Absorption of funds from the Recovery and Resilience Facility : progressing with delays and risks remain regarding the completion of measures and therefore the achievement of RRF objectives. Special report 13, 2024.
Date: 2024-10-24
Institutions: European Court of Auditors
Subjects: EU Member State, EU financial instrument, EU financing arrangements, coronavirus disease, economic and social cohesion, economic recovery, economic reform, investment, performance audit, report

EN 

2024 

13 

Special report  Absorption of funds from the 

Recovery and Resilience Facility 
Progressing with delays and risks remain 
regarding the completion of measures and 
therefore the achievement of RRF objectives 

 
 
 
Contents 

Executive summary 

Introduction 

Audit scope and approach 

Observations 

Pre-financing facilitated the disbursement of funds initially, but 
RRF absorption is facing delays and does not necessarily mean 
that funds have reached the final recipients 

Pre-financing facilitated the disbursement of funds initially 

Absorption of RRF funds is progressing but generally faces delays 

Several factors contribute to the delays 

Disbursed funds have not yet necessarily reached final recipients and the 
term “final recipient” is not always used consistently 

The Commission and member states took actions to facilitate 
absorption, but it is too early to assess whether they have a 
positive impact 

All sampled member states requested amendments to their RRPs, but the 
impact on absorption remains to be seen 

The Commission provided guidance with regard to the specific rules for 
implementing the RRF, but it still leaves room for interpretation 

Member states in our sample took actions to increase administrative 
capacity, but still face staffing shortages 

Member states and the Commission set up systems to monitor 
implementation progress, but follow-up of delays is not systematic 

The design of the RRF entails risks to absorption and the 
completion of measures by 31 August 2026 

The quantity and nature of outstanding milestones and targets poses risks to 
absorption and the completion of measures 

Disbursements do not necessarily reflect the quantity and importance of 
milestones and targets included 

2 

Paragraph 

I-XI 

01-09 

10-16 

17-90 

17-56 

18-20 

21-27 

28-52 

53-56 

57-75 

59-63 

64-68 

69-70 

71-75 

76-90 

77-85 

86-90 

 
 
3 

91-99 

Conclusions and recommendations 

Annexes 

Annex I – Main information on ECA’s surveys to member states 

Annex II – Procedural steps and time (in days) needed to fulfil 

Annex III – Functionalities of national IT monitoring systems for 
tracking absorption of RRF funds at national level 

Annex IV – Percentage of reforms and investments to be 
completed per year, by member state 

Abbreviations 

Glossary 

Replies of the Commission 

Timeline 

Audit team 

 
 
 
 
4 

Executive summary 

I In February 2021, the EU established the Recovery and Resilience Facility (RRF), 
amounting to €723.8 billion, with the aim of mitigating the economic impact of the 
pandemic, for which swift uptake of funding was essential, and making member states’ 
economies more resilient. The RRF is implemented under direct management by the 
Commission and the member states as beneficiaries and borrowers of funds must 
ensure that measures under the RRF are implemented in compliance with relevant EU 
and national law. 

II We included this audit in our annual work programme due to the materiality of the 
amounts involved and the novelty of the RRF’s funding model. We examined the RRF’s 
design and implementation to assess whether: 

o 

o 

o 

RRF funds had been disbursed as planned; 

the actions taken by the member states and the Commission have ensured that 
funds were absorbed as planned; and 

there are inherent risks with regards to absorption and completion of measures in 
the second half of the RRF’s implementation. 

III We conclude that the absorption of RRF funds is progressing with some delays, 
and that there are risks to absorption and to the completion of measures in the second 
half of the RRF’s implementation. 

IV The pre-financing of up to 13 % provided for in the legislation allowed more funds 
to be paid out quickly at the beginning of the RRF; however, absorption faced delays 
for several reasons. By the end of 2023, the Commission had disbursed around 
€213 billion in total, including €56.5 billion in the form of pre-financing. By the end 
of 2023, member states had in total requested €228 billion of the €273 billion that was 
expected to have been requested based on their operational arrangements. Seven 
member states, however, had not received any funds for the satisfactory fulfilment of 
milestones and targets from the RRF by the end of 2023. 

V While the reasons for delays vary among member states, the most common ones 
include changes in external circumstances (such as inflation or supply shortages), 
underestimation of the time needed to implement measures, uncertainties regarding 
specific RRF implementation rules (such as the “do no significant harm” principle) and 
challenges related to the administrative capacity of member states. 

 
 
5 

VI In October 2023, about half of the funds received had been paid to final 
recipients. However, not all member states provided complete and consistent 
information on the current location of RRF funds. In addition, the definition of “final 
recipient” leaves room for interpretation. 

VII Both the Commission and the member states took actions to address the delays; 
however, it is too early to assess whether they have a positive impact. For example, 
the member states proposed amendments to their initial recovery and resilience plans 
and the Commission provided guidance and support to facilitate the implementation 
of the RRF. However, the impact of the amendments to the recovery and resilience 
plans remains to be seen, and some member states consider that parts of the guidance 
leave room for interpretation or are difficult to apply due to the complexity and 
novelty of the guidance itself. 

VIII Member states also took action to increase their administrative capacity, but 
challenges – namely recruiting the necessary staff – remain. Both the Commission and 
member states have set up IT systems to monitor implementation progress, but for 
two of the sampled member states the national systems did not provide sufficient 
information to identify delays in good time. Furthermore, although the Commission 
monitored progress through its regular contacts with the member states, it did not 
systematically ask them to provide information on the actions taken to address delays 
reported by member states, even though the Commission implements the RRF under 
direct management and bears ultimate responsibility. 

IX We consider that there are risks to timely absorption and the completion of 
measures in the second half of the RRF’s implementation. More specifically, a 
significant number of milestones and targets remain to be fulfilled and they may be 
more difficult to achieve. In addition, the shift from reforms to investments is likely to 
further increase the risk of delays. 

X We also noted that the disbursements of RRF funds to member states do not 
necessarily reflect the quantity and importance of the milestones and targets included 
therein. Furthermore, the relationship between amounts received under the RRF and 
the achievement of milestones and targets differs among member states. As the RRF 
Regulation does not provide for the possibility of recovering funds related to already 
fulfilled milestones and targets if measures are not completed, this poses risks as it 
may result in RRF funding being paid without member states having completed the 
corresponding measures. 

 
 
6 

XI Based on these findings, we recommend that the Commission: 
o 

ensure a consistent application of the definition of “final recipient”; 

o 

provide member states with additional guidance and support; 

o  monitor and mitigate the risk of non-completion of measures and the financial 

consequences thereof; 

o 

strengthen the design, with regard to absorption, of future instruments based on 
financing not linked to costs. 

 
 
 
 
7 

Introduction 

01 In response to the COVID-19 pandemic, a recovery fund worth more than 
€800 billion (in current prices) – Next Generation EU – was set up. Its centrepiece is the 
Recovery and Resilience Facility (RRF)1, established in February 2021, with a maximum 
total value of €723.8 billion (in current prices). 

02 The scope of the RRF, as defined in the RRF Regulation2, comprises measures 
(either investments or reforms) under the six priority areas or “pillars” shown in 
Figure 1. The RRF finances reforms and investments in EU member states that took 
place from the start of the pandemic in February 2020 up until August 20263. 

Figure 1 – The six pillars 

Green transition

Digital transformation

Smart, sustainable and inclusive 
growth, including economic 
cohesion jobs, productivity, 
competitiveness, research, 
development and innovation, and 
a well-functioning internal market 
with strong SMEs

Social & territorial cohesion

Health, and economic, social 
and institutional resilience
with the aim of, inter alia, 
increasing crisis preparedness 
and crisis response capacity

Policies for the next generation, 
children and the youth, such as 
education and skills

Source: ECA, based on Commission’s Recovery and Resilience Scoreboard. 

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

12 February 2021 establishing the Recovery and Resilience Facility, referred to in this report 
as the “RRF Regulation”. 

2  Article 3 of the RRF Regulation. 

3  For examples of reforms and investments funded under the RRF, see Special 

Report 21/2022: The Commission’s assessment of national recovery and resilience plans, 
Annex IV. 

 
 
 
 
8 

03 The purpose of the RRF is to mitigate the economic and social impact of the 
COVID-19 pandemic, for which swift uptake of funding was essential, and make 
member states’ economies and societies more sustainable, resilient and better 
prepared for the challenges and opportunities of the green and digital transitions. Its 
objective is therefore twofold – enhancing recovery from the pandemic and improving 
resilience to future crises. 

04 The Commission is ultimately responsible for the implementation of the RRF as it 
manages the RRF4 directly, and the member states as the beneficiaries and borrowers 
of funds must ensure that measures under the RRF are implemented in compliance 
with relevant EU and national law.  

05 Under the RRF, the Commission can provide financial support of up to 
€338.0 billion in grants and up to €385.8 billion in loans5. Each member state is 
eligible for a certain amount of support, based on a formula (“allocation key”) for 
grants and a cap for loans 6. 

06 To benefit from this support, member states submitted their recovery and 
resilience plans (RRPs), to be assessed by the Commission and subsequently approved 
by the Council in form of Council Implementing Decisions7. The Commission then 
agreed operational arrangements with each member state, which included the details 
and technical aspects of implementation, such as an indicative schedule for the 
payment of instalments, additional interim steps for the achievement of milestones 
and targets, and arrangements for providing access to underlying data. The RRF 
Regulation also specifies four circumstances under which a member state may amend 
its RRP8: 

4  Article 8 of the RRF Regulation. 

5  These amounts do not include the additional REPowerEU funding. 

6  Articles 11 and 14(5) of the RRF Regulation. 

7  Article 20 of the RRF Regulation. 

8  Article 21 of the RRF Regulation. 

 
 
 
9 

(1) 

if the maximum financial contribution is updated9; 

(2) 

if milestones and targets are no longer achievable because of objective 
circumstances; 

(3) 

if the member state requests loans; and 

(4)  when the member state includes its REPowerEU chapter10 in its RRP, in line with 

the EU’s energy transition plan. 

In case of amendments, the Council Implementing Decision and operational 
arrangements are also amended accordingly. 

07 For Council Implementing Decisions adopted by 31 December 2021, member 
states could request an advance in the form of pre-financing amounting up to 13 % of 
their total grant allocations and, where applicable, of their total loan amounts 11. The 
pre-financing is deducted (“cleared”) proportionally from each subsequent payment. 
For REPowerEU, member states could receive pre-financing of up to 20 % of their 
additional funding, subject to the approval of their REPowerEU chapters. 

08 The RRF is an instrument based on “financing not linked to costs”, meaning that, 
apart from pre-financing, all payments are based on member states’ achievement of 
relevant milestones and targets. The value of each payment request is not based on 
the estimated costs of achieving the milestones and targets included therein. Figure 2 
illustrates the steps for requesting funding under the RRF. 

9  Commission note to the Council and European Parliament of 30 June 2022: “RRF: Update of 

the maximum financial contribution”. 

10  Regulation (EU) 2023/435 amending Regulation (EU) 2021/241 as regards REPowerEU 

chapters in recovery and resilience plans and amending Regulations (EU) No 1303/2013, 
(EU) 2021/1060 and (EU) 2021/1755, and Directive 2003/87/EC. 

11  Article 13 of the RRF Regulation. 

 
 
 
10 

Figure 2 – RRF implementation process 

Member State

European Commission

Council

RRP submitted

2 months

RRP assessed

1 month

Council Implementing 
Decision

Operational 
arrangements 
agreed 

Payment request 
submitted once milestones 
and targets achieved

2 months

Preliminary assessment 
of milestones and targets

Decision authorising 
disbursement

Payment

4 weeks

Economic and Financial 
Committee opinion

Source: ECA. 

09 Member states can submit up to two payment requests per year following the 
achievement of the related milestones and targets. The Commission then has two 
months to assess the payment request and verify the satisfactory fulfilment of the 
underlying milestones and targets. After a positive assessment, the Council’s Economic 
and Financial Committee has 4 weeks to provide an opinion and the Commission 
adopts a decision through the comitology examination procedure (i.e. involving a 
committee of representatives from all member states) authorising the disbursement of 
funds 12. 

12  Article 24(2)-(5) of the RRF Regulation. 

 
 
 
 
 
 
11 

Audit scope and approach 

10 For the RRF to achieve its twofold objective of recovery and resilience13, timely 
absorption of funds is essential. It helps to avoid bottlenecks in implementing 
measures towards the end of the implementation period and thereby reduces the risk 
of inefficient use of funds and of irregularities. 

11 In the absence of a clear definition in the RRF Regulation, we define absorption 
as EU funding paid out by the Commission to the member states. In the context of the 
RRF, member states are the beneficiaries, and funds are paid by the Commission to a 
member state upon satisfactory fulfilment of milestones and targets. In order to obtain 
a comprehensive overview, we also looked at the payments to the final recipients, as 
well as at pre-financings, in this audit. 

12 Furthermore, we base our assessment of timely absorption on whether member 
states submitted their payment requests in line with the indicative timetable agreed in 
their operational arrangements. In addition, we assessed whether there are any 
significant risks to the completion of measures within the RRF implementation period 
(February 2020 to August 2026) and thus to the achievement of the RRF’s objectives in 
the long term. 

13 We included this audit in our annual work programme due to the materiality of 
RRF spending and its novelty as a funding instrument. The audit covered the period 
from the RRF’s inception in February 2021 until the end of 2023. This allowed us to 
assess the status and implementation progress of the measures in the first half of the 
RRF implementation period and to identify the causes of problems and risks to the 
timely absorption of funds by member states and, ultimately, to the completion of 
measures. 

14 We examined the RRF’s design and implementation to assess whether: 

o 

o 

RRF funds had been disbursed as planned; 

the actions taken by the member states and the Commission had ensured that 
funds were absorbed as planned; 

13  Article 4(1) of the RRF Regulation. 

 
 
 
12 

o 

there are inherent risks with regards to absorption and completion of measures in 
the second half of the RRF’s implementation. 

15 Our audit work included: 

o 

o 

o 

o 

o 

o 

o 

o 

o 

desk reviews of documents and other publications or information relevant to the 
absorption of RRF funds; 

a review and analysis of Commission’s assessments of RRPs and payment requests 
for the four member states in our sample (Spain, Italy, Slovakia and Romania), 
which were selected based on their progress in implementing the RRF, the 
materiality of the RRF funds allocated to them and the increase in their 
allocations of EU funds compared to the 2014-2020 multiannual financial 
framework; 

on-the-spot visits to the sampled member states; 

interviews with authorities in charge of implementing and coordinating RRF 
activities for the sample of four member states; 

interviews with Commission staff, mainly from the Recovery and Resilience Task 
Force and the Directorate-General for Economic and Financial Affairs; 

an analysis of the progress of 42 investment measures in the four sampled 
member states, selected on the basis of their monetary materiality and more 
advanced stage of implementation; 

surveys addressed to the RRF coordinating and implementing bodies as well as 
the audit authorities, with the aim of corroborating our audit work on how the 
design and implementation of the RRF affect timely absorption (see Annex I); 

a review of relevant reports by member states’ supreme audit institutions; 

interviews with the RRF coordinating bodies of all member states to ensure a 
common understanding and the quality of the information provided with regard 
to the location of funds and final recipients. 

 
 
13 

16 During our audit, all member states submitted requests for amendments to their 
RRPs, which were all assessed by the Commission and subsequently approved by the 
Council. For the member states in our sample, the outcomes of the RRP amendment 
process on the absorption of RRF funds were taken into account where relevant. 
However, to allow for comparability of data, the REPowerEU pre-financings paid out to 
some member states by the end of 2023 lie outside the scope of this audit. In this 
audit, we did not assess whether RRF reforms and investments are achieving their 
intended results. 

 
 
 
 
14 

Observations 

Pre-financing facilitated the disbursement of funds initially, but 
RRF absorption is facing delays and does not necessarily mean 
that funds have reached the final recipients 

17 We assessed the disbursement of funds by the Commission, taking into account 
payment requests submitted by the end of 2023. The assessment was based on data 
from the initial operational arrangements, the Commission’s Recovery and Resilience 
Scoreboard, and other relevant documents. 

Pre-financing facilitated the disbursement of funds initially 

18 Under the RRF Regulation, member states whose Council Implementing Decisions 
were adopted before 31 December 2021 were entitled to pre-financing of up to 13 % 
of their total financial contribution. 

19 The pre-financing initially allowed more funds to be made available quickly and 
was therefore consistent with the RRF’s objective of responding to crisis. By the end 
of 2023, almost half way through the RRF implementation period, the Commission had 
disbursed around €213 billion in total to member states (€139 billion in grants and 
€74 billion in loans), including €56.5 billion in the form of pre-financing 14. 

20 Though not conditional on the fulfilment of milestones and targets at the time of 
payment, pre-financing is nevertheless indirectly linked to their fulfilment insofar as it 
is cleared proportionally from subsequent payments. By the end of 2023, around 
€25.6 billion or 45 % of the pre-financing paid had been cleared. 

14  European Commission, Recovery and Resilience Scoreboard – Disbursements, as at 

1 February 2024, excluding disbursements related to REPowerEU. 

 
 
 
15 

Absorption of RRF funds is progressing but generally faces delays 

21 In line with the RRF Regulation15, the Commission agrees a timeline for 
submitting payment requests with the member states in their respective operational 
arrangements. Although indicative, these timelines set out the planned 
implementation schedule in each member state and thus help to identify delays and 
the underlying problems and risks in the implementation of the RRF. These timelines 
therefore form the basis for our assessment of whether the RRF’s implementation 
faces delays. 

22 Progress in the implementation of RRPs differs among member states. Figure 3 
gives an overview of the state of play as at the end of 2023. 

15  Article 20(6) and recital 70 of the RRF Regulation. 

 
 
 
16 

Figure 3 – Progress in RRF implementation as at end of 2023 

Original RRP / 
Council 
Implementing 
Decision adopted 

Pre-financing 
disbursed

Operational 
arrangements 
signed

Number of 
payment requests 
submitted

Number of 
payments 
received

grants
loans

Austria

Belgium

Bulgaria

Croatia

Cyprus

Czechia

Denmark

Estonia

Finland

France

Germany

Greece

Hungary

Ireland

Italy

Latvia

Lithuania

Luxembourg

Malta

Netherlands

Poland

Portugal

Romania

Slovakia

Slovenia

Spain

Sweden

Note: The figure contains only data relating to the initial RRPs, and therefore excludes the approved 
amendments and the REPowerEU pre-financing paid by the end of 2023, which lie outside the scope of 
this audit. 

Source: ECA, based on Commission’s Recovery and Resilience Scoreboard. 

 
 
 
17 

23 We note that by the end of 2023, almost three years into the RRF’s 
implementation and after almost half of the RRF implementation period had passed, 
seven member states had not received any funding for the satisfactory fulfilment of 
milestones and targets: 

o 

o 

o 

two member states (Hungary and Netherlands) had not signed operational 
arrangements and were therefore not able to submit payment requests or receive 
RRF funding; 

one member state (Sweden) had signed operational arrangements but not 
submitted any payment requests; 

four member states (Belgium, Finland, Ireland and Poland) had submitted 
payment requests but not received the corresponding funding as their requests 
were still being assessed by the end of 2023. 

24 Out of the 104 payment requests for grants and loans indicatively due for 
submission by the end of 2023, 73 (70 %) had been submitted by that date, and with 
significant differences across member states (Figure 4). In terms of funding, member 
states had submitted payment requests worth €228 billion instead of the €273 billion 
initially planned, or around 16 % less. Out of this amount, around €182 billion had 
been paid to member states for the satisfactory fulfilment of milestones and targets by 
the end of 2023, including the pre-financing amounts already cleared. 

 
 
Figure 4 – Proportion of payment requests submitted by the end of 2023, 
compared to the indicative timelines in the operational arrangements 

18 

Croatia

Czechia

Denmark

Germany

Italy

Latvia

Malta

Portugal

Slovakia

Spain

Romania

Greece

EU-27

Estonia

France

Lithuania

Bulgaria

Luxembourg

Slovenia

Ireland

Austria

Finland

Cyprus

Poland

Belgium

Sweden

Hungary

Netherlands

Source: ECA, based on operational arrangements and Commission’s Recovery and Resilience 
Scoreboard. 

100 %

100 %

100 %

100 %

100 %

100 %

100 %

100 %

100 %

80 %

75 %

75 %

70 %

67 %

67 %

67 %

67 %

50 %

50 %

50 %

50 %

50 %

40 %

25 %

25 %

0 %

0 %

0 %

 
 
 
19 

25 We note that almost all member states experienced delays in submitting 
payment requests compared to the indicative timelines in their respective operational 
arrangements (Figure 5). The delays vary considerably, not only in terms of the 
number of payment requests delayed, ranging from one (Finland and Ireland) to six 
(Poland, Romania, Slovenia), but also in the length of delay, which ranges from 
1 month (Cyprus, first payment) to 12 months (Estonia, first payment). 

 
 
20 

Figure 5 – Delays in submitting payment requests, compared to 
indicative timeline 

Circle represents 
payment request 
for:

grants
loans

Colour represents 
when the payment 
requests were 
submitted

on time
with delay
The actual submission time is indicated by the arrow

not submitted by the end of 2023

2021

Q4

2022

2023

Q1

Q2

Q3

Q4

Q1

Q2

Q3

Q4

Austria

Belgium

Bulgaria

Croatia

Cyprus

Czechia

Denmark

Estonia

Finland

France

Germany

Greece

Ireland

Italy

Latvia

Lithuania

Luxembourg

Malta

Poland

Portugal

Romania

Slovakia

Slovenia

Spain

Sweden

Note: The table does not include Hungary and Netherlands as they have not signed operational 
arrangements in our audit period and therefore could not submit a payment request by the end of 2023. 
More recent information on progress in implementing the RRPs is available at the Commission’s 
Recovery and Resilience Scoreboard. The figure contains only data relating to the initial RRPs, and 
therefore excludes the approved amendments by the end of 2023, which lie outside the scope of this 
audit. 

Source: ECA, based on operational arrangements and Commission’s Recovery and Resilience 
Scoreboard. 

 
 
 
21 

26 Figure 5 also shows a trend in the timeliness of payment requests in that delays 
have become more frequent as the RRF’s implementation has progressed. Whereas for 
the first payment 56 % (18 out of 32) of requests were submitted on time, this 
proportion decreased to 27 % (8 out of 30) for the second payment request and 9.5 % 
(2 out of 21) for the third. We note, however, that the timeliness of a member state’s 
payment request submissions can only be assessed once its operational arrangements 
have been adopted, as these include the indicative timetable for payment requests. 
Therefore, countries may appear in the figure with no delays (for example, Germany) 
because they signed their operational arrangements later — not necessarily because 
they are more advanced in their implementation of the RRF. See Annex II for an 
overview of the time needed for relevant assessments. 

27 In addition, member states must report twice a year on the progress made in the 
implementation of their RRPs 16. This biannual reporting is done in the context of the 
European Semester and includes self-reported data on progress in achieving 
milestones and targets due in the past and due twelve months into the future. Our 
analysis of the last two biannual reports submitted by member states shows that the 
proportion of milestones and targets not completed on time has increased while the 
proportion of future milestones facing delays has remained unchanged: 

o 

o 

in the April 2023 report, approximately 18 % of the milestones and targets 
planned to be achieved had not been completed. This proportion increased to 
24 % in the report submitted in October 2023; 

for future milestones and targets (planned to be completed in the twelve months 
following the date of reporting), the proportion of milestones and targets 
reported as facing delays remained unchanged at 16 % in both the April 2023 and 
October 2023 reports. 

Several factors contribute to the delays 

28 One of the objectives of this audit was to identify the reasons for delays in 
absorbing RRF funds. We therefore discussed the reasons for delays with the national 
authorities during our on-site audit visits and analysed a sample of 42 investments in 
the four sampled member states to assess which reasons contribute to delays, where 
applicable. We also included a question in our survey to the RRF coordinating bodies 
on factors contributing to delays in absorption. 

16  Article 27 of the RRF Regulation. 

 
 
 
22 

29 In our analysis, we identified several reasons causing delays in RRP 
implementation: 

o 

changes in external circumstances, such as increased inflation and supply 
shortages as well as changes in the political context in the member state for 
reforms;  

o  measures not being suited to the RRF’s timeframe and underestimation of the 

time needed to implement them (due to public procurement and state aid rules); 

o 

implementing rules and uncertainties on how they should be applied (the 
guidance on the ‘do no significant harm’ principle (DNSH) and the satisfactory 
fulfilment of milestones and targets); 

o 

issues related to the administrative capacity and complex rules at national level. 

30 We noted that the reasons for the delays in RRP implementation vary among 
member states and differ between reforms and investments. The replies to our survey 
indicate the most frequent factors contributing to delays in absorption (see Figure 6). 

Figure 6 – Frequency of reasons for delays in achieving milestones and 
targets 

81 %

77 %

54 %

42 %

23 %

23 %

Changes in 
external 
circumstances 

Underestimation 
of the time needed 
to implement 
measures when 
designing the RRP 

Issues related 
to public 
procurement 

Application of 
state aid rules 

Issues related 
to administrative 
capacity

Complexity of 
national procedures 

Note: Respondents could provide multiple answers to the question, by selecting options provided in the 
survey and/or by providing additional reasons. 

Source: ECA survey of RRF coordinating bodies. 

 
 
 
23 

Changes in external circumstances 

31 The Commission’s guidance noted that it was important that milestones and 
targets remain within the control of the member state and not be conditional on 
external factors such as the macroeconomic outlook or the evolution of the labour 
market17. 

32 Since the inception of the RRF early in 2021 the geopolitical landscape has seen 
substantial changes, especially with the war of aggression against Ukraine since 
February 2022, which has triggered inflation and record energy prices in the EU. 

33 Such developments and their effects (such as less interest from applicants in 
certain calls for proposals) could not be considered at the time the RRPs were 
submitted. They nevertheless pose a risk to, or have already had a negative impact on, 
the timely achievement of certain milestones and targets and therefore the 
implementation of measures (see Box 1 for examples from our sample of measures). 

Box 1 

Examples of measures facing challenges due to external 
circumstances 

In Spain, the intermediary target of renovating 231 000 residential dwellings by 
the end of 2023 was delayed due to lower-than-expected demand for renovation 
work caused by inflation, and particularly the large increase in raw material prices. 
During the process to amend its RRP, Spain therefore proposed postponing the 
intermediary target’s due date by one year but also reducing the total number of 
renovations to be completed under the measure from 510 000 to 410 000. 
Following its assessment, the Commission accepted both proposals.  

In Italy, the target of notifying the award of all public contracts to build 2 500 rapid 
recharging stations for electric vehicles by the second quarter of 2023 was delayed 
as there were no applications for one part of the measure. This was mainly 
because of shortages of raw materials. Italy subsequently proposed postponing 
this part of the measure, which was accepted by the Commission. 

17  Commission staff working document “Guidance to member states – Recovery and resilience 

plans” (SWD(2021) 12 final), part 1/2, p. 34. 

 
 
 
24 

RRF timeframe and underestimation of time needed to implement measures 

34 The Commission’s guidance18 invited member states to describe in their RRPs 
whether a mature project pipeline existed or what steps would be necessary to create 
such a pipeline. This was to be done both for the RRP as a whole and for each 
individual component to specify a clear implementation path, help identify where 
technical support could be beneficial and ensure absorption. 

35 We examined whether the RRPs of the four sampled member states included 
information on the existence of a mature project pipeline. Furthermore, we assessed 
whether there were any absorption issues resulting from projects not being mature 
enough at the start of the RRF or generally not being suited to the RRF’s timeframe. 

36 During our interviews, the national authorities stated that the information or 
level of detail to be included in their RRPs on the maturity of project pipelines was not 
clear, as it was not specified in the Commission’s guidance. In the sampled member 
states’ RRPs, such descriptions were limited to, for example: 

o 

o 

for Spain: three out of ten selected measures, noting only that maturity would be 
a criterion for selecting projects; 

for Italy: five out of the ten selected measures, mentioning only that they had 
been selected in response to the Commission’s guidance to prioritise mature 
projects. 

37 In our discussions, national authorities pointed out that some of the measures 
included in their RRPs had turned out to be unsuited to the RRF’s timeframe. This 
applies particularly to innovative projects, which are by definition more difficult to plan 
and more likely to encounter obstacles during implementation (see Box 2 for an 
example from our sample of measures). In our opinion on the proposal to amend the 
RRF Regulation to accommodate REPowerEU chapters, we noted that some 
REPowerEU measures, in particular those addressing long-term objectives, may not be 
possible to implement within the RRF’s timeframe19. 

18  Commission staff working document “Guidance to member states – Recovery and resilience 

plans” (SWD(2021) 12 final), part 1/2, pp. 43 and 45. 

19  Opinion 04/2022 concerning the proposal for a Regulation of the European Parliament and 
of the Council amending Regulation (EU) 2021/241 as regards REPowerEU chapters in 
recovery and resilience plans and amending Regulation (EU) 2021/1060, Regulation 

 
 
 
 
25 

Box 2 

Examples of measures facing challenges due to being unsuited to the 
RRF’s timeframe 

Romania’s RRP included an investment to construct a hydrogen-ready distribution 
network. However, during our visit, the Romanian authorities expressed concerns 
about the investment not being well suited to the RRF’s timeframe. The main 
reasons given were its innovative nature and uncertainties regarding the legal and 
operational framework, as well as various implementation risks related to 
technical issues. No progress had been made on this investment at the time of our 
audit, and the Romanian authorities proposed removing the sub-measure for the 
construction of the distribution network of renewable gases from the RRP, which 
the Commission accepted. 

The Italian RRP included an investment for the development of offshore electricity 
generation infrastructure, including experimental technologies that use currents 
and wave motion to produce clean energy. Following public consultations and 
further investigations by the Italian authorities, it emerged that the authorisation 
process for projects benefiting from the measure was incompatible with the RRF 
implementation period. The Italian authorities therefore proposed removing the 
measure from the RRP, which the Commission accepted following its assessment. 

Issues related to public procurement and application of state aid rules 

38 Public procurement and compliance with state aid rules were frequently 
mentioned by national authorities as reasons for longer-than-expected project 
implementation. Neither of these factors are new or specific to the RRF. That indicates 
that the cause of these delays is not the rules themselves but rather underestimation 
of the time needed to apply them when selecting the measures to be included in the 
RRPs. 

39 Public procurement was one of the areas affected by the changes in the 
economic environment since the RRPs were prepared. In particular, the increase in 
prices and shortage of supplies led to procurement procedures having to be adjusted 
or being unsuccessful for some of the measures in our sample. 

(EU) 2021/2115, Directive 2003/87/EC and Decision (EU) 2015/1814 [2022/0164 (COD)], 
paragraph 7 and 12 - 14. 

 
 
 
26 

40 As regards state aid, the RRF Regulation recalls that the general state aid rules 
apply and that member states should ensure that all reforms and investments included 
in the RRPs comply with EU state aid rules and follow all state aid procedures20. The 
Commission published guiding templates to assist member states in the design of the 
state aid elements of their RRPs and to provide guidance on related aspects of the 
types of investments expected to be common to most of them21. 

41 Nevertheless, designing and obtaining approval for state aid schemes proved to 
be time-consuming and member state authorities frequently underestimated the 
duration of proceedings with the Commission when they included the measures in 
their RRPs (see Box 3 for an example from our sample of measures). 

Box 3 

Example of a measure facing challenges related to public 
procurement and state aid 

Romania’s RRP included an investment to set up plants for producing/ 
assembling/recycling batteries and photovoltaic cells and panels. The first 
milestone, planned to be achieved in the third quarter of 2022, was the signing of 
the related contracts. However, it was only achieved with a delay of more than 
8 months. 

The Romanian authorities launched the pre-notification procedure in May 2022 
for the state aid scheme. This process lasted 7 months. Consequently, the state aid 
scheme was officially notified to the Commission only in December 2022. The 
authorities launched the call for proposals for the investment in January 2023, 
which included a suspension clause since the state aid scheme was not yet in 
place, and extended the deadline for submitting applications once. The state aid 
scheme was approved only in February 2023. Our discussions with the Romanian 
authorities revealed that the uncertainty regarding the validity of the state aid 
scheme had resulted in a reduced response rate. 

20  Recital 8 to the RRF Regulation. 

21  European Commission, “Practical guidance to Member states for a swift treatment of State 

aid notifications in the framework of the Recovery and Resilience Facility”. 

 
 
 
27 

Issues related to administrative capacity 

42 The Commission noted22 that it is essential that member states improve their 
administrative capacities to be able to gain the economic and social benefits of the RRF 
and other EU funds and contribute to increasing absorption. We therefore examined 
whether the amounts available to be spent by national administrations in the current 
financial period may pose risks to absorption. 

43 We note that, in some member states, implementing the RRF has resulted in a 
significant increase in the amounts to be spent, with 14 countries receiving at least 
twice as much funding for the 2021-2027 period as they did for 2014-2020 (see 
Figure 7). 

22  Commission staff working document “Guidance to member states – Recovery and resilience 

plans” (SWD(2021) 12 final), part 1/2, p. 45. 

 
 
 
28 

Figure 7 – Comparison of funding allocated to member states in the 
2014-2020 and 2021-2027 periods – cohesion and RRF 

Allocation for Cohesion 2014-2020
Allocation for Cohesion 2021-2027
Allocation for RRF

billion euros
20
0

40

60

80

100

120

Allocation for 
Cohesion 2014 – 2020 
(in % of 2019 GDP)

Allocation for

Cohesion 2021 – 2027 
RRF
(in % of 2019 GDP)

Spain

Italy

Poland

France

Germany

Romania

Portugal

Greece

Czechia

Hungary

Slovakia

Bulgaria

Croatia

Lithuania

Belgium

Latvia

Netherlands

Sweden

Austria

Slovenia

Estonia

Finland

Ireland

Denmark

Cyprus

Malta

Luxembourg

2.3 %

1.8 %

14.6 %

0.7 %

0.6 %

10.3 %

10.0 %

8.5 %

9.8 %

14.9 %

14.8 %

12.4 %

15.4 %

22.3 %

0.5 %

9.2 %

0.2 %

0.4 %

0.3 %

6.4 %

2.8 %

6.2 %

2.3 %

3.8 %

14.1 %

4.2 %

0.7 %

1.5 %

0.5 %

0.8 %

13.5 %

5.4 %

11.0 %

7.2 %

11.7 %

9.5 %

9.7 %

3.4 %

15.4 %

4.0 %

13.6 %

6.4 %

16.4 %

9.3 %

16.3 %

9.9 %

21.3 %

6.9 %

0.6 %

0.9 %

9.4 %

3.7 %

0.2 %

0.6 %

0.4 %

0.7 %

0.3 %

0.9 %

6.8 %

3.1 %

12.9 %

11.8 %

3.2 %

0.6 %

0.3 %

0.2 %

3.0 %

4.9 %

0.2 %

0.7 %

0.8 %

0.3 %

0.3 %

0.2 %

0.5 %

3.9 %

3.9 %

5.6 %

1.4 %

0.1 %

0.0 %

Source: ECA, based on the Commission’s (The EU’s 2021-2027 long-term budget and NextGenerationEU 
and RRF: Update of the maximum financial contribution), European Parliament’s and Eurostat data. 

 
 
  
29 

44 Moreover, we concluded in our previous publications that: 

o 

o 

o 

for those member states in which cohesion funding already accounted for a 
significant share of public investments23, absorbing significantly more EU funds in 
the 2021-2027 period with the introduction of the RRF would be particularly 
challenging24; 

the parallel and delayed implementation of several instruments increases the risk 
of member states losing out on funding25; 

some of the member states with the lowest absorption in the current 
programming period were likely to receive substantial support from the RRF26; 

o  monitoring systems or RRF implementing bodies were in some cases not yet in 
place at the time the RRPs were approved, which limited the Commission’s 
assessment of their administrative capacity27. 

45 Furthermore, 57 % of the RRF coordinating bodies we surveyed considered it 
likely or very likely that absorbing RRF funds in addition to other EU funds in the 
2021-2027 period would be a challenge. The Commission also reported in its mid-term 
evaluation that some member states had experienced difficulties with the increase in 
the workload since the inception of the RRF, and that efforts to improve national 
administrative capacities must therefore continue28. 

23  Bulgaria, Estonia, Croatia, Latvia, Lithuania, Hungary, Poland, Portugal, Romania, and 

Slovakia. 

24  Review 1/2023: EU financing through cohesion policy and the Recovery and Resilience 

Facility: A comparative analysis, paragraph 53. 

25  Annual reports concerning the financial year 2022, Chapter 2: Budgetary and financial 

management, paragraph 2.65. 

26  Opinion 6/2020 concerning the proposal for a regulation of the European Parliament and of 
the Council establishing a Recovery and Resilience Facility (COM(2020) 408), paragraph 32. 

27  Special report 21/2022: The Commission’s assessment of national recovery and resilience 

plans, paragraphs 98 - 105. 

28  European Commission, “Strengthening the EU through ambitious reforms and investments” 

(COM(2024) 82 final), p. 15. 

 
 
 
30 

46 However, issues related to administrative capacity do not affect all member 
states equally: around one third of the coordinating bodies surveyed did not consider 
it a concern. This was particularly true of member states whose RRF funding allocation 
was low in proportion to their GDP and/or funding under other EU funding 
instruments. Another reason given in the survey for not considering administrative 
capacity a concern was that the member states concerned had created specific 
structures (e.g. dedicated RRF units within national authorities) to facilitate the RRF’s 
implementation. 

Uncertainty on how to apply the specific rules for implementing the RRF 

47 The RRF Regulation includes a set of specific rules concerning its implementation: 

o 

o 

the RRF should only support measures that comply with the DNSH principle29. 
The RRF is the first instrument to have DNSH as a condition for funding. The RRF 
Regulation also states that the Commission should provide technical guidance on 
how the DNSH principle should apply in the context of the RRF30; 

the Commission must assess, at the latest within 2 months of receiving a payment 
request, whether the relevant milestones and targets set out in the Council 
Implementing Decision have been satisfactorily fulfilled. The further 
specifications in the operational arrangements should also be taken into account 
for this assessment31. 

48 During our discussions, member state authorities identified the application of the 
different implementing rules and uncertainty regarding how to apply them as one of 
the challenges affecting the timely achievement of milestones and targets and 
therefore absorption. 

49 Although the Commission provided technical guidance as well as additional 
information in informal discussions, applying the DNSH principle was a novelty and 
national authorities therefore considered the corresponding provisions challenging. 

29  Article 5 of the RRF Regulation. 

30  European Commission, Technical guidance on the application of ‘do no significant harm’ 

under the Recovery and Resilience Facility Regulation (2021/C 58/01). 

31  Article 24(3) the RRF Regulation. 

 
 
 
31 

50 The Commission suspended its assessment of payment requests to ask for 
additional information on the fulfilment of milestones and targets from the sampled 
member states where relevant. Our sample of measures shows that for few of them, 
interpretations of what constitutes “satisfactory fulfilment of milestones and targets” 
differed between the Commission and the member states concerned. These 
differences took additional discussions and time to resolve. 

51 While the Commission provided case-by-case clarification on a bilateral basis 
regarding the satisfactory fulfilment of milestones and targets, written guidance was 
issued only in February 202332. Despite this, our survey shows that 65 % of RRF 
coordinating bodies in the member states agree or strongly agree that the definition of 
“satisfactorily fulfilment” poses a risk to the timely absorption of funds (see Annex I). 

52 Box 4 provides examples of measures in our sample facing challenges related to 
the specific rules for implementing the RRF and uncertainty regarding how to apply 
them. 

Box 4 

Example of measures facing challenges related to the specific rules 
for implementing the RRF and uncertainty regarding how to apply 
them 

“Do no significant harm” principle 

Italy’s RRP included an investment for the construction of a certain number of 
kilometres of public transport infrastructure in specified metropolitan areas. 
During our audit, the Italian authorities raised concerns regarding the timely 
fulfilment of the measure, one reason being that one of the projects could not 
comply with the DNSH principle since it was located in a volcanic area. They 
ultimately requested to modify the measure by removing the specific references 
to one of the locations where the infrastructure would be developed, and replace 
the initial target with a milestone to award the contract. The Commission 
accepted the proposal. 

32  European Commission, “Recovery and Resilience Facility: Two years on – A unique 

instrument at the heart of the EU’s green and digital transformation”, Annex I (COM(2023) 
99 final). 

 
 
 
32 

Satisfactory fulfilment of milestones and targets 

Romania’s RRP included an investment to develop combined heat and power 
generation in district heating systems, with an installed electricity production 
capacity of at least 300 megawatts (MW). The initial milestone for this measure 
was the signing of contracts, followed by a target of commissioning 300 MW of 
capacity. 

After submitting a first batch of contracts, the Commission raised concerns on 
their validity and sufficiency to cover the 300 MW target. Then the Romanian 
authorities submitted additional contracts, claiming to cover a total capacity of 
349 MW. They also claimed that their initial understanding of the milestone had 
been affected by certain inconsistencies between the English and the Romanian 
versions of the Council Implementing Decisions and the operational arrangements. 

This resulted in the assessment procedure lasting six months, at the end of which 
the Commission concluded that the milestone had still not been satisfactory 
fulfilled, as the Romanian authorities had not provided reasonable assurance that 
the contracts signed were linked to the country’s district heating needs. In 
addition, the Commission considered that the authorities had not accurately 
assessed whether the applications met the requirements set in the call. 
Consequently, it partially suspended the payment concerned. 

Disbursed funds have not yet necessarily reached final recipients and the 
term “final recipient” is not always used consistently 

53 In the context of the RRF, funding is considered to be absorbed once it is 
disbursed to member states, as the beneficiaries of RRF funds. Absorption therefore 
does not mean that these funds have reached their final recipients (see paragraph 11). 
However, in order to obtain information on RRF funding that has already reached the 
real economy, we asked the member states about (i) the proportion of RRF funding 
disbursed from the national budget to final recipients and (ii) the location of the RRF 
funding they had received to date from the Commission. 

54 In October 2023, we contacted the 22 member states that had received RRF 
funds to ask them for information about the current location of those funds. Whilst 
some of them either did not provide this information (three) or provided information 
which was incomplete or inconsistent (four), for those 15 member states which 
provided this information, about half of the funds received had reached final 
recipients. 

 
 
33 

55 As of March 2023, member states are obliged to publicly disclose and biannually 
update lists of the 100 final recipients receiving the highest amount of funding for the 
implementation of measures included in their RRPs33, with the aim of increasing 
transparency regarding the use of RRF funds34. The Commission’s guidance defined35 a 
“final recipient” as the last entity receiving funds that is not a contractor or sub-
contractor. In our analysis of these lists, however, we noticed that the interpretation of 
the term “final recipient” differs among member states for similar measures. For 
example: 

o 

o 

o 

for measures related to the provision of financing to businesses, final recipients in 
some member states’ understanding of the term included institutions granting 
the funding at national or even EU level (such as the European Investment Bank, 
the European Investment Fund or the European Bank for Reconstruction and 
Development), whereas other member states understood it as referring to the 
businesses receiving the financing; 

for measures related to energy renovation of public buildings, those recorded as 
final recipients in some member states were either ministries or cities, and in 
other member states public energy companies or private businesses; 

for measures related to the provision of digital devices in education, those 
recorded as final recipients in some member states were either ministries or 
cities, and in other member states universities or schools themselves. 

56 The national authorities also confirmed in our meetings that the current 
definition of the final recipient leaves room for interpretation.  

33  Article 25(a) of the Regulation (EU) 2023/435 amending Regulation (EU) 2021/241 as 

regards REPowerEU chapters in recovery and resilience plans and amending Regulations 
(EU) No 1303/2013, (EU) 2021/1060 and (EU) 2021/1755, and Directive 2003/87/EC. 

34  European Commission, Guidance on Recovery and Resilience Plans in the context of 

REPowerEU (2023/C 80/01), p 34. 

35  European Commission, Guidance on Recovery and Resilience Plans in the context of 

REPowerEU (2023/C 80/01), p 34. 

 
 
 
34 

The Commission and member states took actions to facilitate 
absorption, but it is too early to assess whether they have a 
positive impact 

57 The Commission and the member states took actions to facilitate absorption, 
which include: 

o 

o 

amendments to the RRPs to address the changes in external circumstances; 

the Commission’s support and guidance to reduce divergent interpretations of 
implementing rules; 

o  measures to increase administrative capacity; and 

o 

setting up a system to monitor RRF implementation. 

58 We analysed whether the measures taken are likely to address the issues 
identified. 

All sampled member states requested amendments to their RRPs, but 
the impact on absorption remains to be seen 

59 The RRF Regulation establishes the conditions under which a member state may 
modify its RRP (see paragraph 06). The Commission's guidance to member states 
provides further details on when and how member states can request such revisions. 

60 For the 42 measures in our sample, we assessed how many of them were subject 
to amendments, as well as the nature of these amendments (see paragraph 06). We 
note that 27 of the sampled measures (64 %) were affected by amendments, including 
23 on the basis of milestones and targets not being achievable due to “objective 
circumstances” (Article 21(1) of the RRF Regulation). The amendments mainly 
concerned lowering targets, postponing the completion of measures or removing 
measures from the RRP (see Table 1). 

 
 
Table 1 – Requested changes to sampled measures 

Member 
state 

Number 
of 
sampled 
measures 

Number for 
which 
amendments 
requested 

Number 
positively 
assessed by 
the 
Commission 

Number for 
which 
amendment 
request 
based on 
Article 21  

Italy 

10 

10 

10 

10 

Romania  11 

Slovakia 

11 

Spain 

10 

4 

8 

5 

4 

8 

5 

2 

7 

4 

Total 

42 

27 

27 

23 

Source: ECA based on amended RRPs. 

35 

Examples of 
suggested 
changes 

Change 
measure 
description 

Lower targets 

Postpone 
completion 

Remove 
measure 

Lower targets 

Remove 
milestone 

Lower targets 

Postpone 
completion 

Lower targets 

Postpone 
completion 

61 The RRF Regulation does not state clearly what exactly constitutes “objective 
circumstances” justifying amendments. However, in February 2023, the Commission 
issued guidance on RRPs in the context of REPowerEU36 that provided further 
clarification on these objective circumstances, as well as examples. 

36  European Commission, “Guidance on Recovery and Resilience Plans in the context of 

REPowerEU” (2023/C 80/01), p. 11 – 12. 

 
 
 
  
 
36 

62 In general, the member states proposed amendments to RRPs in order to provide 
a solution for measures which would otherwise no longer be achievable. They may 
therefore facilitate absorption. However, the Commission’s guidance states that the 
proposed changes should not decrease the overall ambition of the RRPs 37, but this 
aspect was outside the scope of our audit. 

63 Furthermore, 58 % of the 26 RRF coordinating bodies that replied to our survey 
agreed or strongly agreed that further guidance from the Commission on the process 
and conditions for amending the RRPs would be necessary to ensure timely absorption 
of funds. Furthermore, only 46 % of them considered that the guidance had been 
provided in a timely manner. 

The Commission provided guidance with regard to the specific rules for 
implementing the RRF, but it still leaves room for interpretation 

Satisfactory fulfilment of milestones and targets and partial payments 

64 To facilitate absorption, the Commission provided guidance to member states 
and facilitated an exchange of good practice amongst member states. On 
21 February 2023, the Commission published its framework for assessing the 
satisfactory fulfilment of milestones and targets and the methodology for the 
determination of payment suspension38. We noted that the Commission provided the 
methodology two years after the start of the RRF implementation period and that it 
leaves room for interpretation, particularly as milestones and targets are often vaguely 
defined39. Moreover, the decision to reduce payments if certain milestones or targets 
are not fulfilled remains to some extent a matter of judgement40. 

37  European Commission, “Guidance on Recovery and Resilience Plans in the context of 

REPowerEU” (2023/C 80/01), p. 12. 

38  European Commission, “Recovery and Resilience Facility: Two years on – A unique 

instrument at the heart of the EU’s green and digital transformation”, (COM(2023) 99 final), 
Annexes I and II. 

39  Special report 21/2022: “The Commission’s assessment of national recovery and resilience 

plans – Overall appropriate but implementation risks remain”, paragraph 82. 

40  Annual reports concerning the financial year 2022, chapter 11: Recovery and Resilience 

Facility, paragraphs 11.19 and 11.37. 

 
 
 
37 

65 Furthermore, the methodology states that elements of the operational 
arrangements (such as the verification mechanism and monitoring steps) should not 
be regarded as requirements during the assessment, even though – as we have 
pointed out in previous audit reports – the information provided in the verification 
mechanism makes the milestones significantly clearer or more measurable in 
comparison to the descriptions included in the Council Implementing Decisions41. 

66 The results of our survey of RRF coordinating bodies show that their views on 
whether the guidance was provided in a timely and easily accessible manner, and on 
whether it would facilitate absorption, were relatively evenly split. However, 61 % of 
RRF coordinating bodies agreed or strongly agreed that further guidance and 
information from the Commission was still necessary. 

“Do no significant harm” principle 

67 As mentioned in paragraph 47, the RRF was the first instrument to introduce the 
DNSH principle as a condition for funding. The Commission published its technical 
guidance on the application of the DNSH principle in good time. However, during our 
audit visits, member state authorities stated that it was challenging to apply due to its 
complexity, despite the support provided by the Commission. 

68 This was also confirmed by the responses to our survey of RRF implementing 
bodies, with approximately 60 % considering that further guidance on the application 
of the DNSH principle would be necessary to ensure timely absorption of RRF funds. In 
September 2023, the Commission published additional guidance on the application of 
the DNSH principle42. It is too early to assess whether it addresses the challenges 
member states have faced up to now. 

41  Special report 26/2023: “The Recovery and Resilience Facility’s performance monitoring 

framework – Measuring implementation progress but not sufficient to capture 
performance”, paragraphs 28 – 29. 

42  Commission notice C(2023) 6454 final: “Technical guidance on the application of ‘do no 

significant harm’ under the Recovery and Resilience Facility Regulation”. 

 
 
 
38 

Member states in our sample took actions to increase administrative 
capacity, but still face staffing shortages 

69 In its guidance on RRPs, the Commission pointed out that to ensure effective 
implementation so that reforms and investments proceed as planned, member states 
should make efficient use of their resources and ensure that the administrative 
capacity needed is present43. 

70 The member states in our sample envisaged a number of measures to strengthen 
administrative capacity to implement the RRF. These included recruiting additional 
staff, providing operational support and simplifying administrative procedures. 
However, certain challenges remain: 

o 

o 

Spain’s RRP included specific reforms to modernise the country’s public 
administration by strengthening its public procurement framework, improving 
recruitment procedures and developing a system to manage and monitor the 
implementation of the RRF. However, the completion of some measures was not 
as quick as expected. These included a reform to strengthen the administration’s 
ability to attract and retain staff, which was finally approved by the Spanish 
Parliament in December 2023. Furthermore, a report by the Spanish supreme 
audit institution in April 2023 noted challenges in properly planning human 
resources and ensuring adequate resources (especially at regional level) to 
implement the RRF44. 

Romania’s RRP included a set of reforms to improve the quality of its public 
administration. Romania fulfilled the milestone on establishing the institutional 
framework for the RRP and the legal mandate of relevant bodies. There were 
several proposals to reorganise its RRF coordinating body, including to increase 
the number of staff involved in managing RRF funds. However, in May 2023 the 
increase in staff did not match that identified by the RRF coordinating body as 
being needed to implement the RRF. 

43  Commission staff working document “Guidance to member states – Recovery and resilience 

plans” (SWD(2021) 12 final), part 1/2, p. 45. 

44  Court of Auditors, Informe de fiscalización sobre las medidas adoptadas en el ámbito 
autonómico para la implementación del Plan de Recuperación, Transformación y 
Resiliencia, N.1.515. 

 
 
 
39 

o 

o 

Italy completed a set of reforms of its public administration, including in relation 
to recruitment procedures, the establishment of the IT system for monitoring and 
managing the RRF’s implementation and simplification of administrative 
procedures. It also included a milestone on increasing the administrative capacity 
of local authorities45. However, the Italian supreme audit institution in 
March 2023 noted challenges relating to high turnover of recruited staff and 
highlighted that the procedures for implementing the RRP were complex, with 
many authorities still not having the necessary staff46. 

Slovakia implemented a reform aimed at strengthening administrative capacity at 
both local and national level. This entailed approving the legal basis establishing 
the relevant bodies and defining their roles and responsibilities and analysing the 
organisational set-up of the departments responsible for implementing the RRP. 
The Slovak audit authority highlighted deficiencies in October 2022 relating to 
organisational structures and staffing levels, as well as a lack of sufficient 
guidance at national level, particularly on ensuring proper internal controls47. 

Member states and the Commission set up systems to monitor 
implementation progress, but follow-up of delays is not systematic 

71 Member states are required to establish, in their RRPs, arrangements for the 
effective monitoring and implementation of those plans, including the envisaged 
timetable, milestones and targets, and the related indicators48. As noted in our special 
report on the RRF’s performance monitoring framework49, member states and the 
Commission set up IT systems and governance and control structures for the RRF 
within a short timeframe. 

45  See also 2022 annual reports on the implementation of the EU budget for the 2022 
financial year and on the activities funded by the 9th, 10th and 11th European 
Development Funds (EDFs) for the 2022 financial year, paragraph 11.33. and box 11.3. 

46  Court of Auditors, Relazione sullo stato di attuazione del Piano Nazionale di Ripresa e 

Resilienza (PNRR). 

47  National Implementation and Coordination Authority (NIKA), Summary of audits pursuant 
to Article 22(2)(c) of Regulation (EU) 2021/241 and Annex III to the financing agreement, 
October 2022. 

48  Article 18(4)(p) and 19(3)h of the RRF Regulation. 

49  Special report 26/2023: “The Recovery and Resilience Facility’s performance monitoring 

framework – Measuring implementation progress but not sufficient to capture 
performance”, paragraphs 54-57. 

 
 
 
40 

72 Our survey of RRF coordinating bodies illustrates that member states took 
different approaches in designing their IT systems for monitoring implementation. The 
survey results demonstrate, in most cases, the IT systems’ ability to monitor the 
fulfilment of milestones and targets at any given point, both for the member state as a 
whole and for final recipients. Of the four member states we sampled, however, this 
was not the case for Romania and Slovakia, as their monitoring systems could not 
provide such detailed breakdowns. In addition, Romania’s IT system was not used by 
all the implementing ministries and therefore did not include comprehensive 
information on implementation. As a result, the RRF coordinating body did not always 
have timely information on the progress of the measures concerned, which would 
allow it to remedy any delays and facilitate absorption. At the time of our audit, both 
member states were in the process of establishing new monitoring systems. 

73 In addition, around half of the respondents to our survey indicated that their 
monitoring systems did not include an “early warning system” to notify them of delays 
in progress towards milestones or targets in advance of their due dates or to flag the 
reversal of previously achieved milestones or targets. For the detailed results of our 
survey regarding the monitoring systems, see Annex III. 

74 The RRF Regulation50 requires member states to report twice a year on their 
progress in implementing their RRPs. The purpose of this reporting is to provide a 
comprehensive stocktake of the implementation of all plans, and to allow the 
Commission to identify potential risks to be addressed with member states. In our 
analysis of biannual reports submitted by member states, we found that not all of 
them systematically provided comprehensive information about the reasons for delays 
in achieving milestones and targets. Instead, this information is in many cases limited 
to general descriptions of steps taken. Furthermore, the Commission also noted that 
member states’ reporting on progress towards milestones and targets was sometimes 
incorrect. 

75 Incomplete and inaccurate information limits what the Commission can do to 
address the underlying causes of delays in a timely manner and mitigate the resulting 
risks to absorption. While the Commission is in regular contact with the member 
states, it does not systematically ask member states to provide information on the 
actions taken to address delays or challenges faced in achieving milestones and 
targets, even though the Commission implements the RRF under direct management 
and bears ultimate responsibility. 

50  Article 27 of the RRF Regulation. 

 
 
 
41 

The design of the RRF entails risks to absorption and the 
completion of measures by 31 August 2026 

76 One of the objectives of this audit was to highlight, at an early stage, any risks to 
the implementation of the RRF within the regulatory timeframe and thus to the 
achievement of the RRF’s objectives in the long term. We therefore analysed whether 
there are any risks to absorption in the second half of the implementation period. In 
our analysis, we paid particular attention to risks to the completion of measures as 
these are a key element in achieving the RRF’s objectives. We also assessed whether 
the disbursements of funds reflect progress in achieving milestones and targets. 

The quantity and nature of outstanding milestones and targets poses 
risks to absorption and the completion of measures  

77 In line with the RRF Regulation, national RRPs set out, among other things, 
milestones, targets and a timetable for the implementation of the reforms, and 
investments to be completed by 31 August 202651. In addition, the Council 
Implementing Decisions for each member state includes an indicative date for the 
fulfilment of each milestone and target. 

The significant number of milestones and targets to be achieved in the second half of 
the implementation period poses risks to absorption and the completion of 
measures 

78 We analysed the distribution of milestones and targets over time and, in 
particular, the proportion of milestones and targets still to be achieved in the second 
half of the RRF’s implementation period. 

79 The number of milestones and targets to be achieved is not distributed evenly 
over the RRF implementation period. The 73 payment requests submitted by the end 
of 2023 included 1 750 milestones and targets – only around 28 % of the 
6 234 milestones and targets envisaged in the initial Council Implementing Decisions. 
The challenges and delays faced by member states in fulfilling their milestones and 
targets by the dates indicated in the Council Implementing Decisions, even at the 
beginning of the RRF (see paragraph 27), mean there is a risk to absorption and that 
measures will not be completed as planned, given the expected cumulative effect of 
these delays. 

51  Article 18 of the RRF Regulation. 

 
 
 
42 

80 To complement our analysis, our survey included questions about the likelihood 
of milestones and targets being achieved by the date indicated in their Council 
implementing Decision and of measures being completed by the end of the RRF 
implementation period (Figure 8). We note that only two member states considered 
that all investment milestones and targets were likely to be achieved by the date 
indicated in the Council Implementing Decision. 

Figure 8 – Likelihood of achieving milestones and targets as planned 

Reforms
Investments

Likelihood 
to achieve all 
milestones and 
targets

Very likely

Likely

Unlikely

Very unlikely

No opinion

by the timeline indicated in the current CID

by 31 August 2026

4 %
4 %

4 %
4 %

39 %

31 %

39 %
39 %

15 %

23 %

19 %

15 %

15 %

19 %

0 %

8 %

4 %
4 %

Source: ECA survey of RRF coordinating bodies. 

62 %

54 %

Shift from reforms to investments and reaching the final stage of implementation 
increase the risk of delays 

81 The initial RRPs included 2 530 measures, of which 1 541 were investments and 
989 reforms. Most member states decided to implement reforms first, as they were 
often important to facilitate the efficient and effective implementation of 
investments52, which in most cases come second, as confirmed by the Commission53 
(see Figure 9). 

52  Commission staff working document “Guidance to member states – Recovery and resilience 

plans” (SWD(2021) 12 final), part 1/2, p. 15. 

53  European Commission, Strengthening the EU through ambitious reforms and investments 

(COM(2024) 82 final), p. 4. 

 
 
 
 
Figure 9 – Number of reforms and investments due to be completed per 
quarter, 2020-2026 

43 

500

450

400

350

300

250

200

150

100

50

0

Investments

Reforms

Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3

2020

2021

2022

2023

2024

2025

2026

Source: ECA, based on Commission’s FENIX database. 

82 Member states planned to complete milestones and targets related to 39 % of all 
investments and 14 % of all envisaged reforms in 2026, during the last eight months of 
the RRF implementation period. An analysis of individual member states reveals that 
16 of them planned to complete milestones and targets related to at least 30 % of 
their investments only in 2026, ranging from 30 % in the case of Spain to 62 % in the 
case of Italy and 70 % in the case of Poland (see Annex IV). 

83 Investments, and particularly infrastructure investments, can be rather complex 
in nature and are generally more sensitive to delays caused by external circumstances, 
which lie outside the member states’ control. As a result, the backloading of 
investments is likely to further increase the risk of delays and absorption slowing 
down. When presenting the mid-term evaluation, the Commission acknowledged that 
the second half of the RRF’s implementation will be more challenging than the first, as 
investments reach a critical stage in their implementation54. 

84 We note, furthermore, that at the beginning of the RRF, milestones and targets 
related to early stages of implementation (such as the adoption of laws, the 
publication of calls for proposals or tenders, or the selection of projects), whereas 
those in the second half of the RRF implementation period are often more complex 

54  European Commission, Statements by Executive Vice-President Dombrovskis and 

Commissioner Gentiloni at the press conference on the mid-term evaluation of the 
Recovery and Resilience Facility, 21 February 2024. 

 
 
 
 
44 

and challenging in nature as they refer to the final stages of implementation (such as 
the completion of infrastructure investments or reforms, or sometimes even the 
results of these). 

85 More importantly, the milestones and targets in the second half of the RRF 
implementation period are often more closely linked to the completion of measures 
and the achievement of objectives. Not achieving these milestones or targets 
therefore may pose risk to the absorption and completion of the measures concerned. 
Table 2 shows examples of the difference between the penultimate and final 
milestones/targets for some measures in the sampled member states. 

Table 2 – Examples of the difference between penultimate and final 
milestones/targets in the sampled member states 

Member 
State 

Description of 
measure 

Penultimate 
milestone/target 

Italy 

Production of 
hydrogen on 
brownfield 
sites 

Award of the projects 
for the production of 
hydrogen in abandoned 
industrial areas. 

Q1/2023 

Final milestone/target 
included in last payment 
request 

Complete at least 10 
projects for the production 
of hydrogen in abandoned 
industrial areas of an 
average capacity of at least 
1-5 MW each. 

Q2/2026 

The project design for 
the modernisation works 
for flood protection shall 
be adopted. 

The project for 
modernisation of flood 
protection shall be 
completed. 

Q1/2023 

Q2/2026 

Start bringing together 
universities into larger 
units. 

The completion of the 
process of merging 
research units 

Q4/2021 

Q2/2026 

Romania 

Slovakia 

Integrated 
flood risk 
mitigation 
systems in 
forest river 
basins 

Increase in the 
performance 
of Slovak 
higher 
education 
institutions – 
Reform 5: 
Concentration 
of excellent 
educational 
and research 
capacities 

 
 
45 

Member 
State 

Description of 
measure 

Penultimate 
milestone/target 

Final milestone/target 
included in last payment 
request 

Spain 

Energy 
Rehabilitation 
of Buildings 
Programme 

Award of renovations 
for residential dwellings 
and non-residential 
buildings, achieving on 
average at least a 30 % 
primary energy demand 
reduction. 

Completion of renovations 
for residential dwellings 
and non-residential 
buildings, achieving on 
average at least a 30 % 
primary energy demand 
reduction. 

Q4/2023 

Q2/2026  

 Source: ECA, based on the Council Implementing Decisions. 

Disbursements do not necessarily reflect the quantity and importance of 
milestones and targets included  

86 In general, disbursement of funding should reflect progress in achieving 
milestones and targets55. All payments after the initial pre-financing payment are 
based on the achievement of milestones and targets included in the corresponding 
payment request. The amount of each payment and the milestones and targets to be 
fulfilled in order to receive it are defined in the Council Implementing Decisions.  

87 The payment profiles are a result of negotiations with the member state 
concerned. While taking into account the quantity and importance of milestones and 
targets56, the payment profiles do not necessarily reflect them. By the end of 2023, the 
Commission had disbursed 37 % of the total RRF allocation (grants and loans) in return 
for the satisfactory fulfilment of 19 % of all milestones and targets, taking into account 
pre-financing amounts already cleared (see Figure 10). 

55  Commission staff working document “Guidance to member states – Recovery and resilience 

plans” (SWD(2021) 12 final), part 1/2, p. 35. 

56  Special report 21/2022: The Commission’s assessment of national recovery and resilience 

plans, paragraph 73. 

 
 
 
46 

Figure 10 – RRF disbursements for the satisfactory fulfilment of 
milestones and targets by the end of 2023 

Proportion of 
funding disbursed

Proportion of 
satisfactorily fulfilled 
milestones and targets

Total number of 
milestones and targets

M&T satisfactorily 
fulfilled by Q4 2023

France

Portugal

Spain

Italy

Greece

Croatia

EU-27

Slovakia

Luxembourg

Estonia

Lithuania

Slovenia

Austria

Denmark

Bulgaria

Romania

Malta

Germany

Czechia

Latvia

Cyprus

Belgium

Finland

Hungary

Ireland

Netherlands

Poland

Sweden

59 %

48 %

46 %

46 %

40 %

38 %

37 %

33 %

32 %

30 %

29 %

24 %

23 %

22 %

22 %

21 %

19 %

17 %

15 %

12 %

8 %

0 %

0 %

0 %

0 %

0 %

0 %

0 %

53 %

28 %

29 %

34 %

26 %

28 %

19 %

30 %

41 %

23 %

16 %

31 %

26 %

32 %

6 %

14 %

14 %

28 %

15 %

4 %

5 %

0 %

0 %

0 %

0 %

0 %

0 %

0 %

175

341

416

525

331

371

2 159

196

63

124

191

209

171

77

346

507

138

129

244

214

271

210

140

270

109

127

283

56

93

96

121

178

87

104

679

58

26

29

31

64

44

25

22

70

19

36

37

9

14

0

0

0

0

0

0

0

Source: ECA based on the operational arrangements and the Commission’s Recovery and Resilience 
Scoreboard. 

 
 
 
47 

88 Furthermore, several member states will need to complete more than 50 % of 
their measures in 2026 while most of them will receive less than 20 % of their total 
funding in order to do so (see Figure 11). 

Figure 11 – Proportion of measures with milestones and targets to be 
fulfilled vs proportion of funds to be received within 2026 

Proportion of measures to be completed within 2026

Proportion of funds to be received within 2026

0 %

10 %

20 %

30 %

40 %

50 %

60 %

Latvia

Lithuania

Germany

Italy

Estonia

Poland

Romania

Hungary

Slovenia

Bulgaria

Belgium

Austria

Croatia

Slovakia

Cyprus

Netherlands

Finland

Ireland

Spain

Czechia

Portugal

Malta

Denmark

Sweden

France

Greece

Luxembourg

Source: ECA, based on the Fenix database. 

 
 
 
48 

89 In addition, the relationship between disbursements received and the milestones 
and targets achieved differs considerably among member states (see paragraph 86). 
For example, the last two payment requests for Portugal represent 18 % of the 
country’s total RRF funding but will require the fulfilment of 45 % of all milestones and 
targets included in its RRP. This relationship is similar in the case of, for example, the 
Netherlands (15 % of funding versus 39 % of milestones and targets), Slovakia (6 % 
versus 29 %), Romania (9 % versus 31 %) and Croatia (17 % versus 38 %) 
(see Figure 12). 

Figure 12 – Analysis of penultimate and final payment request 

Proportion of funding to be received
Proportion of milestones and targets to be fulfilled

Grants
60 %

50 %

40 %

30 %

20 %

10 %

0 %

AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK

Loans
60 %

50 %

40 %

30 %

20 %

10 %

0 %

AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK

PL PT RO

CY

EL

IT

SI

Source: ECA, based on the Council Implementing Decisions. 

 
 
 
49 

90 The fact that the RRF is designed in such a way that disbursements do not 
necessarily reflect the quantity and importance of milestones and targets may result in 
the risk of a significant proportion of RRF funding being paid without member states 
having completed the corresponding measures. According to the RRF Regulation, RRPs 
set out, among other things, a timetable for the implementation of the reforms and 
investments to be completed by 31 August 202657. We note however that the RRF 
Regulation does not provide for the possibility of recovering funds related to already 
fulfilled milestones and targets if measures are not completed. This poses a risk to the 
achievement of RRF’s objectives and therefore the EU’s financial interests in the event 
of those member states not completing the agreed measures. 

57  Article 18(4)i of the RRF Regulation. 

 
 
 
 
 
50 

Conclusions and recommendations 

91 We conclude that, in the early stages of the implementation of the Recovery and 
Resilience Facility (RRF), pre-financing facilitated the disbursement of funds. However, 
the absorption of funds subsequently faced delays for various reasons. We found that 
although the Commission and the member states reacted to these delays, there 
remain risks to absorption and to the completion of measures in the second half of 
RRF’s implementation. 

92 The pre-financing of up to 13 % provided for in the legislation was justified in light 
of the crisis in which the RRF arose and allowed funds to be disbursed quickly to most 
member states (see paragraphs 18-19). We found however that, while a swift uptake 
of RRF funding was essential to recover from the crisis, absorption of funds in the first 
half of the RRF implementation period generally faced delays. By December 2023, the 
number of payment requests submitted to the Commission was considerably lower 
than planned in the operational arrangements. However, the delays varied among 
member states in terms of the number of payment requests submitted, the funding 
requested and milestones and targets achieved, and also in terms of the length of 
delays (see paragraphs 21-27). 

93 Several factors contributed to delays, including external factors such as price 
increases and supply shortages, as well as the time needed to implement measures – 
especially for innovative or large infrastructure projects – having been underestimated 
at the time they were selected for inclusion in the recovery and resilience plans. 
Moreover, certain RRF implementation rules, and differing interpretations regarding 
how to apply them, increased the time needed to implement measures (see 
paragraphs 28-52). 

94 Furthermore, almost half of the RRF funds disbursed to the 15 member states 
that provided the respective information, have not yet reached final recipients. In 
addition, the other seven member states that received funds did not provide complete 
and consistent information on the current location of these funds. Furthermore, the 
definition of the term “final recipient” leaves room for interpretation, and was applied 
differently for similar measures (see paragraphs 53-56). 

 
 
51 

Recommendation 1 – Ensure a consistent application of the 
definition of “final recipient” 

The Commission should ensure that member states have a common understanding of 
what constitutes a “final recipient” and apply it consistently. 

Target implementation date: 2024. 

95 Both the Commission and the member states took some measures to facilitate 
absorption, but risks remain. The amendments made to the recovery and resilience 
plans, while offering the opportunity to overcome issues identified during 
implementation, should not decrease the overall ambition of the recovery and 
resilience plans. The extent to which these amendments will influence absorption 
remains to be seen (see paragraphs 57-63). 

96 The Commission published the methodology for assessing the satisfactory 
fulfilment of milestones and targets two years after the start of the RRF 
implementation period. However, uncertainties remain regarding the reduction of 
payments for failure to fulfil certain milestones or targets, as the methodology leaves 
room for different interpretations. Guidance on the application of the “do no 
significant harm” principle was provided in good time but national authorities found it 
challenging to apply due to its complexity and novelty (see paragraphs 64-68). 

97 The member states also took action to enhance their administrative capacity, in 
particular through the recruitment of additional staff, but did not fully address the 
challenges (see paragraphs 69-70). The Commission and member states set up systems 
to monitor the RRF’s implementation but the information provided was sometimes 
incomplete. While the Commission is in regular contact with the member states, it 
does not systematically ask them to provide information on the actions taken to 
address delays, even though the Commission implements the RRF under direct 
management and bears ultimate responsibility. (see paragraphs 71-75). 

Recommendation 2 – Provide member states with additional 
guidance and support  

The Commission should provide additional support and guidance, where necessary, to 
address any remaining uncertainties in the areas identified by member states. 

Target implementation date: 2024 

 
 
52 

98 In the second half of the RRF implementation period, the quantity and nature of
the milestones and targets to be achieved, as well as the shift from reforms to 
investments, are likely to pose additional challenges to the timely absorption of funds. 
Given the delays already faced by the end of 2023, we consider there is a risk that not 
all planned measures will be completed within the RRF’s implementation timeframe 
(see paragraphs 78-85). 

Recommendation 3 – Monitor and mitigate the risk of non-
completion of measures and the financial consequences 
thereof  

The Commission should in cooperation with member states: 

(a)

identify the measures most at risk of not being completed by 31 August 2026;

(b)

systematically follow up these measures and agree on actions to overcome the 
delays;

(c) mitigate the risk of funding non-completed measures.

Target implementation date: 2024. 

99 We also found that the amount of funds received by member states does not
necessarily reflect the quantity and importance of the achieved milestones and 
targets. In addition, the relationship between funding and the achievement of 
milestones and targets differs among member states. This may result in a significant 
proportion of funds being paid out for measures that may not be completed. This 
poses risks as the RRF Regulation does not provide the possibility of recovering funds 
related to already fulfilled milestones and targets if measures are not completed (see 
paragraphs 86-90). 

53 

Recommendation 4 – Strengthen the design, with regard to 
absorption, of future instruments based on financing not linked 
to costs 

If the Commission designs instruments based on financing not linked to costs, it 
should:  

(a)  ensure a close link between disbursements and progress in achieving objectives;  

(b)  address the absence of the possibility to recover funds if measures are not 

completed. 

Target implementation date: when designing instruments based on financing not 
linked to costs. 

This report was adopted by Chamber IV, headed by Mr Michails Kozlovs, Member of 
the Court of Auditors, in Luxembourg on 4 July 2024. 

For the Court of Auditors 

Tony Murphy 
President 

 
 
 
 
 
 
 
 
54 

Annexes 

Annex I – Main information on ECA’s surveys to member states 

Addressees 

Topic 

Sample 

Period 

Response rate 

RRF coordinating 
bodies  

RRF implementing 
bodies  

Absorption 
in general 

Audit authorities 

27 member 
states 

20 member 
states for which 
we obtained 
relevant contacts 

27 member 
states 

96 % 

April – 
June 2023 

61 % 

70 % 

 
 
 
 
 
Annex II – Procedural steps and time (in days) needed to fulfil 

Time needed for Commission's assessment of the RRP
Time needed for Council's approval of the Commission's assessment of the RRP
Time needed for signing the operational arrangements after Council's approval of the RRP's assessment

55 

Germany

Finland

Sweden

Ireland

Luxembourg

Belgium

Poland

Hungary

Denmark

Malta

Czechia

Cyprus

Romania

Lithuania

Slovenia

Bulgaria

Latvia

Estonia

Portugal

Croatia

Greece

Italy

Slovakia

Austria

France

Spain

Netherlands

0

100

200

300

400

500

600

700

800

900

Source: ECA, based on Commission’s Recovery and Resilience Scoreboard. 

 
 
 
 
 
56 

Annex III – Functionalities of national IT monitoring systems for 
tracking absorption of RRF funds at national level 

Yes

No

Not applicable

Allows monitoring of achievement of milestones and targets at any given point

24

3

0

Includes the level of implementation of funds for each final recipient

23

Gives an overview of the absorption of funds at national level

22

3

4

1

1

Gives an overview of absorption of funds at level of final recipient

20

4

3

Notifies in case of delays in each phase of implementation even before reaching the deadline for 
achieving the relevant milestone or target

15

11

1

Gives an overview of absorption of funds at regional level

14

6

7

Foresees checks for identifying eventual reversion of previously achieved milestones and targets

11

11

5

Source: ECA survey of RRF coordinating bodies. 

 
 
 
 
 
57 

Annex IV – Percentage of reforms and investments to be 
completed per year, by member state 

blank

Legend:

Investment

Reform

Austria

Belgium

Bulgaria

Croatia

Cyprus

Czechia

Denmark

Estonia

Finland

France

Germany

Greece

Hungary

Ireland

Italy

Latvia

Lithuania

Luxembourg

Malta

Netherlands

Poland

Portugal

Romania

Slovakia

Slovenia

Spain

Sweden

100 %

50 %

0 %
100 %

50 %

0 %
100 %

50 %

0 %
100 %

50 %

0 %
100 %

50 %

0 %
100 %

50 %

0 %
100 %

50 %

0 %
100 %

50 %

0 %
100 %

50 %

0 %

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
0
2

5
2
0
2

6
2
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
0
2

5
2
0
2

6
2
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
0
2

5
2
0
2

6
2
0
2

Source: ECA, based on the Fenix database. 

 
 
 
 
 
 
 
 
   
 
58 

Abbreviations 

DNSH: Do no significant harm 

RRF: Recovery and Resilience Facility 

RRP: Recovery and resilience plan 

 
 
 
 
59 

Glossary 

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

Cohesion Fund: EU fund for reducing economic and social disparities in the EU by 
funding investments in member states where the gross national income per inhabitant 
is less than 90 % of the EU average. 

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

Effectiveness: Extent to which the objectives pursued are achieved through the 
activities undertaken. 

European Semester: Annual cycle which provides a framework for coordinating the 
economic policies of EU member states and monitoring progress. 

Final recipient: Person or legal entity that receives RRF funds to implement a measure 
included in a member state’s recovery and resilience plan. 

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

Milestone: Qualitative measure of progress towards the achievement of a reform or 
investment. 

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

Operational arrangement: Agreement between the Commission and a member state 
on technical matters relating to the implementation of its recovery and resilience plan. 

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

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. 

 
 
60 

Reform: An action or process of making changes and improvements with significant 
impact on long lasting effects on the functioning of a market or policy, the functioning 
or structures of an institution or administration, or on progress to relevant policy 
objectives, such as growth and jobs, resilience and the twin transitions. 

Result: Immediate effect of a project or programme upon its completion, such as the 
improved employability of course participants or improved accessibility following the 
construction of a new road. 

Target: Quantitative measure of a member state’s progress towards the achievement 
of a reform or an investment. 

 
 
 
 
Replies of the Commission 

61 

https://www.eca.europa.eu/en/publications/sr-2024-13 

Timeline 

https://www.eca.europa.eu/en/publications/sr-2024-13 

 
 
 
 
 
 
 
 
 
 
 
 
 
62 

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 IV Regulation of markets 
and competitive economy, headed by ECA Member Mihails Kozlovs. The audit was led 
by ECA Member Ivana Maletić, supported by Sandra Diering, Head of Private Office 
and Tea Vlainić, Private Office Attaché; Juan Ignacio Gonzalez Bastero, Principal 
Manager; Giorgos Tsikkos, Head of Task; Felipe Andres Miguelez, Sorana Rotta and 
Valentina-Adriana Visan, Auditors. Michael Pyper provided linguistic support. 
Alexandra-Elena Mazilu provided graphical support. 

Ivana Maletić

Sandra Diering

Tea Vlainić

Juan Ignacio Gonzales 
Bastero

Giorgios Tsikkos

Sorana Rotta

Valentina-Adriana Visan

Michael Pyper

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HTML 
PDF 

ISBN 978-92-849-2501-8 
ISBN 978-92-849-2525-4 

ISSN 1977-5679 
ISSN 1977-5679 

doi:10.2865/80695 
QJ-AB-24-013-EN-Q 
doi:10.2865/207321  QJ-AB-24-013-EN-N 

3 

The Recovery and Resilience Facility (RRF), amounting to €724 
billion, was set up in response to the COVID-19 pandemic. 

We audited the absorption of RRF funds and concluded that it is 
progressing with delays. 

Whilst the Commission and member states took actions to 
address these delays, risks remain regarding the completion of 
measures and therefore the achievement of the RRF’s objectives. 

We found that the RRF Regulation does not provide for the 
possibility of recovering funds if measures are not completed and 
that the disbursements to member states do not necessarily 
reflect the quantity and importance of the achieved milestones 
and targets. 

We recommend, among others, that the Commission provides 
additional guidance where needed, monitors non-completion of 
measures and strengthens the design of future similar 
instruments regarding absorption. 

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

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