Green transition : unclear contribution from the Recovery and Resilience Facility. Special report 14, 2024.
Date: 2024-09-12
Institutions: European Court of Auditors
Subjects: EU Member State, EU budget, audit, climate change, green economy, performance audit, report, sustainable development

EN 

2024 

14 

Special report  Green transition 

Unclear contribution from the Recovery  
and Resilience Facility 

 
 
 
Contents 

Executive summary 

Introduction 

The Recovery and Resilience Facility and its main features 

The green transition under the RRF 

Climate tracking under the RRF 

Audit scope and approach 

Observations 

The contribution from the RRF and the national plans 
to the green transition could be overestimated 

Challenges in the RRF framework in terms of estimating climate contribution 
and covering the green transition 

Unclear contribution of the planned RRF measures to climate action 
and the green transition 

Weak indication of how implementing RRF measures contributes 
to the green transition 

Inconsistencies in applying the principle of ‘do no significant harm’ 

Not all climate-relevant measures are as green as planned 

RRF reporting on climate spending and the green transition 
is disconnected from actual costs and results 

Blind spots in capturing the performance of the RRF’s green transition 
measures 

No reporting on actual spending for climate action 

No link between expenditure and green transition reporting 

Conclusions and recommendations 

Annex – Our selection of measures 

Abbreviations 

2 

Paragraph 

I-VI

01-09

01-03

04-05

06-09

10-14

15-69

15-35

16-24

25-35

36-47

36-43

44-47

48-69

48-53

54-59

60-69

70-77

3 

Glossary 

Replies of the Commission 

Timeline 

Audit team 

 
 
 
 
4 

Executive summary 

I The Recovery and Resilience Facility (RRF) is a temporary instrument that was 
launched in May 2020 to help member states recover from the COVID-19 pandemic, 
with €648 billion available, as at February 2024. The green transition is one of the 
pillars of the Facility. Member states had to earmark at least 37 % of their national 
allocations for climate action. The Commission assessed that this target had already 
been achieved at the planning stage, reaching 42.5 %. 

II The objective of our audit was to assess whether the design and the 
implementation of the RRF and the national recovery and resilience plans contribute 
effectively to the green transition. We assessed the contribution made to the green 
transition by the selected measures, their milestones and targets, and their climate 
coefficients. We also reviewed how these measures progress and how they are 
monitored from a green transition perspective. Finally, we looked into how the 
Commission and the member states report information on climate spending and the 
green transition. 

III We carried out this audit because the green transition and the EU’s climate targets 
are high on the political agenda. We expect the results of our work to contribute to the 
debate on how to design and implement future instruments with climate and 
environmental objectives. We also expect our work to contribute to improving the 
effectiveness of the EU funds for climate action and the green transition in the context 
of the EU’s ambitious 2030 and 2050 climate targets. 

IV We found shortcomings in the design of both the RRF framework and the national 
recovery and resilience plans in the audited member states. There were also 
inconsistencies in the implementation of the measures, relating to the green transition 
and the climate objectives. In particular, we noted that tracking climate expenditure 
involves a high level of approximation and some coefficients were leading to potential 
overestimations. We found weak indications on how the implementation of RRF 
measures contributes to the green transition, and also found that the contribution 
towards the EU climate objectives and targets is not assessed, as this is not required by 
the legislation. In addition, we found that the reporting on climate spending and green 
transition is disconnected from actual costs and results, limiting its relevance for 
stakeholders. 

 
 
5 

V We conclude that the identified weaknesses in the design and implementation of 
the Facility call into question the achievement of its climate and environmental 
objectives. Consequently, we consider that the contribution of the Recovery and 
Resilience Facility to the green transition is not clear. 

VI Based on our findings, we recommend that the Commission: 

o 

o 

o 

o 

better estimate climate spending under future funding instruments; 

ensure adequate design of future funding instruments that are to support the 
climate and environmental objectives and targets; 

enhance the performance of green transition measures; 

improve reporting on climate spending under Recovery and Resilience Facility. 

 
 
 
 
6 

Introduction 

The Recovery and Resilience Facility and its main features 

01 In May 2020, the EU launched NextGenerationEU (NGEU) as a temporary 
instrument to help member states recover from the COVID-19 pandemic. NGEU 
consists of up to €731 billion (at 2022 prices), which is in addition to the EU’s long-term 
budget for the 2021 to 2027 period. Its centrepiece is the Recovery and Resilience 
Facility (RRF)1 – Figure 1. The purpose of the RRF is to mitigate the economic and social 
impact of the COVID-19 pandemic, making member states’ economies and societies 
more sustainable and resilient. The RRF should help member states to better prepare 
for the challenges and opportunities arising from the green and digital transitions. 
Moreover, in May 2022, the EU launched the REPowerEU plan as a response to the 
global energy crisis, adding €19 billion in grants to the RRF as at February 2024. 

Figure 1 – The NGEU budget (as at February 2024) 

€ 338 billion
RRF grants

€386 billion
RRF loans available

€724 billion 
RRF maximum amount 
available 
(according to the RRF Regulation)

€648 billion 
RRF total financial 
amount committed 
(February 2024)

€83 billion
NGEU contribution 
to other 
programmes 
outside RRF

+

€ 19 billion
additional funds

€ 291 billion
RRF loans committed

Note: All amounts are at 2022 prices. 

Source: European Commission and the RRF Scoreboard, as at February 2024. 

02 The Commission directly manages the RRF. This means that the Commission is 
responsible for the RRF’s implementation, including monitoring its progress and 
assessing its results. Each member state is eligible for a share of the available RRF 

1  Regulation (EU) 2021/241 establishing the Recovery and Resilience Facility (RRF 

Regulation). 

 
 
 
 
7 

funds, which is worked out based on a specific formula2. Each member state presents a 
national Recovery and Resilience Plan (RRP), which is assessed by the Commission3 and 
approved by the Council. The RRPs include a series of measures, which consist of 
reforms and investments. Milestones and targets are associated with every measure to 
track qualitative and quantitative achievements4. The Commission adopted a set of 
common indicators for reporting and monitoring the progress of the RRF towards its 
objectives5. 

03 The RRF operates based on a new funding model. As opposed to most of the EU 
budget, where funding is provided based on costs incurred, the Commission makes 
RRF payments to member states (‘disbursements’) upon the satisfactory fulfilment of 
milestones and targets. However, when designing their national plans, member states 
had to indicate the estimated costs for each measure, to justify the requested amount 
of RRF grants or loans6. Otherwise, the amount would have been reduced to match the 
estimated costs. Figure 2 provides a summary of the roles and responsibilities in the 
different phases. 

2  Article 11 of Regulation (EU) 2021/241. 

3  Special report 21/2022 on the Commission’s assessment of national RRPs. 

4  Special report 26/2023 on the RRF performance monitoring framework. 

5  Commission Delegated Regulation (EU) 2021/2106 setting out the common indicators. 

6  Annex V, point 3, of the RRF Regulation. 

 
 
 
8 

Figure 2 – Roles and responsibilities 

Co-legislators
(Council of the EU 
and the European Parliament)

European 
Commission

Member 
states 

FRAMEWORK

PLANNING

IMPLEMENTATION

REPORTING

In February 2021, co-
legislators adopted 
RRF Regulation

In September 2021, the 
Commission adopted 
Delegated Regulation on 
the common indicators 
and the RRF Scoreboard

Commission issues 
guidance to member 
states on RRPs

Member states submit 
RRPs, in line with EU 
priorities and also
addressing the European 
Semester country-
specific 
recommendations 

Commission assesses the 
RRPs under the criteria of 
relevant, effectiveness, 
efficiency and 
coherence, using the 
assessment criteria of the 
RRF Regulation

Commission performs ex 
ante audits on the 
national frameworks

Council approves RRPs 
through Council 
implementing decisions

Member states 
implement the measures 
included in their RRPs

Member states report on 
common indicators and 
progress in their RRPs

Member states submit 
payment requests up to 
twice a year for achieved 
milestones and targets

In July 2022, the 
Commission presented a 
review  report

Commission examines 
payment requests from 
member states

Commission authorises 
the disbursement once it 
has received a favourable 
opinion from the 
Economic and Financial 
Committee

Commission performs 
audits on milestones and 
targets

Commission provides an 
annual report to the co-
legislators on the 
implementation of the 
RRF

The Regulation requires 
the Commission to 
report ex post on the 
expenditure financed by 
RRF under each pillar, in 
the RRF Scoreboard

Commission created a 
new tool, the FENIX 
portal, to gather data 
from member states on 
the RRF

Source: ECA. 

The green transition under the RRF 

04 The measures under the RRF refer to policy areas which are relevant across the 
EU, and which are structured under six pillars: one of these pillars is the green 
transition (Figure 3). The scope of the green transition encompasses both climate and 
environmental objectives. Measures under the green transition pillar should 
contribute to: 

o  meeting the EU’s 2030 climate targets (Box 1) and working towards the objective 

of EU climate neutrality by 20507; and 

7  Article 4 of the RRF Regulation. 

 
 
 
 
9 

o 

environmental sustainability. 

Green transition measures should foster sustainable growth, create jobs and preserve 
energy security. The green transition should be supported by reforms and investments 
in green technologies and capacities, including biodiversity, energy efficiency, building 
renovation works, and the circular economy8. 

Figure 3 – The green transition pillar and its policy areas 

Climate change 
adaptation

Other climate 
change 
mitigation

Sustainable use 
and protection 
of water and 
marine resources

Sustainable 
mobility

Renewable 
energy 
and networks

Green 
transition

Energy efficiency

Transition to 
a circular 
economy, waste 
prevention and 
recycling

The protection 
and restoration 
of biodiversity 
and ecosystems

Pollution 
prevention 
and control

R&D&I in green 
activities

Green skills
and jobs

Climate-related policy areas

Environment-related policy areas

Other relevant policy areas

Source: ECA, based on the RRF Scoreboard. 

8  Recital 11 of the RRF Regulation. 

 
 
 
 
10 

Box 1 

The EU’s 2030 climate targets 

(a) Reducing greenhouse gas (GHG) emissions by at least 55 %, compared with

1990 levels

(b) Reaching at least a 42.5 % share of renewables in the energy consumed,

with the aspiration of reaching 45 %

(c) Reducing final energy consumption by 11.7 %, compared with the

projected energy consumption for 2030, based on the 2020 reference
scenario

Source: Article 2 of the Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate 
Action and subsequent modifications, including the Renewable Energy Directive (EU) 2023/2413 and the 
Energy Efficiency Directive (EU) 2023/1791. 

05 The member states and the Commission assessed, based on indications from the
member states and the Commission’s own qualitative judgement, whether each RRP 
manages to strike a balance between the pillars. Based on this analysis, the 
Commission assigned each measure to a primary and secondary pillar, based on a 
measure’s declared objective. This was then checked with the member states, and 
included in the RRF Scoreboard – the reporting platform for the RRF. As of 
February 2024, the RRF Scoreboard indicated that there were 984 measures 
contributing to the green transition. 

Climate tracking under the RRF 

06 The EU committed to spending at least 30 % of the 2021-2027 budget on
climate action9. Under the RRF, each member state must dedicate at least a 37 % share 
of their RRP’s total funding allocation to climate action measures, i.e., climate 
adaptation or mitigation, including actions that contribute to the 2030 climate targets 
(Box 1). The 37 % target provides member states with the opportunity – and the 
requirement – to include in their RRPs a significant share of measures relevant for 
climate action. All these measures are linked to the green transition pillar. 

9  European Council, Conclusions – Special meeting of the European Council, EUCO 10/20, 

2020, p. 7. 

11 

07 To calculate this climate contribution of 37 %, the RFF Regulation includes the
methodology for ‘climate tracking’, which is based on climate coefficients. The 
methodology is an adapted version of the Rio markers introduced in 1998 by the 
Organisation for Economic Co-operation and Development, and is common to all EU 
funds, including RRF, throughout the 2021-2027 period10. 

08 The EU climate coefficients are ‘activity based’11: the RRF Regulation includes a
list of 181 intervention fields, covering several areas of investment, e.g. fixed or 
intangible assets, research and development, energy and transport. Each intervention 
field is associated with a climate coefficient based on the activity’s expected effect on 
climate12. Coefficients can either be 0 %, 40 %, or 100 % (Figure 4). There are 
64 intervention fields with a positive climate coefficient (40 % or 100 %). 

Figure 4 – The three EU climate coefficients according to their expected 
climate contribution 

Substantial 
contribution

Non-marginal, 
positive 
contribution

Neutral 
or insignificant 
contribution

Source: ECA, based on SWD(2022) 225, Climate mainstreaming architecture in the 2021-2027 period. 

09 The total amount of expected climate contribution per member state is
calculated by multiplying the corresponding climate coefficients by the estimated costs 
of each RRF measure, based on the measure’s assigned intervention field. Intervention 
fields are proposed by the member states and checked by the Commission as part of 
its assessment. The aggregated EU member state estimation amounted to about 40 % 
of the RRF allocations, or €203 billion out of the €504 billion initially budgeted by 
member states. As at February 2024, the climate contribution was revised to 
€275 billion (42.5 %) out of a total of €648 billion (Figure 5). 

10  SWD(2022) 225, Climate mainstreaming architecture in the 2021-2027 period, p. 9. 

11  Ibid., p. 5. 

12  Ibid. 

12 

42.5 %

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-

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Figure 5 – RRF expected climate contribution by member state 

Sum of climate tagged contribution

Minimum 37 % target

80 %

70 %

60 %

50 %

40 %

30 %

20 %

10 %

0 %

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2.6

4.0

13.2

0.4

65.0

3.9

0.5

1.4

7.0

3.0

27.9

12.6

3.1

1.5

Planned 
climate 
contribution 
in billion €

3.2

1.1

0.6

0.8

0.1

0.2

2.2

9.1

1.3

1.0

13.7

19.9

75.9

Source: ECA, based on the 27 RRPs, as at February 2024. 

 
 
 
 
 
13 

Audit scope and approach 

10 The objective of our audit was to assess whether the design and the 
implementation of the RRF and the RRPs contribute effectively to the green transition. 
We assessed the contribution made to the green transition by the selected measures, 
their milestones and targets, and their climate coefficients. We also reviewed how 
these measures progress and how they are monitored, in particular with regard to the 
RRPs’ contribution to climate targets. Finally, we looked into how the Commission and 
the member states report information on climate spending and the green transition 
supported by the RRF. 

11 We carried out this audit because of the high level of interest in the RRF’s 
contribution to the green transition and the EU’s climate targets, considering its 
materiality and novel design. This audit expands on our previous work in the area, in 
particular the published reports on the Commission’s assessment of the RRPs, the RRF 
performance monitoring framework. Our audit adds to and complements additional 
ongoing work on double funding, the absorption of RRF funds and member states’ 
control systems for state aid and public procurement. It also builds on our previous 
work on climate spending in the EU budget. 

12 Our audit covered the period from the adoption of the RRF Regulation in 2021 to 
February 2024. To review the design process and the implementation of the green 
transition measures in the RRPs, we selected four member states for on-the-spot visits: 
Greece, Croatia, Portugal and Slovakia. Our selection of member states took into 
account previous coverage by other ECA tasks. In addition, we based the choice on our 
risk analysis of the climate-tagged measures, on the RRPs’ implementation status at 
the time of our audit and geographical coverage. 

13 In this report, we focused on investments by selecting six for each examined 
member state (24 measures in total – Annex). This sample comprised a total of 
55 (sub-)measures with a positive climate contribution. This selection was carried out 
before the REPowerEU chapters were approved and was based on the relevance of the 
measures for the green transition, their materiality, the coverage of different climate 
objectives, and status of implementation. This audit does not cover the evaluation and 
selection process to determine the RRF measures eligible for financing from EU green 
bonds. Our analysis of RRF climate-relevant measures, however, could serve as input 
for any potential future audit focusing on green bonds. Figure 6 shows our audit 
approach. 

 
 
Figure 6 – Work carried out 

14 

Review of relevant data and documents, including strategic, legislative, policy, 
project documentation about the RRF and the green transition and the RRF mid-
term evaluation

Review of all climate-tagged measures included in all RRPs, and the set milestones 
and targets

Interviews with member states’ authorities involved in the design and 
implementation of RRPs, including, where relevant, final recipients, in selected 
member states

In-depth analysis of 24 measures in the selected member states, chosen from the 
most relevant in terms of their contribution to the green transition, through desk 
review and on-the-spot visits

Assessment of the status of implementation of the RRPs of the selected member 
states, with a focus on the progress of milestones and targets that are linked to the 
green transition

Interviews with Commission staff (Directorate-General for Economic and Financial 
Affairs and the Recovery and Resilience Task Force) responsible for steering the 
implementation of the RRF

Interviews with stakeholders and climate experts

Source: ECA. 

14 We expect our work to help member states and the Commission to improve the 
legal framework for the green transition, the relevance of the climate-tagged measures 
and the reliability of reporting on the EU climate contribution. Our findings and 
recommendations will be useful in improving the effectiveness of EU funds for climate 
action and the green transition in the context of the EU’s ambitious 2030 and 
2050 climate targets. 

 
 
 
 
15 

Observations 

The contribution from the RRF and the national plans to the 
green transition could be overestimated 

15 Figure 7 presents an overview of climate contribution, as estimated in the 
national RRPs, which is broken down by climate coefficient and intervention field. Eight 
out of 64 intervention fields with a positive climate coefficient account for 59 % of the 
planned allocation (paragraph 09). 

Figure 7 – Breakdown of climate contribution by type of intervention 
and climate coefficient 

Water 
management
2 %

Other (e.g. waste 
management, 
biodiversity)
8 %

Energy efficiency 
medium-depth 
renovation 
17 %

Energy efficiency 
and new buildings
5 %

Other (e.g, clean 
transport, 
alternative fuel 
infrastructure, 
adaptation)
17 %

Energy efficiency 
and demonstration 
projects in SMEs or 
large enterprises
5 %

Clean urban 
transport 
infrastructure
5 %

CLIMATE COEFFICIENTS

Substantial contribution

Non-marginal contribution

15 %

€275.2 billion 
tagged as contributing 
to climate action 
in all RRPs

85 %

Smart energy 
systems
9 %

Research and 
innovation processes 
for climate action
8 %

Railways
12 %

Renewable energy
12 %

Source: ECA, based on the 27 RRPs, as of February 2024. 

 
 
 
16 

Challenges in the RRF framework in terms of estimating climate 
contribution and covering the green transition 

Our audit 
criteria 

16 In line with the RRF Regulation13, the RRF should contribute to the 
green transition, the achievement of the EU’s 2030 climate targets and 
climate neutrality by 2050. Measures should be assigned to intervention 
fields that have relevant climate coefficients. The Commission should 
monitor progress towards the RRF climate and environmental objectives. 

17 We examined whether the existing RRF framework is designed to effectively 
contribute to the green transition, including the EU’s 2030 and 2050 climate targets. 
We analysed the key concepts of the green transition and climate tracking, and what 
they entail. We also analysed the list of intervention fields and climate coefficients that 
have been approved in the legislation, and the common indicators adopted by the 
Commission. 

18 The contribution to the green transition refers to reforms and investments in 
green technologies and capacities, including biodiversity, energy efficiency, building 
renovation and the circular economy14 (paragraph 04). The green transition has 
therefore a broader scope than climate action, as it includes biodiversity and 
environmental objectives. However, the RRF Regulation establishes a tracking system, 
with a quantitative target of 37 %, only for climate-related measures (paragraph 06), 
but does not set a target for environmental measures. A tracking system for 
environmental objectives does exist15, but is not used, as the RRF Regulation does not 
set a quantitative target for it. 

19 In our special report on climate spending16, we noted that the methodology used 
to track climate action involves a high level of approximation. We also pointed out that 
the climate coefficients do not allow for an exact quantification of the expected 
climate contribution. 

20 The methodology applied to climate tracking is common for all EU funds, 
including the RRF, across the 2021-2027 period, and is similar to the methodology 
applied in the 2014-2020 period (paragraph 07). The Commission acknowledged that 

13  Article 4, recitals 26 and 63 of the RRF Regulation. 

14  Recital 11 of the RRF Regulation. 

15  Annex V of the RRF Regulation. 

16  Special report 09/2022, paragraph 37. 

 
 
 
17 

under the RRF, using a single climate coefficient (either 40 % or 100 %) for a measure 
could lead, in some cases, to under- or overestimating its expected climate 
contribution17. To better estimate climate contribution, the Commission introduced 
the concept of sub-measures, so that, where sufficient information was available, 
multiple intervention fields and coefficients could be used to identify more precisely 
the contribution to climate, and exclude costs that either do not contribute or that 
make an insignificant contribution18. The Commission and the member states 
discussed and agreed the proposed sub-measures on a case-by-case basis. 

21 We noted that almost half of the expected climate contribution from the RRF 
(44 %) comes from measures that have not been split into any sub-measures. Our 
sample confirmed a similar share of 10 out of 24 measures that had not been split 
(41 %). These 10 measures were assigned a 100 % climate coefficient and we found 
potential overestimations in at least seven of them, as not all elements were climate-
relevant. This led us to conclude that this exercise did not always result in fine-tuning 
the climate contribution of the measure they relate to, and that a high level of 
approximation was used to estimate the climate contributions by these measures, in 
particular for complex ones with elements that have different climate contributions. 

22 While the aim of sub-measures was to better assign climate coefficients, the 
Commission’s guidance did not include instructions to ensure consistency in the 
application of sub-measures across the different RRPs. In practice, this resulted in 
attributing coefficients with different levels of detail. For example, in our sample we 
found that only Croatia had split the measure to finance the energy renovation of 
buildings to account for the structural part of the investment without a climate 
coefficient. The other three member states had not proposed any split for similar 
measures. 

23 The RRF Regulation assigns a 40 % climate coefficient to the construction of any 
new highly-efficient building. We consider that, as there are no energy savings which 
result from new buildings, the 40 % climate coefficient cannot be justified and it should 
rather be 0 %. In addition, our previous special report on climate spending found that 
some of the climate coefficients assigned in the legal framework to railway 
infrastructures and electricity grids may lead to overestimations in terms of the 
expected climate contribution. We consider that these findings remain valid for the 
RRF. Figure 8 presents our reassessment of the coefficients for these three mentioned 
areas of intervention and the resulting likely overestimation for the RRF, which 

17  SWD(2021) 12 part 1/2, Guidance to member states’ RRPs, p. 29. 

18  Ibid. 

 
 
 
18 

amounts to €34.5 billion. We based our assessment on assigning a 40 % coefficient for 
a non‐marginal, positive contribution and a 0 % for a neutral or insignificant 
contribution19 (Figure 4). 

Figure 8 – ECA reassessment of coefficients 

Note: This reassessment covers intervention fields 064, 065, 066bis, 033 and 025ter. 

Source: ECA, based on special report on climate spending and the Energy Performance of Buildings 
Directive. 

24 Four of the 14 common indicators defined for the RRF aim at measuring progress 
towards the green transition (Figure 9). Our previous work found that the common 
indicators are limited for assessing the overall performance and they provide only 
limited coverage of the green transition pillar20. For example, there are no common 
indicators for environmental measures or for measures aiming to reduce GHG 
emissions, which are relevant for the environmental and climate objectives of the RRF. 
The lack of such indicators does not allow to measure progress towards these 
objectives. 

19  SWD(2022) 225, Climate mainstreaming architecture in the 2021‐2027 period 

20  Special report 26/2023, paragraphs 42, 43 and 94. 

 
 
 
 
Figure 9 – Four common indicators under the green transition pillar 

19 

Common indicator 1
Savings in annual primary energy 
consumption

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

Source: Delegated Regulation (EU) 2021/2106. 

Common indicator 2 
Additional operational capacity 
installed for renewable energy

Common indicator 3 
Alternative fuels infrastructure 
(refuelling/charging points)

Unclear contribution of the planned RRF measures to climate action and 
the green transition 

Our audit 
criteria 

25 In line with the RRF Regulation21, member states should include in 
their RRPs measures that are relevant for the green transition and that 
contribute to climate targets. The climate coefficients should reflect the 
objectives of the measures and their expected impact on climate action. 
The milestones and targets linked to these measures should assess 
progress towards the achievement of the RRF objectives, including the 
green transition. 

26 We assessed to what extent member states chose relevant measures for the 
green transition or climate action when designing their plans. We also looked at 
whether member states established milestones and targets that can assess 
performance. As national plans are assessed by the Commission, we analysed as well 
the guidance provided. 

27 Overall, we noted that having a quantitative target for climate action prompted 
member states to include measures in their RRPs that have a link to climate. In each of 
the selected member states’ RRPs, we identified measures which focused, at the 
design level, on decarbonisation, renewable energy and energy efficiency (Box 2, Box 3 
and Box 4 provide some examples). 

21  Recitals 26 and 39, articles 2, 4 and 18 of the RRF Regulation. 

 
 
 
 
20 

Box 2 

Building renovations in Croatia and Greece 

The energy renovation of buildings plays an important role in achieving the EU’s 
climate targets, as buildings are responsible for around 40 % of primary energy 
and 36 % of CO2 emissions22. 

Croatia included a measure with €147 million of estimated costs to require a 
50 % reduction in annual energy needs for heating, for a 30 % primary energy 
reduction. The purpose of this measure is to renovate multi-dwelling buildings, 
with greater potential for energy savings. 

Greece proposed a measure with €1.25 billion of estimated costs to improve 
energy efficiency for 105 000 residences and the installation of 150 MW of 
capacity from new renewable energy sources. 

Box 3 

Industrial decarbonisation in Slovakia 

Industrial production and industry’s use of fossil fuels account for 41 % of all 
emissions in Slovakia, the highest share among EU member states23. A measure 
with estimated costs of €362.7 million aims to reduce GHG emissions by 
funding projects to decarbonise industry, to save energy and use innovative 
environmental technologies in carbon-intensive industries. 

22  Croatia’s initial RRP, p. 1124 and Greece’s initial RRP, p. 117. 

23  Slovakia’s initial RRP, p. 7. 

 
 
 
 
 
 
 
 
 
21 

Box 4 

Renewable hydrogen and other gases in Portugal 

Portugal aims to promote renewable energy from hydrogen and other 
renewable gases, in order to improve economic growth and employment, to 
foster research and development, and to reduce national energy dependence. 
The RRF measure, which amounts to €255 million, finances 277 MW of 
additional capacity to produce hydrogen from low-carbon and renewable energy 
sources. 

28 The selection of RRF measures had to be completed within a short timeframe: 
after the adoption of the RRF Regulation in February 2021, member states needed to 
set up their RRPs, and milestones and targets had to be achieved by the RRF ‘expiry 
date’ of 30 August 202624. The Commission’s guidance25 encouraged member states to 
identify mature projects, taking into account the envisaged timeline for their 
implementation. Timing was also particularly relevant for the REPowerEU chapters 
(paragraph 01). In our opinion 04/2022 on the REPowerEU, we noted that that the 
RRF’s limited timeframe combined with the time required to submit and approve 
amendments to the RRPs may not have been suitable for some of the REPowerEU 
objectives26.  

29 Our analysis of the four sampled RRPs shows that these member states generally 
followed the Commission’s guidance and opted for mature projects, and included in 
their RRPs measures that were either typically funded by other EU instruments or had 
been waiting for funds to be implemented. We also found four examples in our sample 
of measures for the maintenance of renewable energy sources or of railways, which 
can be considered as part of recurrent government expenditure27. This is only 
permitted under the RRF in duly justified cases28. 

30 We also assessed how measures were tagged to estimate their climate 
contribution. In the selected RRPs, we found that 36 (sub-)measures (out of 55) had 
appropriate climate coefficients. For the remaining 19 cases, we consider that the 

24  Article 18(4)(i) of RRF Regulation. 

25  SWD(2021) 12 part 1/2, Guidance to member states’ RRPs, p. 44. 

26  Paragraph 7 of opinion 04/2022 REPowerEU. 

27  World Bank working paper, Recurrent expenditure requirements of capital projects. 

28  SWD(2021) 12 part 1/2, Guidance to member states RRPs, pp. 16-17. 

 
 
 
 
 
22 

coefficient was not entirely justified. This was because these (sub-)measures did not fit 
the chosen intervention fields, which did not accurately reflect their nature or their 
objectives. Our assessment is based on the measure’s description and its milestones 
and targets, as included in the RRPs. We consider that the Commission should have 
spotted these inconsistencies when assessing the plans. In 12 of the 19 cases we 
reassigned the (sub-)measures to intervention fields that better reflect the nature of 
the investment and related coefficient. This resulted in likely overestimations of at 
least €430 million. Figure 10 presents examples where we consider that the 
intervention field – and associated climate coefficient – chosen by the member states 
and approved by the Commission is not correct. 

 
 
23 

Figure 10 – Examples of climate tracking that does not reflect the nature 
of the (sub-)measure 

Intervention fields and 
climate coefficients,
chosen by member states

(SUB-)MEASURES
from recovery and 
resilience  plans

Intervention fields and 
climate coefficients, 
as assessed by ECA

40 %
Water management and water 
resource conservation

‘Public water 
supply 
development 
programme –
Digital’ in Croatia

0 %
Government ICT solutions, 
e-services, applications

100 %
Adaptation to climate change 
measures and prevention and 
management of climate related 
risks: others

’Soft tourism 
development plans 
in the national 
parks of Muránska
Planina and 
Poloniny’ 
in Slovakia

0 %
Protection, development and 
promotion of public tourism 
assets and tourism services 

100 %
Adaptation to climate change 
measures and prevention and 
management of climate related 
risks: others

’Parnitha flagship 
investment’ in 
Greece

40 %
Nature and biodiversity 
protection, natural heritage and 
resources

Source: ECA, based on the initial RRPs and on Annex VI of the RRF Regulation. 

31 The guidance provided by the Commission for selecting measures contributing to 
the green transition and associating them with climate coefficients and intervention 
fields29 lacked specific examples of measures that would fit for each of the fields. The 

29  SWD(2021) 12 part 1/2, Guidance to member states RRPs. 

 
 
 
 
24 

guidance did not include criteria or recommendations on when a measure should have 
been split into sub-measures (paragraph 20). 

32 A measure covering a specific activity can be assigned to different intervention 
fields, counting as either 100 % or 40 %, depending on whether or not they are 
associated with necessary conditions to be met30. For example, measures for energy 
efficiency normally have a 40 % climate coefficient. To count as 100 % climate-
relevant, the RRF Regulation requires such measures to reach on average at least a 
medium-depth reduction in primary energy demand. Medium-depth renovations 
correspond to primary energy savings of between 30 % and 60 %31. In its guidance, the 
Commission specified that it was enough to reach 30 % of primary energy savings on 
average (which is the lower range allowed) for a measure to count as contributing 
100 % to climate action32. This means that simple renovations (corresponding to 
savings of less than 30 %) can be counted as 100 % contributing to climate, as long as 
other projects within the same measure achieve higher savings. 

33 The list of intervention fields relevant for climate action, as set out in the RRF 
Regulation, covers about 97 % of all RRF measures with a climate contribution. For the 
remaining cases, member states could use ad hoc intervention fields. We found that 
these ad hoc fields were exclusively used for electric or plug-in hybrid vehicles. Electric 
vehicles were tagged as 100 % and plug-in hybrid vehicles were tagged as 40 %. It is 
unclear whether the co-legislators intended to exclude such investments from the 
climate contribution. According to the Commission, the absence of such intervention 
fields was an oversight. 

34 A problematic issue relates to administrative costs. Slovakia introduced sub-
measures for administrative costs to cover the salaries of existing employees and 
contractors hired to manage the RRF. EU administrative costs do not count as climate 
spending33. In addition, for the RRF, costs for existing staff are generally considered as 
recurring national budgetary expenditure and should not be substituted by RRF 
financing (except in duly justified cases)34. However, the Slovak authorities assigned a 

30  SWD(2021) 12 part 1/2, Guidance to member states RRPs, p. 28; Annex V of the RRF 

Regulation. 

31  Commission Recommendation on Building Renovation. 

32  SWD(2021) 12 part 1/2, Guidance to member states RRPs, p. 30. 

33  Commission, climate mainstreaming webpage. 

34  SWD(2021) 12 part 1/2, Guidance to member states RRPs, p. 16. 

 
 
 
25 

positive climate coefficient to the sub-measures for administrative costs, which in our 
assessment is not justified. 

35 Following our analysis of the milestones and targets assigned to the sampled 
measures in the four member states we selected, we found examples of milestones 
and targets that do not ensure tracking progress to completion for the green transition 
or that do not cover all climate-relevant sub-measures (Table 1). This means that 
milestones and targets will trigger payments without providing information on the 
(sub-)measure’s contribution to the green transition and its results. We consider that 
the Commission could have asked for improved targets. Milestones and targets are 
used for measuring implementation progress. In our previous work35, we noted that 
they focused on outputs rather than results. Nevertheless, we found a good example 
in Slovakia, where the target for a measure to decarbonise the industry was set in 
terms of actual CO2 reductions. 

Table 1 – Examples of issues we identified with green transition targets 

Issue we identified 

Examples from member states 

Lack of climate-relevant targets to 
track progress to completion 

Milestones and targets do not 
cover all of the climate-relevant 
sub-measures 

In Slovakia, the only target for a sub-measure on 
climate adaptation is about project selection. The 
Commission will disburse the funds without 
knowing whether the projects contribute to the 
measure’s objective or whether they are 
completed at all. 

In Greece, a measure targeting industrial parks 
was split to account for investments in solar 
energy, water management, wastewater 
collection, etc. The final milestone on completion 
of the construction of all selected projects does 
not mention any of these sub-measures. 

35  Special report 21/2022, paragraph 81, and special report 26/2023, paragraph 95. 

 
 
 
 
 
26 

Weak indication of how implementing RRF measures 
contributes to the green transition 

Inconsistencies in applying the principle of ‘do no significant harm’ 

Our audit 
criteria 

36 All RRF measures, including the green transition, should ‘do no 
significant harm’ (DNSH) to the six environmental objectives within the 
meaning of Article 17 of the Taxonomy Regulation36. 

37 We examined how the principle of ‘do no significant harm’ was applied in our 
sample of measures, and their contribution to climate action. 

38 The DNSH principle aims to ensure that all measures funded by the RRF are 
sustainable from an environmental perspective. The RRF Regulation requires the 
Commission to carry out a detailed assessment of the RRPs to ensure compliance with 
the DNSH principle37 (Figure 11). For the first time, this principle was a condition for 
receiving funding. Each measure had to be addressed as part of the DNSH assessment. 
When duly justified, the assessment could take a simplified form for one or more 
environmental objectives. 

39 The Commission guidance allowed for the simplified approach “when a measure 
is tracked as 100 % supporting one of the six environmental objectives”, as it “is 
considered compliant with DNSH for that objective”38. In addition, the technical 
guidance allowed a simplified approach for a specific objective when a measure has no 
or an insignificant foreseeable impact on it. However, the DNSH technical guidance 
considered it ‘unlikely’ to apply the simplified approach for measures in areas such as 
energy, transport, waste management and industry, due to higher risks of affecting 
one or more objectives. 

36  Article 5(2) of the RRF Regulation. 

37  Article 18(4)(d) of the RRF Regulation. 

38  Technical guidance on the application of the DNSH under the RRF Regulation. 

 
 
 
27 

Figure 11 – The six environmental objectives covered by the DNSH 
principle in the RRF 

Climate change mitigation

Climate change adaptation

Sustainable use of water 
and marine resources

Pollution prevention 
and control

Circular economy

Protection and restoration

of biodiversity

Source: ECA, based on the Taxonomy Regulation. 

40 The Commission considers member states fully responsible for ensuring the 
correct implementation of the DNSH principle39. However, it has to check the 
compliance with the DNSH principle while assessing the RRPs. At the implementation 
stage, the Commission verifies the compliance with the DNSH safeguards as described 
in the Council decision approving the RRP, provided that these safeguards are part of 
the milestones and targets. A proper DNSH assessment is essential because a measure 
becomes ineligible if it breaches the DNSH principle40. We previously found that the 
Commission generally assessed appropriately the RRF measures and their DNSH 
compliance, requesting exclusions or modifications if needed41, without quantifying 
though the nature and scale of the impact of potentially harmful measures. 

41 Our analysis of the DNSH assessment carried out for the 24 sampled measures, 
showed that the DNSH guidance resulted in different applications of the principle by 
the four selected member states. For example, Croatia performed a substantive DNSH 
assessment of all six measures we sampled, while Greece always opted for the 
simplified approach, even for measures with higher risks of affecting one or more of 
the DNSH objectives (paragraph 40), which was accepted by the Commission. Our work 
confirmed that national authorities consider that the DNSH provisions are challenging 
to implement, mainly due to their complexity and novelty. 

39  Guidance on DNSH compliance during RRP implementation. 

40  Ibid. 

41  Special report 21/2022, paragraphs 58 and 60. 

 
 
 
 
28 

42 Under certain conditions42, the amended RRF Regulation exempts some of the 
REPowerEU measures from complying with the DNSH principle, such as those needed 
to ensure immediate energy security. As acknowledged in our opinion on the 
REPowerEU such an exemption poses risks to the RRF’s effectiveness towards the 
green transition, as there is a trade-off between the objective of a secure energy 
supply on the one hand, and environmental and climate concerns on the other. 

43 In addition to the DNSH principle, major buildings or development projects in the 
EU are subject to an environmental impact assessment (EIA), according to the Directive 
2011/92/EU. Figure 12 shows different approaches towards these environmental 
requirements. Our previous work on the Commission’s assessment of the RRPs 
included a similar observation43. 

Figure 12 – Assessing environmental requirements in Portugal 

Example of good practice:

A measure involving the construction of a dam included a 
reference to the EIA in its milestones. We consider that referring 
to the EIA and its requirements facilitates that national 
authorities and the Commission will check compliance when 
assessing the relevant milestones or targets before disbursing a 
payment.

Example of a more problematic approach:

For one major investment in public transport, the DNSH 
assessment did not consider the measure to have a potentially 
negative impact on climate mitigation since it was tagged 
100 % climate-relevant. However, it is unavoidable that the 
project will emit significant GHGs during the construction 
phase, and without a substantive DNSH assessment the 
national authorities could not check how these would be 
balanced with savings once the project is operational.

Source: ECA, based on information received from Portuguese authorities. 

42  Article 21c(6) of the RRF Regulation, as amended by Regulation (EU) 2023/435 on the 

REPowerEU chapters. 

43  Special report 21/2022, paragraphs 60 and 61. 

 
 
 
 
29 

Not all climate-relevant measures are as green as planned 

Our audit 
criteria 

44 Measures tagged as climate-relevant should effectively contribute 
to the green transition and demonstrate a positive contribution to 
climate action, including with regards to achieving the EU climate 
targets44. 

45 We examined the current status of implementation of climate-related measures, 
at the time of the audit. We assessed potential discrepancies compared with the initial 
design of the measure in the RRPs. 

46 Our analysis of the selected measures tagged as contributing to climate action 
raised issues about whether measures are as green as planned. Box 5 provides 
examples of discrepancies resulting from measures not as green as described, which 
we identified in all member states in our sample when assessing their implementation. 

44  Articles 4 and 19(3)(e), Annex V 2.5 of the RRF Regulation. 

 
 
 
30 

Box 5 

Examples of climate-relevant measures which are not as green as 
described 

Environmental impacts not assessed 

In Greece, a measure is intended to build a new pumped storage hydropower 
plant. This type of energy storage has the highest power range and life duration, 
compared to batteries and hydrogen storage systems, but is less environmentally 
sustainable, as it contributes to biodiversity loss in aquatic life45. We found that 
the potential harm to biodiversity was not assessed for the measure 
(paragraph 41) and mitigating steps were not identified. 

Incorrect climate contribution 

In Croatia, a measure on research and development was tagged as “clean urban 
transport” (100 % coefficient). This is a project with a focus on competitiveness 
and digitalisation. We consider that a more appropriate intervention field would 
have been “digitalisation of transport when dedicated in part to GHG emissions: 
road”, with a 40 % coefficient. We found that the project may have a positive 
spillover effect on climate because it will use electric vehicles, but this is not 
sufficient to justify the 100 % climate coefficient. 

In Portugal, a forest climate adaptation measure (100 % coefficient) financed the 
architectural projects and renovation works for civil protection centres in rural 
areas. We consider this expenditure is only moderately relevant for climate 
adaptation, and therefore a 100 % coefficient cannot be justified. 

47 We also compared the amounts allocated to the selected measures with their 
expected results. We found two cases where, based on the implementation status at 
the time of the audit visits in second half of 2023, the target could have been achieved 
by spending a fraction of the estimated costs, as the targets were set very low – Box 6. 

45  EPRS, What if increased energy storage could help fix climate change?, 2023. 

 
 
 
 
 
 
 
31 

Box 6 

Examples of measures for which the budget was set too high for the 
target to be achieved 

In Slovakia, according to the revised RRP, a measure is intended to modernise 
83 MW of energy generation capacity from renewable sources. In 2022 and 2023, 
the authorities launched three calls for proposals, for the modernisation of 
hydropower plants, or of biogas or biomethane installations. During our audit 
work, we found that eight approved applications under the call for hydropower 
plants could achieve alone 78 MW of upgraded capacity, which corresponds to 
94 % of the target. Therefore, we call into question the ambition of the target. The 
amounts Slovakia approved for these projects correspond to 30 % of the 
estimated costs of the measure. The remaining 70 % of the support could 
therefore only aim to achieve 6 % of the target, showing that the measure could 
have been achieved at a fraction of the cost as the target was set very low. 

In Portugal, a measure to renovate private buildings by improving their energy 
efficiency had an initial target of 1 million m2 of renovated area. We found that 
funded projects exceeded the target by 10 times (10 million m2) with 41 % of the 
estimated costs (€123 million out of €300 million). The REPowerEU chapter of 
Portugal topped up this measure with an additional €120 million, updating the 
target to 7.6 million m2 of renovated area. In the light of the projects that had 
already achieved the target, we consider that the target set for this measure was 
too low for the amounts allocated. 

RRF reporting on climate spending and the green transition is 
disconnected from actual costs and results 

Blind spots in capturing the performance of the RRF’s green transition 
measures 

Our audit 
criteria 

48 The Commission should monitor and assess the performance of 
the green transition in the RRF46. 

49 We examined how the RRF framework monitors the performance of the 
measures in terms of the green transition. We assessed the extent to which common 
indicators provide sufficient information about our sampled measures and the 
potential contribution of green transition measures towards the EU climate targets. 

46  Recital 63 and article 29 of the RRF Regulation. 

 
 
 
 
 
32 

50 Within the RRF’s legal framework, there is no requirement to assess the impact of 
the RRF green transition measures on the EU climate targets. However, in its 
guidelines, the Commission encouraged member states to estimate, in their RRPs, the 
impact of the reforms and investments on the reduction of GHG emissions, the share 
of renewable energy or the energy efficiency. It also encouraged member states to 
estimate the extent to which the RRPs would contribute to achieving the 2030 climate 
targets47. We found that none of the member states we selected had done so. They 
had neither assessed the contribution to climate and energy objectives at individual 
measures level, nor at RRP level. 

51 However, the RRF legal framework includes four indicators to monitor its 
performance towards the green transition (paragraph 24). In our audit work, we 
looked at the common indicators for the green transition measures and we found that 
they did not provide sufficient information on performance. In our sample of 
24 measures, 14 were problematic: 

o 

o 

o 

the results reported for one measure do not relate exclusively to RRF measures 
(Box 7 – example from Portugal); 

six are not covered by any common indicators for the green transition, which we 
found to provide only a limited coverage of the green transition (see 
paragraph 24); 

seven are covered by common indicators that do not provide relevant 
information on the progress made towards achieving the measure’s objectives 
(Box 7 – examples from Croatia and Slovakia). 

47  SWD(2021) 12 part 1/2, Guidance to member states’ RRPs, p. 4. 

 
 
 
33 

Box 7 

Examples of measures whose indicators are not sufficient to capture 
their performance on climate 

In Portugal, a measure including awareness raising and preventive actions 
concerning forest wildfires is linked to the common indicator on the population 
that benefits from such measure (common indicator 4 – Figure 9). The expected 
result is that 30 % of the whole Portuguese population benefits from the forest 
wildfire adaptation measure. We consider that this indicator does not provide 
accurate information on the impact on climate of this measure as it goes beyond 
the reach of the measure. 

In Croatia, a measure for the decarbonisation of the energy sector, which is 
mainly about replacing old transmission lines, is linked to one indicator for 
additional installed capacity from renewables (common indicator 2 – Figure 9). 
While the measure enables additional capacity, it will not achieve it per se. Hence, 
the indicator is not relevant for this measure, so its performance on climate is not 
tracked. 

In Slovakia, a measure for the construction and reconstruction of hospitals is 
covered by the indicator on savings in annual primary energy consumption 
(common indicator 1 – Figure 9). We consider, however, that there are no energy 
savings which can result from new buildings (Figure 8). The only other indicator 
for this measure comes from its target, which relates to the number of beds. This 
is not sufficient to assess the performance and impact of the measure on climate. 

52 Common indicators for the green transition are not designed to eventually track 
impacts for the performance of individual measures in terms of climate and 
environmental action (paragraph 24). Unless included in the plans as a specific target, 
GHG emissions reductions are not captured, as the common indicators do not cover 
them (paragraph 35). Similarly, the common indicator on additional capacity installed 
for renewable energy will not provide information on the replacement of fossil fuels 
with renewables for energy production. However, it is not only important to reduce 
the relative share of energy produced from fossil fuels in the energy mix, but also 
reduce the consumption of energy from fossil fuels in absolute terms48. Due to the 
limitations of common indicators, we conclude that they cannot be used to assess the 
extent to which RRF climate-related measures are contributing to climate action. 

48  SEI, Climate Analytics, E3G, IISD, and UNEP, The Production Gap: Phasing down or phasing 

up?, 2023. 

 
 
 
 
 
34 

53 In December 2023, the Commission published a report, which attempts to
estimate the potential GHG reductions resulting from a subset of the RRF measures49. 
The report concludes that the milestones and targets fulfilled until August 2023 
(153 out of 1 729) have achieved 0.5 % of this estimated reduction of GHG emissions. 
In the report, the Commission explains this low share by the early stage of 
implementation of the RRF, as well not including the milestones and targets for which 
the impact on the GHG emission reduction could not be established. 

No reporting on actual spending for climate action 

Our audit 
criteria 

54 Reporting on the RRF’s contribution to climate action should be
reliable and based on solid assumptions. To be relevant for stakeholders, 
it should provide an accurate image of the actual spending on climate 
action and the contribution to the EU climate targets50. 

55 We examined how the Commission reports on the RRF climate contribution
towards the 37 % target and on the national RRPs allocations (paragraph 06). 

56 The requirement to dedicate 37 % of national allocations to climate action was
checked upfront at the design and approval phases of the RRPs (paragraph 09). Then in 
its 2022 annual management performance report on the performance of the EU 
budget, the Commission reported that the RRF had achieved a climate contribution of 
€203 billion, or 40 %51. This was based on the estimated costs as indicated by member 
states in their initial RRPs and not on actual expenditure. As at February 2024, the 
planned climate contribution increased, due to the revisions of the RRPs and, 
according to the Commission, it accounts for €275 billion or 42.5 % (Figure 5). 

57 The Commission does not monitor the actual share and amounts of the RRPs’
contribution to climate, as the RRF Regulation does not require the Commission to 
report on actual climate spending contributing towards the 37 % target, but on 
estimated costs (paragraph 56). In the framework of their RRF financing or loan 
agreements with the Commission, member states are obliged to declare the total 

49  European Commission, NGEU Report on the impact of green bonds, 2023, p. 17. 

50  Based on International Public Sector Accounting Standards Board, Recommended practice 

guideline 3 – Reporting Service Performance Information. 

51  European Commission, Annual management and performance report 2022, Volume II, p. 9. 

35 

cumulative disbursed expenditure contributing to climate objectives52. According to 
the agreements, this information is not taken into account for the RRF payments. In 
our view, the Commission could use it to monitor actual climate spending. This, 
however, is not the case. 

58 Actual costs for any RRF measure, regardless of its climate contribution, can differ 
significantly from the costs estimated when the RRPs were approved with an impact 
on the share of climate contribution. As confirmed by the Commission, payments 
should be made even if the actual cost of the underlying measure is lower (or higher) 
than initially estimated (paragraph 47 and Box 6), provided that milestones and targets 
are fulfilled. Regardless of differences, the full amount originally planned as the cost of 
this measure will still count in full towards the RRPs’ climate target. We therefore 
consider that there is a risk that reported information may not reflect the actual 
climate contribution of a RRP, impacting the accountability on the 37 % target. 

59 Additionally, there is a risk that delayed implementation of climate-related 
projects and the slow absorption will have an impact on the achievement of the full 
climate contribution of €275 billion (paragraph 56). Projects are delayed, for instance, 
due to delays in public procurement procedures or delays in obtaining operating 
authorisations. Our work also found that national authorities underestimated the time 
required to implement measures. Other measures face lower demand than expected, 
which affects the absorption of funds (Box 8). The actual climate contribution from the 
RRPs will be smaller than initially calculated if the related measures are either not 
completed, or only partially completed within the RRF deadlines. 

52  Article 7 of the Financing agreement between the Commission and the member states. 

 
 
 
36 

Box 8 

Examples of measures facing challenges that could affect climate 
reporting 

No bidders interested in the measure 

In Slovakia, the public procurement for building a new hospital that was planned 
for completion in mid-2026 is still ongoing. The initial tender attracted zero 
bidders, as no contractor wanted to commit to the tight deadlines, as confirmed 
by the Slovak authorities. According to the Slovak RRP, this is one of the major 
investments contributing to the green transition. 

Delays in implementation 

Projects for the production of hydrogen have to go through a lengthy process to 
obtain an authorisation to operate. Delays in obtaining the permits and 
disruptions in the supply chain have also slowed down implementation. In 
Portugal, at the time of our visit (July 2023), only one of the 23 approved 
projects had received an advance payment to start the works. 

Low interest in the measure 

In Greece, a measure for electromobility to finance charging points had only 
received 171 applications by January 2024. This represents 2.7 % of the final 
target, which shows a low level of interest in terms of participating in the action 
by final recipients. Similarly, only 6 % of the planned number of taxis are being 
replaced with electric vehicles. To deal with the low uptake, national authorities 
have increased the support to replace the old taxis and have extended the 
application deadline for beneficiaries. 

No link between expenditure and green transition reporting 

Our audit 
criteria 

60 Reporting on the green transition should be reliable and based on 
solid assumptions. Published information should clearly disclose the 
methodology used to compile it53. 

61 We examined the methodology used by the Commission to report on the 
progress towards the green transition pillar. We also assessed the reliability of the 
information on the green transition disclosed in the RRF Scoreboard. 

53  Based on International Public Sector Accounting Standards Board, Recommended practice 

guideline 3 – Reporting Service Performance Information. 

 
 
 
 
 
 
 
 
 
37 

62 The Commission applies a methodology to report on the green transition which is 
different to that used to calculate the 37 % climate contribution. For the green 
transition, the primary or secondary pillar assigned to each measure is weighted the 
same: the methodology does not differentiate according to whether the estimated 
contribution to the climate and environmental objective is significant (100 %) or 
moderate (40 %). When a measure is assigned to the green transition under both 
primary and secondary pillars its milestones and targets count twice towards the green 
transition. The Commission estimates that such cases accounted for about 1.8 % of the 
sub-measures included in the 27 original RRPs. 

63 Another difference between the two methodologies is that the contribution to 
the 37 % target is only calculated ex ante (paragraph 56). Instead, the reporting on the 
green transition is meant to track progress, and the RRF legislation includes an 
obligation to report on expenditure by pillar54 (Figure 3). The Commission considers 
this provision to be fulfilled by reporting on disbursements to member states based on 
the satisfactory fulfilment of milestones and targets (paragraph 03). In our view, the 
RRF Regulation is unclear on whether the reporting should refer to actual rather than 
estimated expenditure, and the Commission only reports estimated expenditure55. 

64 In order to report on progress on the disbursements by pillar, the Commission 
calculates the unit value of a milestone or target. This number is obtained by dividing 
the total RRF allocation for a member state by its total number of milestones and 
targets56. Milestones and targets are not directly assigned to the pillars. To establish 
which are relevant to the green transition, the Commission checks the primary and 
secondary pillars of the underlying measures (paragraph 05). Milestones and targets 
are considered to be contributing to the green transition pillar as long as at least one 
of their sub-measures is associated with it. 

65 The RRF Scoreboard (paragraph 05) provides information on Commission’s 
disbursements by pillar and on the achieved milestones and targets. As of 
February 2024, member states had received €103 billion in grants and €54 billion in 
loans (on top of the 13 % of pre-financing for about €68 billion). Disbursements linked 
to the green transition pillar represents 17 % (€27.2 billion) of all the disbursements so 
far (Figure 13). Considering that climate-relevant measures alone should contribute to 
42.5 % of the RRF allocated amount (paragraph 09), and that green transition should 

54  Article 29 (3) of the RRF Regulation. 

55  Special report 26/2023, paragraph VII. 

56  Special report 26/2023, paragraph 78. 

 
 
 
38 

include 34 additional environmental measures which are not captured by the climate 
tracking exercise, this amount is still fairly low. 

Figure 13 – Disbursements by pillar, as displayed in the RRF scoreboard 
(in billion euros) 

Green 
transition

Digital 
transformation

Smart, sustainable 
and inclusive growth

Social and territorial 
cohesion

Health, and economic, 
social and institutional 
resilience

Policies for 
the next generation

RRF grants disbursed

RRF loans disbursed

€27.2 billion

€17.0 billion

€39.8 billion

€30.4 billion

€35.2 billion

€7.7 billion

Source: RRF scoreboard, data as of February 2024. 

0

20

40

66 The approach used to report can under- or over-estimate the amounts reported 
as disbursed for the green transition, as the unit value of milestones and targets reflect 
neither the actual nor estimated costs of the measures. For example, a measure on 
energy efficiency in buildings in Portugal has targets related to the renovated area. 
Using the unit value, renovating 45 000 m2 will be counted towards the green 
transition in the same way as renovating 315 000 m2. 

67 Our previous report on the RRF performance monitoring framework considered 
the lack of data on actual expenditure as limiting the assessment of the efficient use of 
RRF resources and the level of the RRF’s performance at the level of its pillars. It 

 
 
 
39 

therefore recommended the Commission57 to report on actual expenditure, which was 
rejected by the Commission. 

68 Reporting on the green transition is further affected by the fact that most of the 
early milestones and targets are linked to the very first steps of implementation (such 
as the approval of a call for projects). This means that early payments to member 
states are not necessarily linked to actual projects, if their milestones and targets are 
linked to reforms or preparatory stages to launch a measure, for example. For those 
projects that are not completed, or for measures failing to fulfil the last milestone or 
target, the Commission cannot recover funds already disbursed, as the RRF Regulation 
does not provide for this possibility. As the Scoreboard reflects amounts disbursed to 
member states, the Commission would not revise what is reported in such cases. 

69 Overall, we found that the green transition reporting presented in the RRF 
Scoreboard is confusing. Neither estimated amounts nor actual costs of the green 
transition measures are taken into account, as the reporting is based on unit values 
(paragraph 66). The RRF Scoreboard, therefore, does not provide users with complete 
and reliable information about the actual amounts spent on the green transition. 

57  Special report 26/2023, paragraph 87 and recommendation 4b. 

 
 
 
 
 
40 

Conclusions and recommendations 

70 One of the goals of the Recovery and Resilience Facility is to contribute to the 
green transition and the EU climate targets. In particular, member states must 
dedicate at least 37 % of the planned funds for climate-related actions 
(paragraphs 01-09). 

71 Our audit sought to assess whether the design and implementation of the Facility 
and the national recovery and resilience plans are contributing effectively to the green 
transition. The Recovery and Resilience Facility provided an incentive to invest on 
climate action and the green transition. However, we found weaknesses in the design 
of the Facility that we confirmed while assessing its implementation. We conclude that 
the weaknesses summarised in Figure 14 and detailed below, call into question the 
achievement of its objectives towards the green transition. 

Figure 14 – Weaknesses in design and implementation of the Facility 
towards green transition 

Performance towards 
achieving the green 
transition cannot be 
assessed

No reporting 
on actual 
expenditure

Weaknesses in the 
application 
of the ‘do no significant 
harm’ principle

Source: ECA. 

At the planning stage, 
climate action is tracked, 
but environmental 
objectives are not 

High level 
of approximation 
in climate tracking

Potential 
overestimations 
of €34.5 billion,
due to the climate 
coefficients reassessed 
by the ECA

Green transition pillar

37 % contribution 
to climate action

Actual contribution
to EU climate targets 
not accounted for

Climate-related 
investments not always 
linked to relevant 
milestones and targets

 
 
 
41 

72 Our analysis shows that while climate action is tracked and counts towards the 
37 % target, it is narrower in scope than the green transition, which encompasses 
biodiversity and environmental objectives in addition to the climate objectives. The 
methodology used to track climate action is based on three climate coefficients (0 %, 
40 %, and 100 %) linked to expected contribution of measures to climate objectives, as 
foreseen in the RRF Regulation. Single climate coefficients were often applied to 
measures that encompass a wide set of actions, not all of which are linked to climate, 
and their underlying costs. To better estimate climate contribution, the Commission 
introduced the concept of sub-measures. In practice, the climate contribution from the 
measures was not always fine-tuned, causing a high level of approximation, leading to 
potential overestimations, in particular for complex measures with elements that 
should have different climate contributions (paragraphs 15-22). 

73 Our work also shows that some climate coefficients set in the RRF Regulation 
(railways, electricity grids and new buildings) do not reflect the expected contribution 
to the EU climate targets, for instance not considering greenhouse gas emissions of the 
construction phase of the investments, leading in reality to a lower climate 
contribution. Using more conservative climate coefficients for these three categories 
than what is laid down in the Regulation, we calculated likely overestimations of 
€34.5 billion of the climate contribution of the RRF. In addition, the performance 
framework does not allow to track the impact of all the measures supporting the green 
transition and it does not cover key aspects, such as the greenhouse gas emissions 
reductions or the contribution to the environmental objectives (paragraphs 23-24). 

Recommendation 1 – Better estimate climate spending under 
future funding instruments 

The Commission should ensure that climate-related measures, interventions or actions 
are broken down to a level which allows them to be linked to the appropriate and 
justifiable climate contribution, resulting in a more detailed and accurate assessment 
of climate spending. 

Target implementation date: when proposing any instruments that require climate 
tracking 

 
 
42 

Recommendation 2 – Ensure adequate design of future funding 
instruments that are to support the climate and environmental 
objectives and targets 

The Commission should: 

(a)  assess how funding instruments that work towards the EU’s climate objectives 
and targets would provide information on their actual contribution to achieving 
them; 

(b)  cover, in its framework for performance monitoring and evaluation, those 

investments relevant for climate and environmental objectives. 

Target implementation date: when proposing any instruments with climate and 
environmental objectives 

74 We found that the inclusion of measures supporting the green transition in the 
national recovery and resilience plans was affected by the limited timeframe of the 
Facility, and the extent to which national plans contribute to the climate action was 
unclear. Some measures were assigned to intervention fields that did not reflect their 
nature, resulting in higher climate contributions, or were not relevant for climate, such 
as sub-measures for administrative costs. We also found that some climate-related 
investments were not sufficiently linked to climate-relevant or impactful milestones 
and targets (paragraphs 25-35). 

75 We also found inconsistencies in the application of the ‘do no significant harm’ 
principle, as, when applying simplified approaches, member states were not always 
required to thoroughly assess the need for mitigation measures associated with their 
investments. We identified instances where member states financed projects that did 
not correspond to a measure’s description, with impacts on the effectiveness and level 
of climate contribution (paragraphs 36-47). 

 
 
43 

Recommendation 3 – Enhance the performance of green 
transition measures 

The Commission should: 

(a)  take measures to address inconsistencies in the application of the ‘do no 

significant harm’ principle by the member states when they use the simplified 
approach. 

Target implementation date: June 2025 

(b) 

if measures linked to the green transition are revised, ensure that milestones and 
targets track measures’ progress up to completion to allow assessment of 
whether the measures have achieved their climate and environmental objectives. 

Target implementation date: December 2025 

76 The Commission does not have sufficient information to evaluate the 
performance of the measures contributing to the green transition, due to the 
limitations in the monitoring framework. The Commission only reports on climate-
related amounts allocated ex ante. Therefore, the information presented does not take 
into account the level of actual spending, which is affected by various factors, such as 
delays and slow absorption. These factors can lead to over- and under-estimation of 
the climate contribution. At the same time, member states report on disbursed climate 
expenditure, but this information is not used by the Commission to report towards the 
37 % quantitative target. Therefore, the Commission cannot guarantee full 
accountability on it (paragraphs 48-59). 

77 The Recovery and Resilience Scoreboard tracks the payments made from 
Commission to the member states. Following the RRF principles, these payments are 
not linked to the underlying costs of a measure and, as a consequence, they do not 
represent the level of actual climate-related expenditure. In addition, achieved 
milestones and targets do not necessarily reflect the ambition of the corresponding 
measure to contribute to the green transition. This makes the reporting on green 
transition unreliable for reporting actual expenditure (paragraphs 60-69). 

 
 
44 

Recommendation 4 – Improve reporting on climate spending 
under the Recovery and Resilience Facility 

The Commission should compile and publish the information already provided by 
member states on the actual costs of climate-related measures, compare them with 
the estimated costs in the national plans, and recalculate the actual climate 
contribution towards the 37 % target. 

Target implementation date: December 2026 

Note: In our special report 26/2023, the Commission did not accept our recommendation that 
it should report on actual expenditure financed by the RRF under the six pillars, as a basis for 
assessing the efficient use of resources. 

This report was adopted by the Court of Auditors in Luxembourg at its meeting of 
4 July 2024. 

For the Court of Auditors 

Tony Murphy 
President 

 
 
 
 
 
 
 
Annex – Our selection of measures 

45 

Relevant area/ 
member state 

Renewables 
and the energy 
sector 

Energy 
efficiency 

Sustainable 
mobility  

Greece 

Croatia 

Portugal 

Slovakia 

EL-C[1,1]-I[16926] Support of 
the installation of storage 
systems to enhance 
renewable energy 
penetration 

HR-C[C12]-I[R1-I1] Revitalising, 
building and digitising the 
energy system and supporting 
infrastructure to decarbonise 
the energy sector 

PT-C[C14]-I[i01] Renewable 
hydrogen and other gases 

SK-C[C1]-I[I2] Modernising the 
existing renewable electricity 
sources (repowering) 

EL-C[1,2]-I[16872] Energy 
renovation of residential 
buildings 

EL-C[1,3]-I[16924] 
Electromobility – charging 
points, electric buses, 
electric taxis 

Decarbonising 
industries 

EL-C[4,7]-I[16980] RRF Loan 
Facility 

Sustainable use 
of natural 
resources 

EL-C[1,4]-I[16849] National 
Reforestation Plan and 
Parnitha flagship investment 

Other sectors 

EL-C[4,6]-I[16634] New 
Industrial Parks 

HR-C[C61]-I[R1-I1] Energy 
renovation of buildings 

PT-C[C13]-I[i01] Energy 
efficiency of residential buildings 

SK-C[C2]-I[I1] Energy efficiency 
of family houses 

HR-C[C14]-I[R5-I2] Research, 
development and production of 
new mobility vehicles and 
supporting infrastructure 

HR-C[C111]-I[R4-I2] Financial 
instrument for micro, small and 
medium-sized enterprises 

HR-C[C15]-I[R1-I1] Construction 
and equipping of logistic and 
distribution centres for fruit and 
vegetables 

HR-C[C13]-I[R1-I2] Public water 
supply development 
programme 

PT-C[C15]-I[i01] Expansion of the 
metro network  

PT-C[C11]-I[i01] Decarbonisation 
of industry  

SK-C[C3]-I[I1] The development 
of low-carbon transport 
infrastructure 

SK-C[C4]-I[I1] The operation of 
the industry decarbonisation 
scheme 

PT-C[C08]-I[i05] Forest 
programme 

SK-C[C5]-I[I1] Adaptation of 
regions to climate change 

PT-C[C12]-I[i01] Bioeconomy 

SK-C[C11]-I[I2] New hospital 
network – construction, 
reconstruction and equipment 

 
 
46 

Abbreviations 

DNSH: Do no significant harm 

GHG: Greenhouse gas 

MW: Megawatt 

NGEU: NextGenerationEU 

RRF: Recovery and Resilience Facility 

RRP: Recovery and resilience plan 

 
 
 
47 

Glossary 

Absorption: Extent to which member states have received RRF funding from the 
Commission for the satisfactory fulfilment of milestones and targets. 

Climate action: Action to address climate change and its impact. 

Climate adaptation: Reducing the vulnerability of countries and communities to 
climate change by increasing their ability to absorb its impacts. 

Climate coefficient: Weighting assigned to EU spending on projects, measures or 
actions to reflect the extent to which they incorporate climate considerations. 

Climate contribution: Estimate of a member state’s RRF spending on climate action. 

Climate mitigation: Reducing or limiting the emission of greenhouse gases due to their 
effect on the climate. 

Climate tracking: Monitoring progress towards the targets of spending on climate 
action. 

Common indicator: Measurable variable providing information on the progress of the 
implementation of the recovery and resilience plans towards common objectives and 
the overall performance of the RRF. 

Do no significant harm: Principle that investment measures should have no major 
detrimental environmental impact. 

Intervention field: Category of activities financed by the RRF, the European Regional 
Development Fund, the Cohesion Fund or the European Social Fund. 

Investment: Expenditure on an activity, project or other action within the scope of the 
RRF Regulation that is expected to bring beneficial results to society, the economy or 
the environment. 

Milestone: Qualitative measure of a member state’s progress towards completing a 
reform or investment in its recovery and resilience plan. 

Monitoring: Systematically observing and checking progress, partly by means of 
indicators, towards the achievement of an objective. 

NextGenerationEU: Funding package to help EU member states recover from the 
economic and social impact of the COVID-19 pandemic. 

 
 
48 

Performance: Measure of how well an EU-funded action, project or programme has 
met its objectives and provides value for money. 

Pillar: Term used for each of the six policy areas that make up the RRF: (i) green 
transition; (ii) digital transformation; (iii) economic cohesion, productivity and 
competitiveness; (iv) social and territorial cohesion; (v) health, economic, social and 
institutional resilience; (vi) policies for the next generation. 

Recovery and Resilience Facility: The EU’s financial support mechanism to mitigate the 
economic and social impact of the COVID-19 pandemic, stimulate recovery and meet 
the challenges of a greener and more digital future. 

Recovery and resilience plan: Document setting out a member state’s intended 
reforms and investments under the Recovery and Resilience Facility. 

Recovery and resilience scoreboard: Commission website showing how the 
implementation of member states’ recovery and resilience plans is progressing. 

Reform: In the context of the RRF, a change resulting in significant, lasting 
improvement in the functioning of a market, a policy, or institutional or administrative 
structures, or in significant progress towards policy objectives such as growth and jobs, 
resilience and the green and digital transitions. 

REPowerEU: EU initiative to end dependence on fossil fuels, diversify energy supplies 
and accelerate the clean energy transition. 

Target: Quantitative measure of a member state’s progress towards completing a 
specific reform or an investment in its recovery and resilience plan. 

 
 
 
 
49 

Replies of the Commission 

https://www.eca.europa.eu/en/publications/sr‐2024‐14 

Timeline 

https://www.eca.europa.eu/en/publications/sr‐2024‐14 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
50 

Audit team 

The ECA’s special reports set out the results of its audits of EU policies and 
programmes, or of management-related topics from specific budgetary areas. The ECA 
selects and designs these audit tasks to be of maximum impact by considering the risks 
to performance or compliance, the level of income or spending involved, forthcoming 
developments and political and public interest. 

This performance audit was carried out by Audit Chamber I – Sustainable use of 
natural resources, headed by ECA Member Joëlle Elvinger. The audit was led by ECA 
Member Joëlle Elvinger, supported by Ildikó Preiss, Head of Private Office and 
Paolo Pesce, Private Office Attaché; Ramona Bortnowschi, Principal Manager; 
Antonella Stasia, Head of Task; Marika Meisenzahl and Asimina Petri, Deputy Head of 
Task; Monika Dedicova and Zvonimir Novoselić, Auditors; Laura Mcmillan, 
Jerónimo Montenegro, Marin Pažanin, Jennifer Schofield, Hana Vendlekova and 
Aikaterini Vraila provided linguistic support. 

From left to right: Ildikó Preiss, Zvonimir Novoselić, Joëlle Elvinger, 
Jerónimo Montenegro, Antonella Stasia, Paolo Pesce, Ramona Bortnowschi, 
Monika Dedicova, Asimina Petri, Marika Meisenzahl, Aikaterini Vraila and 
Marin Pažanin. 

 
 
 
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52 

The Recovery and Resilience Facility provided member states with 
an incentive to invest in the green transition. They planned to 
spend around €275 billion on climate action as part of the green 
transition pillar. However, our analysis revealed shortcomings in 
the Facility’s design and implementation of green transition 
measures. This led to potential overestimations of amounts 
allocated to climate action, discrepancies between planning and 
practice, and little indication of the measures’ actual contribution 
to the green transition. There is no requirement in the legislation 
to assess the Facility’s contribution to the EU’s climate objectives, 
nor report on actual spending, limiting the relevance for 
stakeholders. We make several recommendations to improve 
design and effectiveness of EU funds relevant for green transition. 

ECA special report pursuant to Article 287(4), second 
subparagraph, TFEU. 

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