequently the RRPs; the RRF has envisioned a mechanism for revisions of the RRPs, which is currently being implemented 
(most members States have been updating their plans in 2023). 

While the reasons behind the 2026 deadline are well understood, it has led to limitations in selecting investments, particularly in the renewable energy 
sector. As concerns feasibility, national authorities have expressed their concerns regarding the 2026 deadline. 

EQ23.1: To what extent did the initial allocation key remain relevant over the period?  

The allocation key used to apportion funds among Member States proved relevant to support the economic convergence in the EU. The allocation key394 
applied to 70% of the non-repayable support is based on the population, the inverse of GDP per capita of 2019 and the relative average unemployment rate 
of each Member State in 2019. The allocation key applied to 30% of the non-repayable support also takes into account the change in real GDP in 2020 and 
2021. Results of macroeconomic models395 indeed show that, given the allocation key, Member States with below-average levels of GDP per capita are 
estimated to experience the largest boost to GDP levels. For a 6-year stimulus and a high-productivity calibration, the increase in output reaches more than 
3.2% in Greece; around 3% in Bulgaria, Croatia, and Romania; and around 2.5% in Italy and Portugal. 

The examination of the 2020-21 data shows that there was a need to re-evaluate which Member States are more in need of RRF disbursements – which the 
Commission did in June 2022, as per Article 11 of the RRF Regulation. Taking these factors into account has ensured that Member States in greatest need 
would benefit the most. 

However, it needs to be acknowledged that a later update of the allocation key may have looked a bit different, given that the Russian invasion of Ukraine 
and the resulting energy crisis affected Member States’ economies heterogeneously. 

394   For details on the allocation key, see Annex I, II and III of the RRF Regulation. 
395   Pfeiffer,  P.,  Varga,  J.,  and  in’t  Veld,  J.  (2023a)  Quantifying  spillovers  of  coordinated  investment  stimulus  in  the  EU,  Macroeconomic  Dynamics  (27),  pp.  1843-1865,  available  at: 
https://www.cambridge.org/core/journals/macroeconomic-dynamics/article/quantifying-spillovers-of-coordinated-investment-stimulus-in-the-eu/FFCCAAA20BD98AC50A93A4F24562EAD4.  

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EQ23.2: To what extent have the initial RRPs remained relevant/feasible to implement until 2026 (i.e., scope of changes made to the RRPs till the 
cut-off date)? 

Each RRP includes an agenda of reforms and investments that are relevant to each Member State and that are also relevant for EU policy priorities. The 
reforms and investments covered in the RRPs relate to the CSRs, which concern important and relevant strategic measures tailored to Member States’ 
needs. At the same time, as CSRs respond to broader EU policy priorities, the implementation of the measures included in the RRPs also support the broader 
EU agenda. In particular, with the specific climate and digital targets, the RRF directly contributes to the twin transformations (green and digital) of Member 
States’ economies, which is an overarching EU-wide policy for years to come. The results from the different consultations show broad support for the 
relevance of the RRF, with no interviewee questioning the relevance of the instrument396. 

The RRF remained relevant in an evolving context, demonstrating the flexibility of the instrument to adapt to changing circumstances. While the RRF was 
created in the context of the COVID- 9 shock to support the economic recovery and enhance the EU’s resilience, the RRF implementation is taking place 
in a changing environment, marked by Russia’s invasion of Ukraine, high inflation, and an energy crisis. Thanks to the continued relevance of its main 
policy objectives and its delivery model, the amendment of the RRF Regulation in the context of REPowerEU in 2023, and the mechanisms included in 
the RRF Regulation for amending RRPs based on objective circumstances (Article 21), ensured that the RRPs remained relevant and well suited to address 
the new challenges. In late 2022 and 2023, all 27 Member States submitted revised RRPs, in line with the different venues provided by the RRF Regulation 
to amend RRPs (objective circumstances, additional loans and updated maximum financial contribution).  

Most interviewees mentioned the CSR long-term relevance and the continued relevance of green and digital reforms and investments. A more granular 
look into the relevance of specific measures explored in the case studies confirms the relevance of the RRPs (e.g., the analysed active-labour market policies, 
rule of law measures, the measures in support of SMEs, energy efficiency, and eHealth measures). 

On one hand, the relevance of the 2026 deadline is  well-understood across stakeholders, particularly as concerns reforms. It  is  acknowledged that the 
deadline is playing a role in accelerating reforms. On the other hand, the 2026 deadline limits the investment measures only to mature ones, because they 
would otherwise not be completed by this hard deadline. While this allows for some level of demarcation between RRP and non-RRP actions, this has also 
limited the choice of interventions. According to interviewees, the close deadline of 2026 has limited the ambitions in the REPowerEU chapters. 

396   See pages 190 to 191 of the supporting study. 

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As concerns feasibility, national authorities have already flagged that some milestones and targets – in particular those related to infrastructure investments 
– can no longer be completed by August 2026 due to objectives circumstances. Ongoing revisions of RRPs will decrease some of the risks in terms of 
feasibility of the of the fulfilment of milestones and targets by the 2026 deadline.  

EQ24: To what extent is the instrument sufficiently flexible/agile to adjust to changing circumstances (cf. REPowerEU)? 

While the RRF was established during the COVID-19 pandemic to help Member States recover faster and become more resilient, its implementation is 
taking place in a constantly evolving context. Nearly a year after the entry into force of the RRF, the international context experienced another radical 
change following Russia’s illegal war of aggression against Ukraine. Due to its geographical proximity to the war and heavy reliance on gas imports from 
Russia, the EU economy was expected to fall into a winter recession in 2022-2023. While this recession was avoided by a margin, economic momentum 
slowed down significantly since the end of 2022, and the need emerged to quickly phase out reliance on Russian fossil fuels. 

Russia’s aggression against Ukraine caused renewed pressures on supply chains as well as on global energy and food markets, which to a large extent 
resulted in high levels of inflation, with the European Union being particularly affected. These external factors have had an impact on the implementation 
of the RRF, both as concerns implementation speed and the need to use the Facility to tackle emerging challenges.  

The REPowerEU Plan, presented by the Commission in May 2022 as the EU’s response to the energy crisis, paved the way for an amendment of the RRF 
Regulation less than two years after its entry into force. The RRF became a key tool to deliver on the REPowerEU objectives. It increased the amount of 
EU funds made available to the Member States through the RRF, and enabled Member States to adjust their RRPs by putting forward additional reforms 
and investments  to  rapidly phase-out  the EU’s dependence on Russian fossil fuels,  accelerate the clean energy transition,  support the reskilling of the 
workforce, and address energy poverty. 

Hence, the RRF has proven its ability to react to new challenges, as shown by the integration of REPowerEU and its flexibility in reacting to high inflation 
and supply chain constraints.  

On the other side, some stakeholders point to a lack of flexibility in the implementation of the instrument. Member States have pointed to a perceived 
rigidity in the way they are requested to implement RRPs (strict interpretation of detailed milestones and targets, strict list of milestones and targets that 
must be satisfactorily fulfilled to receive a specific instalment, disbursement procedures) and regarding the process to revise them. While this perceived 

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rigidity  stems  from  legal  obligations  anchored  in  the  RRF  Regulation,  it  has  reportedly  led  to  a  higher  than  expected  administrative  burden  and 
implementation delays. 

EQ25: What was the rationale behind Member States’ decisions to apply – or not apply – for loans under the RRF? 

While the RRF loans were relevant for some Member States, they were not for others. Assessment of the rationale behind Member States’ decisions to 
apply – or not apply – for loans under the RRF shows that a mix of financial and non-financial considerations has driven Member States’ decisions397. As 
of 1 September 2023, 13 Member States had requested loan support or additional one as per the revised RRF Regulation's Article 14(6). The amount of 
loan support requested was EUR 292.6 billion (in current prices), corresponding to 76% of the total loan support available.  

The potential reasons to apply for RRF loans were related to whether the Member State faced higher interest rate on the markets or a reduction in non-
repayable RRF support398. Some Member States with financing conditions on the markets at an interest rate higher than the EU interest rate sought additional 
support with RRF loans. Some Member States that faced a downwards revision of their maximum contribution of non-repayable support in 2022 also 
applied for loans to make up for the shortfall and ensure the continuity of their projects. Factors such as the health of public finances, the need for additional 
funding, inflation concerns, administrative burden, and the scale of planned projects have all played a role in determining whether Member States opted 
for RRF loans or not. 

On the contrary, the potential financial reasons not to apply for RRF loans were usually related to larger available funding or more favourable financing 
conditions by the market (when RRF loans were at higher interest rates compared to market alternatives)399. Some Member States also factored in inflation, 
i.e.  concerns  of  injecting  additional  money  into  an  economy  already  facing  inflationary  pressures.  Member  States  that  considered  that  the  maximum 
contribution of non-repayable support was sufficient also did not apply for loans.  

From a strict cost-of-funding viewpoint, RRF loans are expected to bring a sizeable return on investment (‘R I’) for some Member States400. According to 
Commission calculations based on available data on NGEU versus sovereign cost of funding in the period up until November 2023, all Member States who 

397   See pages 194 to 196 of the supporting study. 
398   Evidence in this paragraph is sourced from the supporting study, see pages 194 to 196. 
399   Evidence in this paragraph is sourced from the supporting study, see pages 194 to 196. 
400   Evidence in this paragraph is sourced from Monteiro, D. P. (2024), “Large-scale EU issuance: 3 years on”, Quarterly Report on the Euro Area, Vol. 22, No. 4 (forthcoming). 

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requested loan support were expected to benefit from a positive ROI401 from RRF loan disbursements. It was estimated at between 3% and 17% for nine 
euro area Member States, and between 14% and 39% for four non-euro area countries. This ROI is however subject to market developments. For non-euro 
area Member States, high ROIs are accompanied by exchange rate risk, which depends on the volatility of the exchange rate with respect to the EUR. 

401   Based on a discounted ROI approach, whereby the present value of the financial costs associated with a RRF loan (i.e., the stream of interest payments and future principal repayments) is compared with 

the present value of the financial benefit (i.e., the loan amount itself that is being granted). 

199 

 
 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS [AND, WHERE RELEVANT, TABLE ON SIMPLIFICATION AND BURDEN REDUCTION] 

The table A4.1 below presents the administrative costs in terms of Full-Time Equivalent (‘FTE’) persons reported by Member States as working on the 
tasks listed (second column) for the implementation of the RRF.  

There are significant variations across Member States in the number of FTE declared by coordination bodies both for one-off and recurrent activities. This 
can be partly explained by the size of the Member State and of the RRP. 

Table A4.1.: Overview of costs and benefits 

Type 

Name 

Description 

One-off/ 
Recurrent / 
Long-term 

Direct cost 

RRF financial contribution 

Sum of RRF estimated grant value and loans 

One-off 

Direct cost 

Financial cost 

Cost of borrowing of RRF debt 

Long-term 

Administrative cost 

Setup cost 

Resources spent to setting up the governance 
structure 

One-off 

Administrative cost 

RRP preparation cost 

Resources spent to prepare, negotiate, and 
officially submit the RRP. 

One-off 

Administrative cost 

RRP amendments cost 

Resources spent to prepare REPowerEU 
chapter and plan amendments 

One-off 

Administrative cost 

Audit and control cost 

Costs associated with auditing for 
administrations (i.e. Audit Authorities). 

Recurrent 

Administrative cost 

Payment claim cost 

Costs associated with payment requests 

Recurrent 

200 

Stakeholder 

MS administration 

MS / Final beneficiaries 

/ 

/ 

Costs of paying back the EU 
bonds 

Budgeted: EUR 14.9 billion* 
Estimated: EUR 30 billion* 

Median FTE: 10 
FTE range from 5 to more 
than 60 

Median FTE: 25 
FTE range from 10 to more 
than a hundred 

Median FTE: 15 
FTE range from 5 to more 
than a hundred 

Median annual FTE: 13 

Median annual FTE: 13 

/ 

/ 

/ 

/ 

/ 

 
 
 
 
 
 
 
 
 
 
 
 
Administrative cost 

Communication cost 

Resources spent for consultation, outreach 
activities and communication  

Administrative cost 

Performance 
management cost 

Resources spent for meeting/checking 
performance-based requirements 

Administrative cost 

Implementation cost  

Resources spent by implementing bodies to 
prepare tenders and guidelines and to screen 
and select project applications 

Recurrent 

Recurrent 

Recurrent 

Administrative cost 

Monitoring and reporting cost 

Resources spent by implementing bodies in 
relation to monitoring and reporting. 

Recurrent 

Direct benefits 

Improved well-being, changes in 
pollution levels, safety, health… 

Wide and varied range of benefits along the 
six pillars 

Long-term 

Wider benefits 

GDP growth 

Cumulative change in real GDP predicted by 
our model to occur by 2041 as a result of the 
RRF funding (both grants and loans) against 
the baseline. 

Long-term 

Median annual FTE: 6 

Median annual FTE: 15 

Median annual FTE: 70 

Median annual FTE: 18 

/ 

/ 

/ 

/ 

/ 

/ 

Quantification not possible 
beyond the common indicators 

EU level: EUR 127,179.5 million 
(in 2015 prices) 

/ 

/ 

/ 

/ 

The following table A4.2 provides an overview of the potential for simplification conveyed by stakeholders.  

Table A4.2: Overview of simplification measures 

Type 

One-off / Recurrent  

Simplification and burden reduction 

Reduction in spreads 

One-off  

Administrative cost savings due to a 
unique plan 

Administrative cost savings for plan 
amendments 

Administrative cost savings for control 
and audit 

Administrative cost savings for payment 
requests 

One-off 

Recurrent 

Recurrent 

Recurrent 

Already achieved 
The launch of the RRF led to savings in the cost of borrowing.  The announcements of a 
recovery fund – specifically, the initial Franco-German proposal on 18 May 2020 and the 
Commission proposal on 27 May that became the RRF  – led to a reduction in spreads of 
between 50 and 100 basis points for those Member States in Southern and Eastern Europe 
where borrowing costs are typically high.  
Having just one plan per Member State for both reforms and investments is considered a 
simplification as compared to other EU instruments. This led to some time and cost 
savings in the preparation and negotiation process.  

Potential 

/ 

/ 

/ 

/ 

(in principle) No need to provide evidence of the cost incurred  

Member States consider that there is a potential to shorten the process for amending 
RRPs  by  considering  the  possibility  to  differentiate  further  between  major/minor 
amendments.  
Member States consider that there is scope for simplification by avoiding multiple 
checks by the national audit court and ECA.  
Member  States  consider  that  there  is  scope  for  simplification  concerning  the 
information to be provided to evidence the fulfilment of milestones and targets when 
submitting a payment request. 

201 

 
 
 
 
 
 
 
 
Administrative costs savings for reporting 

Recurrent 

ANNEX V. STAKEHOLDERS CONSULTATION – SYNOPSIS REPORT  

Member States consider that there is scope for simplification by not reporting on 
common indicators (that they consider provide limited value added – although they 
are anchored in the Regulation) 

The Commission ran a call for evidence in November-December 2022 as well as a public consultation between March-June 2023. All other stakeholder 
consultation has been independently conducted and analysed by the contractors of the supporting study.  

Consultation strategy and methodology 

The stakeholder consultations involved conducting interviews, sending targeted surveys, and a public consultation (launched by the Commission through 
EUSurvey). Below a short description of the targeted stakeholder per each activity and the number of participants is provided. 

Table A5.1: Overview of consultation strategy and methodology 

Activities 

Stakeholder targeted 

Timing, stakeholder engagement 

Call 
evidence 

for 

Individual citizens, Academic and research institutions, NGOs, Consumer and social 
organisations, Individual economic operators and representatives, Public authorities 

8 November – 6 December 2022, 54 responses 

Public 
consultation 

Individual citizens, Academic and research institutions, NGOs, Consumer and social 
organisations, Individual economic operators and representatives, Public authorities 

16 March – 8 June 2023, 172 responses. 

The consultation outcome and the summary report are available on the Commission’s ‘Have your say’ portal402.  

Targeted 
surveys 

Survey for RRF coordination bodies 

18 May 2023 –7 July 2023, 40 respondents 

Survey for members national of parliaments 

25 May 2023 – 7 July 2023, 5 responses 

Survey for SMEs 

May 2023 – 7 July 2023, 33 responses 

402   The  consultation  outcome  and  the  summary  report  are  available  at:  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13608-Recovery-and-Resilience-Facility-2020-2024-mid-

term-evaluation/public-consultation_en.  

202 

 
 
 
 
Activities 

Stakeholder targeted 

Timing, stakeholder engagement 

Interviews 

National RRPs coordination bodies, EU institutions, societal actors/social partners 

Between May and August 2023, 61 (+81 for the case studies) interviews. Additional input on administrative costs and 
specific evaluation questions  (e.g.  on  loans)  was  received  from  five Member  States,  following a  request to  the  RRF 
expert group. 

Source: Supporting study 

Results of the consultation activities 

Feedback from the call for evidence 

The ‘call for evidence’ on the RRF mid-term evaluation was open for feedback from 8 November to 6 December 2022. The Commission received 54 
responses – most of them of little to no value added for the conduct of the evaluation. The most useful input came from public authorities. This trend tends 
to confirm that the evaluation should mainly rely on targeted consultations and case studies to gather meaningful information. 

The responses by category of respondents are presented below: 

Figure A5.1: Categories of respondents to the call for evidence 

Source: European Commission 

203 

 
 
 
•  Most of the responses submitted to the call for evidence came from citizens (73%), who voiced criticism against the EU on topics outside the scope 
of the evaluation (from anti-immigration to anti-vaccines criticisms hardly related to the RRF). One respondent opposed the solidarity effort of its 
Member State and considered that the RRP was an “austerity plan”. Another respondent called for the support of nuclear energy to foster resilience 
and recovery of Europe. 

•  Eight NGOs provided feedback403 (15%). They mainly called for greater involvement of NGOs in the elaboration and implementation of the Plans. 
They also called for more transparency about the process (including on how DNSH assessments were carried out) and on how RRF  funds were 
spent. They also called for a reduction of administrative burden.  An NGO called for transforming the RRF from a one-time only crisis-linked 
instrument to a structural EU instrument. 

•  Two  companies404  and  one  business  association405  in  the  health  sector  responded  to  the  call  for  evidence.  They  noted  some  difficulties  in  the 
implementation of health projects and called for taking into account inflation/energy costs in procurement and for an extension of the 2026 deadline. 

•  Three public authorities provided feedback (Spain’s Basque Government, Barcelona’s Provincial Council and Estonia’s Permanent Representation).  

o  The Spanish regional authorities called for a “regionalisation of the RRF”, with a greater involvement of regional authorities in the design 
of the plan (compulsory consultations) and in the implementation (direct management of a greater part of resources), as well  as for the 
possibility to transfer funds also from the RRF to cohesion (flexibility should go both ways).  They also called for increased flexibility in 
the implementation (for example by reducing the targets if demand has been overestimated or to take account of inflation) and for expanding 
the time limit beyond 2026 (noting that transformative/strategic projects take time).  

o  Estonia supported the scope of the mid-term evaluation as defined in the call for evidence and made some suggestions to cover additional 
aspects for most evaluation criteria. For example, Estonia recommended to add an assessment of how the proportionality principle has been 
applied  (taking  into  account  Member  States’  allocation)  under  ‘effectiveness’;  an  assessment  of  the  challenges  in  the  establishment  of 
plausible  costs  under  ‘efficiency’;  an  assessment  of  the  synergies  with  the  Technical  Support  Instrument  under  ‘coherence’.   n  data 

403   CEE Bankwatch Network, European Students' Union (ESU), EuroHealthNet, European Roma Grassroots Organisations (ERGO) Network, Fundación Secretariado Gitano (Roma Secretariat Fundation), 

Climate Action Network Europe, Civil Society Europe, European Anti-Poverty Network. 

404   Philips (health technology company), TVP. 
405   COCIR (health industries). 

204 

 
 
collection, Estonia pleaded to ensure that the evaluation analysis covers all Member States, to focus on the experience of final recipients that 
have hands on experience with RRF projects and to ensure to leave room for open/unstructured feedback. 

Feedback from the public consultation 

The public consultation on the RFF was open for twelve weeks between 16 March and 8 June 2023 and aimed to collect the views and evidence from all 
relevant stakeholders on the RFF, its contribution and features and the main elements that link the RFF with other policies and reforms. The consultation 
was accessible in all official EU languages via a dedicated page. The consultation outcome and the summary report are available on the Commission’s 
‘Have your say’ portal406. A total of 172 responses were received from 24 EU Member States and one non-EU country. The largest number of contributions 
stems from Portugal (57 responses), followed by Belgium (16), Germany (15), Spain (13), Romania (12), Italy (11) and Czechia  (10 responses). Four 
replies come from Austria and three from Hungary. The largest share of replies stems from EU and non-EU citizens, jointly accounting for almost two-
thirds of the responses (99 replies). Public authorities provided the second-largest share of replies (32). Including ministries and other authorities (26 replies) 
and agencies (three replies), their scope is local (seven replies), regional (seven replies), national (15 replies), and international (one reply) level. Companies, 
businesses, and business associations provided 16 replies, while 12 responses stem from NGOs and environmental organisations.  

Most respondents to the public consultation are familiar with the RRF and are aware that it supports reforms and investments under RRPs. Public authorities 
are particularly aware of the RRF's conditionality on reform implementation, while approximately 85% of the respondents have been directly involved in 
RRF-related activities. In particular, 28 respondents have benefited from RRF-funded projects and 26 have participated in plan implementation. While 
most respondents feel their organisations were adequately considered in the national consultation process, the response rate to this question was particularly 
low. 

Around  two-thirds  of  respondents  believe  the  RRF  has  contributed  to  economic  recovery  from  COVID-19,  and  a  similar  proportion  recognises  its 
contribution to green and digital transitions (Figure A5.1). However, only 54% believe the RRF significantly fosters EU growth. Respondents expressed 
mixed views on the RRF's contribution to enhancing EU resilience, social and territorial cohesion: approximately 44% feel it increased resilience to some 

406   The  consultation  outcome  and  the  summary  report  are  available  at:  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13608-Recovery-and-Resilience-Facility-2020-2024-mid-

term-evaluation/public-consultation_en.  

205 

 
 
extent, while 49% believe the impact was limited or non-existent. About half of the respondents think its contribution to social and territorial cohesion is, 
to some extent, limited. 

Figure A5.2: To what extent the RRF has contributed (or will contribute) to the following objectives? 

Fostering the growth potential of the EU economy

Supporting the digital transition

Supporting the green transition

Increasing health, economic, social, educational and institutional…

Strengthening social and territorial cohesion

Supporting the economic recovery from the COVID-19 crisis

To a large extent

To some extent

0%

25%
To a limited extent

50%

75%

100%

Not at all

Do not know

Source: Supporting study 

Most respondents believe that the RRF contributed to the initiation or implementation of reforms, with only 14% indicating otherwise. Examples of areas 
where the RRF played a role include the green and digital transition, labour reforms, and the health sector. Similarly, around 80% of respondents are aware 
that the RRF supports measures aligning with the "Do no significant harm" principle, which many believe has contributed to the green transition. However, 
respondents are less certain about the RRF's impact on gender equality, equal opportunities, and policies for children and young people: less than 10% 
believe the RRF addresses these issues to a large extent, while around a third see some contribution. Most respondents highly value the RRF's performance-
based feature (93 replies), followed by the speed of payments to Member States, and support for reforms. Support for projects in multiple countries is seen 
as less valuable but still important by three out of four respondents.  

Approximately half of the respondents believe that the RRF has created unnecessary burdens and complexity (Figure A5.2). This sentiment is shared across 
different respondent groups, including citizens, public authorities, and businesses. The perceived burden and complexity are identified in various stages of 
the RRF, with implementation, controls and reporting being particularly  problematic, according to a significant proportion of respondents. Among the 
examples listed, there were high proposal preparation costs and transaction costs related to the performance-based delivery model. In general, more than 

206 

 
 
 
half of the respondents see opportunities to simplify the RRF: apart from general calls for a reduction of the administrative burden, respondents suggest 
that more guidance should be provided by the Commission, and that procedures (especially on reporting) could be streamlined and further harmonised with 
other existing reporting requirements to reduce complexity.  

Figure A5.3: At which stages have you identified unnecessary administrative burden and complexity? 

100%

75%

50%

25%

0%

37

55

17

74

31

62

33

56

29

66

46

14

Preparation of the
national recovery and
resilience plans
(n=92)

Source: Supporting study 

Implementation of
the plans (n=91)

Reporting on the
plans (n=93)

Monitoring the plans
(n=89)

Audits and controls
(n=95)

Other (n=60)

Yes

No

Almost 75% of respondents suggest that it has been beneficial for the EU to support reforms and investments together under one instrument. More than 
two-thirds of respondents suggest that the RRF continues to be an appropriate way to support and complement the COVID-19 recovery in Member States, 
at least to some extent. Majorities of respondents suggest that the RRF has supported the Green Deal, initiatives on the circular economy, sustainable 
transport,  the  digital  agenda,  and  the  European  Semester  to  some  or  to  a  large  extent.  For  the  European  Semester  and  the  European  Green  Deal, 
approximately two-thirds of the respondents expressed these views. Among all policies, the largest share of respondents sees no support from the RRF for 
the biodiversity strategy. Among 99 respondents aware that the RRF seeks to improve the rule of law, 46 respondents suggest that the RRF strengthened 
the rule of law to at least some extent, while 28 respondents replied that it did so to a limited extent. 

207 

 
 
 
A vast majority of stakeholders (almost four in five) express the view that the RRF produced, at least to a limited extent, more results than what Member 
States could have done on their own. Finally, two-thirds of respondents express the view that this has happened to some or even a large extent, compared 
to only 14% of respondents who do not see any additional contribution from the RRF overall.  

Feedback from targeted surveys 

Two targeted surveys were launched at the end of May 2023 and closed on 7 July 2023. The first survey addresses key national stakeholders involved in 
the programmes’ implementation, in the projects’ selection, and in the monitoring and reporting procedures. The views and perspectives of this category 
will inform on the aspects of state of implementation, administrative costs and burden, the agility of processes and rules, potential overlaps and/or synergies 
with other existing instruments, in particular cohesion programmes, and views about the performance-based system. The second survey targets members 
of national parliaments involved in committees linked to areas of reform identified in the National Recovery and Resilience Plans. 

The survey questionnaires were translated into all official languages of the EU. The survey questionnaires were uploaded on EUSurvey, an open-source 
software solution funded by the Commission for creating surveys and questionnaires. 

Survey for RRF coordination bodies 

The survey received responses from 40 participants representing 24 different EU Member States. Five responses came from Austria, accounting for 13% 
of the replies. Estonia, Italy, and Ireland each contributed three responses (8%). Two replies (5%) were provided by each of the following Member States: 
Cyprus, France, Latvia, Romania, Slovak Republic, and Slovenia. 85% (34) of respondents declared that they are involved in the monitoring of the RRF 
while almost  73% (29) participated in  activities  related to  performance  management. Over half  of the respondents  (55%; 22) reported involvement  in 
payment  requests  and  more  than  one-third  (37%;  15)  in  control  and  audit  activities.  Moreover,  around  43%  (17)  stated  that  they  were  involved  in 
implementing the RRF strategy.  

Respondents were divided regarding the Commission’s communication with respect to guidelines and support documentation for the RRPs preparation. 
43% (17) of respondents found that the Commission communication and guidance has been timely and clear. In contrast, 43% (17) respondents affirmed 
that the Commission’s communication has been somewhat clear and on time, and finally, six respondents (15%) underlined the lack of timelessness and 
clarity of the guidance for designing the RRPs. 

208 

 
Figure A5.4: Timeliness and clarity of the Commission’s communication with respect to guidelines and support documentation for the preparation of the 
RRPs 

Yes

Somewhat

No

15%

43%

43%

Source: Supporting study 

The majority of respondents identified poor flexibility as one of the main weaknesses of the RRF funding instrument, counting 19 (49%) replies stating 
that the RRF showed very little flexibility, 13 (33%) responses consider the RRF somewhat flexible, six (15%) feedback declared that the RRF was not 
flexible at all. Only one respondent stated that the RRF has been flexible to a large extent. 

Figure A5.5: Respondents’ feedback regarding the extent of flexibility of the RRF to adjust to the changing circumstances 

To a large extent

Somewhat

Very little

Not at all

3%

33%

15%

49%

Source: Supporting study 

Survey  respondents  were  requested  to  give  their  opinion  on  how  the  effectiveness  of  the  RRF  compares  with  Cohesion  Policy  funds.  The  opinion  of 
respondents is mixed. However, it is noteworthy that only a limited number of respondents provided feedback on this matter (nine out of 40). The two 
positive feedbacks point to the fact that RRF reforms being country-specific can positively influence the effectiveness of investments, while Cohesion 
Policy enabling conditions are the same for all Member States. 40% (16) and 50% (20) of respondents declared that Member State administration suffered 

209 

 
 
 
 
 
the “entry costs” in gaining familiarity with the RRF to a large and to some extent, respectively.  nly  0% (4) of replies affirmed that the acquaintance 
process took a limited extent of “entry costs”.  

Figure A5.6: Respondents’ feedback on the level of national administrative “entry costs” in becoming familiar with the RRF as a new instrument 

To a limited extent

10%

To some extent

To a large extent

50%

40%

0%

10%

20%

30%

40%

50%

60%

Source: Supporting study 

With regard to the governance setting, opinions were divided. 21 affirmed that they would not change the current setup of the national RRF governance, in 
contrast to 46% of respondents who would set up a different governance structure after two years of RRF implementation. 

Figure A5.7: Respondents’ feedback to the question “Over two years into the implementation of the RRF, would you set up the national RRF governance 
structure differently?” 

No

Yes

46%

54%

Source: Supporting study 

Survey for national parliaments 

210 

 
 
 
  
Due to the very low number of responses received for the survey from members of national parliaments, its results could not be considered as representative 
to be incorporated into the evaluation. 

Survey for SMEs  

The survey received responses from 33 participants, out of which 30 came from EU SMEs – six responses from Romania, five responses each from Italy 
and Bulgaria, four answers from Spain, and two responses each from Belgium and Greece.  

The survey provided insight into the speed of disbursement to the final beneficiaries. Out of 33 respondents, 13 to the question on allocation, most (20) 
categorised the disbursement process as slow (14) or very slow (6), with only five considering it timely (4) or very timely (1). A few interviewees also 
raised the issue of slower payments to the ultimate recipients of RRF support. Unfortunately, there is no data available to confirm the issue of disbursements 
to final beneficiaries beyond some anecdotal evidence provided by interviewees (e.g. 12% paid to final implementation entities in one Member State). 

Figure A5.8: SMEs feedback regarding the RRF speed of disbursement to final beneficiaries 

5 – Very timely

1

4 – Timely

4

3 – I do not know / Neutral

8

2 – Slow

1 – Very slow

Source: Supporting study 

0

2

4

6

6

8

10

12

11

SMEs did not find a common agreement on the positive impact of the RRPs on businesses and SMEs. 10 respondents declared that the RRPS had a positive 
impact on businesses, while six and two respondents disagreed and strongly disagreed. 12 participants considered themselves neutral to the question (Figure 
A5.8).  

211 

 
 
Figure A5.9: Feedback from the question: “Do you agree that the measures included in your Member State’s RRP positively impact businesses and SMEs 
in particular? 

5 – Strongly agree

0

4 – Agree

3 – I do not know / Neutral

2 – Disagree

6

1 – Strongly disagree

2

10

12

0

2

4

6

8

10

12

14

Source: Supporting study 

Regarding synergies with other national programmes, 10 respondents affirmed that the RRF measures were coordinated and aligned relatively well and 
very well (1), while for nine other responses, the coordination was limited or absent. Eleven SME participants responded, “I do not know”. With regards 
to the Cohesion Policy funds, six respondents affirmed that the coordination and alignment of enterprise or SME-relevant RRP measures was strong. In 
comparison, nine respondents found limited or absent coordination. Results are shown in the figures below (Figure A5.9). 

Figure A5.10: Level of coordination between the enterprise RRF-measures with other programmes 

Source: Supporting study 

212 

 
 
 
 
 
Interviews 

A total of 61 interviews were conducted between May and August 2023 in the context of the supporting study407. The aim of the interviews was to collect 
the views and perspectives based on the mid-term evaluation questions and in line with the criteria of effectiveness, efficiency, relevance, coherence and 
EU added value.  

Effectiveness 

Overall,  interview  participants  stated  that  the  RRF  has  been  an  effective  instrument.  On  one  hand,  some  respondents  highlighted  that  the  RRF  has 
demonstrated a swift and efficient disbursement of payments to Member States. Compared to other EU Policies, such as the Cohesion Policy, the RRF has 
been innovative and effective by blending a broad range of initiatives, investments and performance-driven reforms. In particular, several interviewees 
observed that pre-financing provided fast direct support, playing a stabilising role in the aftermath of the unprecedented economic and social shock caused 
by the COVID-19 pandemic, thereby also helping to kick-start the recovery. On the other hand, most Member State coordination bodies indicated several 
challenges  and  difficulties  observed  in  the  initial  planning  of  investment  request  submissions,  mostly  due  to  the  lack  of  flexibility  and  requested 
amendments, and ultimately, they argued that RRF disbursements to final beneficiaries had been frequently delayed by National authorities. The majority 
of consulted societal actors, underlined a perceived democratic deficit due to simplified Member State consultation compared to other EU funding, limiting 
democratic participation, and leading to top-down planning. 

Most of the interviewees at national  and EU levels confirmed that the RRF contributed to pushing forward reforms in national agendas. In particular, 
interviewees  underlined  that  linking  investments  to  reforms  served  as  an  incentive  during  the  RRPs  implementation.  The  financial  support  has  been 
considered as the predominant factor accounting for the RRF’s success in implementing reforms aimed at addressing the Semester’s CSRs. While most 
respondents, including societal actors, considered the RRF a good instrument helping to accelerate the implementation of specific reforms and investments, 
other participants – mainly from national coordination bodies – emphasised that certain reforms encountered obstacles within the RRF framework due to 
political hurdles and time constraints. 

Furthermore, some interviewees highlighted the complexity of monitoring and assessing the achievement of milestones and targets and the importance of 
the  performance-based  approach.  On  the  other  side,  some  interviewees  criticised  the  performance-based  approach  and  emphasised  the  importance  of 

407   Annex VI of the supporting study provides a comprehensive summary of the interviewees’ answers for each evaluation criterium. 

213 

 
 
evaluating milestones and targets based on policy considerations rather than on fulfilment of the defined deliverables, which are often delayed due to energy 
crises,  issues  in  the  supply  chains  or  lack  of  flexibility  in  changing  the  national  plans.  Regarding  outputs,  most  interviewees  highlighted  the  RRF’s 
effectiveness in promoting reforms addressing various policy areas, such as green, digital and governance areas. According to EU-level stakeholders, the 
RRF  has  been  considered  effective  in  supporting  economic  recovery  by  promoting  this  broad  range  of  policies.  Some  national  coordination  bodies 
confirmed its effectiveness in supporting a fast economic recovery, with expected modest positive impact on GDP and employment; nevertheless, delays 
in the RRF disbursements led to national budgetary challenges.  

The effectiveness of the RRF in contributing to REPowerEU objectives is still in the early stages of assessment. On one hand, some respondents reported 
that the REPowerEU balances short-term needs like reducing dependence on Russian gas with long-term climate and energy targets. On the other hand, 
other respondents noted the challenges posed by political barriers and complexities in aligning RRF measures with REPowerEU, despite the value of the 
RRF in setting government programmes for several years. 

Responses regarding the impact of external factors on the RRF were quite homogenous. Respondents underlined that external factors, such as the war in 
Ukraine, the energy crisis, high inflation levels and issues in the supply chains, led to substantial barriers and challenges to the RRF’s implementation.  

Interviewees frequently refrained from directly comparing the effectiveness of the RRF and other cohesion policies, highlighting the early implementation 
stage as a reason for caution. Some respondents viewed the RRF, and especially its result-based approach, as more conducive than the ESF+ framework 
and procedures.  

Efficiency 

According to several EU-level interviewees, administrative costs and the burden of implementing the RRF have been a complex issue. Some Member 
States have faced challenges adapting to the RRF’s performance-based approach, with the need to establish efficient monitoring and auditing authorities. 
Costs included hiring additional staff to meet RRF requirements. The comparison with other instruments, such as Cohesion Funds, revealed differences in 
the audit and control systems, with RRF having a more demanding set of requirements. All interviewees highlighted the complexity and administrative 
burden of the RRF. Challenges consisted of high detailed cost estimation, administrative burdens requested up to final recipients, excessive paperwork and 
reporting, and high complexity of the auditing processes. The linkage between reforms and investments has been identified as one of the key innovative 
aspects of the RRF. Respondents from the EU-level, national bodies and societal actors agreed the pursuit of reforms and investments together was also 
aligned with the CSRs. 

214 

 
Most  participants,  both  at  the  EU  and  national  levels,  highlighted  the  importance  of  a  flexible  and  adaptable  governance  setting  for  an  efficient 
implementation. Some respondents also underlined that a more centralised political approach to governance has proven to be more efficient. 

Coherence 

According to interviewees, in some Member States, coherence between the RRF and other Cohesion Policy funds was ensured due to the nature of the 
governance settings. In fact, in some cases, coherence was endogenously guaranteed because the same team within the Ministry was in charge of designing 
both RRPs and Cohesion Policies. In other cases, coherence was ensured between RRF and national funding.  

According to interviewees, the link between RRF and EU Semester has been considered positive. The European Semester has been considered integrated 
into the RRF, as several reforms included in national plans came as a result of the CSR from previous EU Semester cycles.  

In addition, according to most interviewees, the EU’s priorities significantly influenced the reforms and investments included in the RRPs, particularly the 
measures focused on green and digital areas, circular economic and social dimensions. According to a few Member State-level respondents, the national 
plans were built upon already existing programmes and strategies. Some societal actors mentioned that in their view the DNSH principle had not been 
sufficiently integrated and incorporated into the RRF instrument. 

EU added value  

Some respondents found that the linkage between reforms and investments demonstrated complementarity and mutual reinforcement. Most interviewees 
underlined that the introduction of reforms to a financial funding instrument has been the key EU added value of the RRF. 

According to some national-level participants, the RRF has not been causal for introducing certain reforms on the policy agenda.  

Relevance 

According to national-level participants, adjustments and revisions of the initial funds’ allocation have been considered necessary for maintaining the RRPs 
as still relevant. Again, Member States underlined that more flexibility to adjust RRPs would have been helpful to better adapt to changing circumstances 
and to address external factors. 

215 

 
National coordination bodies listed different potential financial reasons that may affect the decision for applying – or not – for loan requests under the RRF. 
High debt or structural deficits or compensation for grant allocation reduction were considered as the main reasons behind the decision to apply for loans. 
On the contrary, healthy public finances, inflation concerns, and sufficient initial grant allocation had disincentivised Member States from requesting loans.  

216 

 
 
ANNEX VI. ADDITIONAL DATA AND ANALYSIS  

The following tables and figures provide further details and data to the analysis and findings described in the main text. 

Date of submission and adoption of original RRPs 

Table A6.1 lists the date on which Member States officially submitted their original RRPs to the Commission and the dates at which the plans were 
subsequently adopted by the Council. This list does not include the subsequent revisions and amendments in light of REPowerEU. 

Table A6.1: Date of submission and adoption of original RRPs 

Member State 

Date of submission of RRP by the Member 
State 

Date of adoption by the Council 

Date RRF pre-financing disbursed to 
Member State 

Belgium 

Bulgaria 

Czechia 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Lithuania 

30/04/2021 

15/10/2021 

01/06/2021 

30/04/2021 

28/04/2021 

18/06/2021 

28/05/2021 

27/04/2021 

30/04/2021 

28/04/2021 

14/05/2021 

30/04/2021 

17/05/2021 

30/04/2021 

14/05/2021 

13/07/2021 

05/05/2022 

08/09/2021 

13/07/2021 

13/07/2021 

29/10/2021 

08/09/2021 

13/07/2021 

13/07/2021 

13/07/2021 

28/07/2021 

13/07/2021 

28/07/2021 

13/07/2021 

28/07/2021 

217 

03/08/2021 

NA 

28/09/2021 

02/09/2021 

26/08/2021 

17/12/2021 

NA 

09/08/2021 (both non-repayable support 
and loans) 

17/08/2021 

19/08/2021 

28/09/2021 

13/08/2021 (both non-repayable support 
and loans) 

09/09/2021 (both non-repayable support 
and loans) 

10/09/2021 

17/08/2021 

 
Luxembourg 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

30/04/2021 

11/05/2021 

13/07/2021 

08/07/2022 

30/04/2021 

03/05/2021 

22/04/2021 

31/05/2021 

30/04/2021 

29/04/2021 

27/05/2021 

28/05/2021 

13/07/2021 

15/12/2022 

05/10/2021 

04/10/2022 

13/07/2021 

17/06/2022 

13/07/2021 

29/10/2021 

28/07/2021 

13/07/2021 

29/10/2021 

04/05/2022 

03/08/2021 

NA 

17/12/2021 

NA 

28/09/2021 

NA 

03/08/2021 (both non-repayable support 
and loans) 

02/12/2021 (non-repayable support) and 
13/01/2022 (loans) 

17/09/2021 

13/10/2021 

21/01/2022 

NA 

Note: No pre-financing was requested by Ireland. As the RRPs for Bulgaria, Hungary, the Netherlands, Poland and Sweden were adopted after the legal deadline established in the RRF Regulation and 
several months after that of other Member States, those five countries were unable to request pre-financing. 
Source: European Commission 

Number of fulfilled milestones and targets, per Member State and per pillar 

In complement to the data provided in Figure 2 in the main Staff Working Document, the following figures illustrate Member States’ progress in fulfilling 
milestones and targets for each of the RRF policy pillars: 

218 

 
 
 
 
 
Figure A6.1.: Number of fulfilled milestones and targets contributing to the green transition, per Member State 

Source: Recovery and Resilience Scoreboard 
Figure A6.2.: Number of fulfilled milestones and targets contributing to the digital transformation, per Member State 

Source: Recovery and Resilience Scoreboard 

219 

0 0203040 0Number of milestones and targetsReformsInvestments0 0203040 0Number of milestones and targetsReformsInvestments 
 
 
Figure A6.3: Number of fulfilled milestones and targets contributing to smart, sustainable and inclusive growth, per Member State 

Source: Recovery and Resilience Scoreboard  
Figure A6.4: Number of fulfilled milestones and targets contributing to social and territorial cohesion, per Member State 

Source: Recovery and Resilience Scoreboard  

220 

0 0203040 0 0Number of milestones and targetsReformsInvestments0 0203040 0Number of milestones and targetsReformsInvestments 
 
 
Figure A6.5: Number of fulfilled milestones and targets contributing to health, and economic, social and institutional resilience, per Member State 

Source: Recovery and Resilience Scoreboard  
Figure A6.6: Number of fulfilled milestones and targets contributing to policies for the next generation, per Member State 

Source: Recovery and Resilience Scoreboard  

221 

0 0203040 0 0Number of milestones and targetsReformsInvestments0  0  Number of milestones and targetsReformsInvestments