COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Denmark Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Third River Basin Management Plans Second Flood Risk Management Plans
Date: 2025-02-04
Institutions: Directorate-General for Environment, European Commission
Subjects: Denmark, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2025  SWD(2025) 34 final  COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans     Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans    Member State: Denmark Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC)        Third River Basin Management Plans    Second Flood Risk Management Plans {COM(2025) 2 final} - {SWD(2025) 13 final} - {SWD(2025) 14 final} - {SWD(2025) 15 final} - {SWD(2025) 16 final} - {SWD(2025) 17 final} - {SWD(2025) 18 final} - {SWD(2025) 19 final} - {SWD(2025) 20 final} - {SWD(2025) 21 final} - {SWD(2025) 22 final} - {SWD(2025) 23 final} - {SWD(2025) 24 final} - {SWD(2025) 25 final} - {SWD(2025) 26 final} - {SWD(2025) 27 final} - {SWD(2025) 28 final} - {SWD(2025) 29 final} - {SWD(2025) 30 final} - {SWD(2025) 31 final} - {SWD(2025) 32 final} - {SWD(2025) 33 final} - {SWD(2025) 35 final}  
 
 
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Country specific staff working document 

Denmark 

ENVIRONMENT 

 
 
 
 
 
 
 
 
Content 

Content ................................................................................................................................................................................................... 2 

SECTION A: WATER FRAMEWORK DIRECTIVE .......................................................................................................................... 3 

1. General info, member state characterisation ............................................................................................................. 4 

2. Horizontal aspects ................................................................................................................................................................... 10 

2.1 Governance ......................................................................................................................................................................... 10 

2.2 Characterization of River Basin District .............................................................................................................. 10 

3. Policy elements contributing to biodiversity and climate change adaptation ...................................... 17 

3.1 Surface Water: what is their ecological status or potential .................................................................... 17 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) .......................................... 19 

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 20 

3.4 Protected Areas (identification, monitoring, objectives and measures) ........................................... 21 

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 22 

3.6 What Denmark is doing for abstractions and water scarcity ................................................................. 22 

3.7 Adaptation to climate change .................................................................................................................................. 23 

4. Policy elements contributing to zero pollution ........................................................................................................ 24 

4.1 Surface Water: what is their chemical status ................................................................................................. 24 

4.2 Groundwater Bodies: what is their chemical status .................................................................................... 27 

4.3 What Denmark is doing to combat pollution from agriculture ............................................................. 29 

4.4 What Denmark is doing to combat pollution from other sectors ........................................................ 32 

4.5  What  Denmark  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 33 

5. Exemptions and economics ............................................................................................................................................... 34 

5.1 To what extent are exemptions applied in Denmark .................................................................................. 34 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 36 

6. WFD recommendations ........................................................................................................................................................ 37 

SECTION B: FLOODS DIRECTIVE .................................................................................................................................................. 40 

7. Flood risk management under floods directive (FD) ............................................................................................ 41 

7.1 Flood hazard and risk maps ...................................................................................................................................... 41 

7.2 Flood risk management plans .................................................................................................................................. 42 

8. FD recommendations ............................................................................................................................................................ 45 

2 

 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, member state characterisation

Denmark is the southernmost of the Scandinavian countries, lying south-west and south of Sweden, 
south of Norway and north of Germany with which it shares a short border. The Kingdom of Denmark 
also includes the Faroe Islands and Greenland which will not be considered in this report. Denmark 
consists of the larger, northern part of the Jutland peninsula and an archipelago of over 400 islands, 
the largest and most populous of which include Zealand, Amager Funen, North-Jutlandic Island and 
Lolland. Bornholm is an outlier, as it is an island situated in the middle of the Baltic Sea.   

Denmark has almost 6 million inhabitants and a surface of 43,094 km2 with a population density of 
about 139 inhabitants per km2, higher than the EU average. In general, population density increases 
when moving from west to east. About 1 of 2 Danes lives in urban centers with a population of at 
least 20 thousand. Almost one in five Danes live in the Copenhagen metropolitan area. 

Because of the many islands and fjords, Denmark’s general coastline is much shorter than its tidal 
short  line  (over  1000  and  about  8700  km  respectively). Hence, there  are  relatively  many coastal 
waters which can be roughly divided in those bordering the North Sea, thus with strong tides, and 
those at the Baltic Sea where waves and tides are much smaller.  

E-reporting, the source of this map, defines DK4 as a national RBD, whereas the national RBMP PDF defines it as 

Note:  
an international RBD. 

The country is flat with little relief. The average height inland is about 30 meters about sea level, and 
the highest peak is only 170 meters. There are no long or big rivers in Denmark because of its small 
size, low elevation and relatively low rainfall. Instead,  the land is drained through relatively short 
rivers and streams flowing into lakes or the nearby sea. Only two rivers, both in Jutland, attain more 

4 

 
than 100 km in length and only five more exceed 60 km. The longest river in Zealand is 83 km, and 
the longest in Funen is 53 km. 

Denmark has 14.9% of its territory designated as nature protected areas, below the EU average of 
26%. Agricultural land covers around 60% of the territory. Danish agriculture is a large net exporter 
of agricultural products, and the contribution of agriculture plays an important role in the country’s 
economy. Pigmeat and dairy are the most important sectors in terms of production value.   

Reporting 

The deadline for reporting the 3rd RBMPs was in March 2022. The Commission and the EEA together 
with Member States developed an electronic reporting system in WISE (Water Information System 
for  Europe).  Its  use  was  voluntary.  Some  Member  States  used  it  to  fulfil  their  obligations,  others 
reported the plans in pdf format. The cut-off date for the WISE e-reporting was September 2023 and 
the MS were assessed based on the datasets available by this date.  

By September 2023 Denmark had not submitted full electronic reporting. Therefore, the assessment 
is based on the data mining of the pdf RBMPs. 

Despite the cut off dates for the production of this report, reporting continued and, for the State of 
Water report, the EEA aggregated the results available by July  2024 in their products and dashboards 
available at WISE Freshwater web portal. 

5 

 
 
 
Changes in Status, Pressures, Exemptions & Measures 

Surface 
Water 
Bodies 
(7812) 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

ECOLOGICAL 
STATUS 

The large majority of surface water bodies is not in good or high ecological status. In terms of the number of waterbodies: 29.9% of surface 
water bodies have attained good status, while 57.8% are classified with a lower status and 12.3% have unknown status. The absence of good 
status  concerns  68%  of  rivers,    84%  of  lakes  and  95%  of  coastal  water  bodies.  In  fact,  a  high  proportion  is  in  poor  or  bad  ecological 
status/potential: 34% of rivers, 43% of lakes, and 73% of coastal waters. In addition, 65% of river water bodies and 19% of lakes have unknown 
ecological status/potential. 

Assessing progress through comparing the 2nd and 3rd RBMPs is complicated by changes in the delineation of water bodies, the changes in 
number of quality elements as well as the reduction of the percentage of rivers with unknown status. There seems but little progress: only a 
slight increase in the percentage of surface water bodies in good / high status; an increase in the percentages of rivers, lakes and coastal waters 
in poor / bad status; and a marked rise in the percentage of rivers failing to attain good status. The confidence in the assessment has on the 
whole increased  

While almost all rivers are scheduled to have attained good ecological status / potential by 2027, over half of the lakes and almost all coastal 
water are expected to achieve this only well after 2027. 

Eutrophication caused by nutrients is the major cause of the persistent failure to timely improve the ecological quality: it concerns phosphorus 
for lakes and nitrates for the coastal waters. The main pressure is from agriculture's use of manure and fertilisers, while there are also significant 
contributions from wastewater plants and aquaculture. 

The included measures are insufficient to achieve the stated ecological objectives for 2027. While the baseline assumes 75 % of the estimated 
load reductions planned in the 2nd RBMP to be implemented, the planned measures on top of the baseline cover around 80% of the remaining 
gap. The included measures on river restoration fall 1650 km short of the required effort. In both cases, the announced revision of the 3rd RBMP 
is reported to define additional measures to bridge the gaps. 

6 

 
 
 
 
CHEMICAL 
STATUS 

Only a tiny fraction of surface waters, namely 1.7 %, is in good chemical status, whereas 5.6 % is in poor status and for 92.7% the chemical 
status is classified as unknown. While the absence of good status affects the surface water types nearly equally (99% of rivers, 91% of lakes 
and 95% coastal waters), it is for a different reason. For almost all coastal waters, the status is known, and 93% of them are in poor chemical 
status. In contrast, for 70% of lakes and 97% of rivers, chemical status is unknown. The RBMPs do explain neither this low rate of chemical 
status classification nor the lack of classifications made with high confidence, both of which seems at odds with the extension of the monitoring 
network now covering 85% of all surface waters. 

The comparison between the 2nd and 3rd RBMPs suggests a deterioration, although its extent is hard to ascertain because of the change in the 
number of surface waterbodies and of priority substances as well as the reduction of the percentage of lakes and in particular coastal waters 
in unknown status (resp. with 25 and 39 %-points). The increased rate of chemical status classification goes together with a fall in the ratio of 
good over poor status, namely for all surface water bodies together, from a 1-1 ratio in the 2nd RBMP to a 1-3 ratio in the 3rd RBMP. At least 
for coastal waters, this does not merely reflect an observation effect, but also an actual decline: as share in the total of surface waters with a 
chemical status classification, the percentage of coastal waters in poor status jumps from 17 to 94. 

The chemical status assessment includes only 25 priority substances out of the 45 required by the Environmental Quality Standards Directive, 
only a few more than in the 2nd RBMP. This coverage gap is not explained.  

The RBMPs do not pronounce clearly to what extent rivers and lakes will attain good chemical status by 2027.xxxxxxxThe rather small sample 
of surface water bodies with a status classification suggests a worsening water pollution, the actual size of which remains unclear. In about 
one out of two surface water bodies found in poor status, mercury pollution can count as the reason; it concerns a four-fold increase in number 
of water bodies. Anthracene pollution is a problem in almost as many water bodies, while nearly absent in the 2nd RBMP. The number of water 
bodies affected by cadmium, lead and nonylphenol has also strongly increased.  

7 

 
 
 
 
Ground 
Water 
Bodies 
(2050) 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

QUANTITATIVE 
STATUS 

As in the 2nd RMBPs, almost all groundwater bodies are in good quantitative status (99.6%); these classifications are on the whole made 
with high confidence. In fact, all drinking water comes from groundwater reservoirs with only minimal treatment requirements. Consequently, 
out of the total of 2050 groundwater bodies, 1705 are protected for drinking water abstraction. 

Only 9 out of 2050 groundwater bodies (0.4 %) have been found in poor quantitative status in the year 2021, due to over-abstraction. This 
suggests an emerging (seasonal) scarcity problem, also because 4% of groundwater bodies is at risk to fail good quantitative  status in 
2027. A comparison with the corresponding number of water bodies in the 2nd RBMP is not meaningful because of a fivefold increase in 
the total number of groundwater bodies resulting from a hydrological review that aimed to define entities with more homogenous conditions 
(more rigorous separation of shallow, regional or deep groundwater entities). 

The groundwater associated aquatic ecosystems have been considered, similarly to the approach followed in the 2nd RBMPs. The main gap 
in the assessment methodology is the lack of consideration of groundwater dependent terrestrial ecosystems.   

8 

 
 
CHEMICAL 
STATUS 

A large majority of groundwater bodies is in good chemical status (88.8%). The chemical status is poor in 9.4% of groundwater bodies and 
unknown  in 1.9%.  Even when  accounting  for  the fivefold increase  in the  total number of groundwater bodies due  to a comprehensive 
hydrological review, this seems an improvement vis-à-vis the 2nd RBMP which reported only 44.3% of total groundwater bodies in good 
status with 30.6% in unknown status. The fall in the percentage of waterbodies at risk to fail good status from 25 to 13% also suggests 
an improvement. 

The  chemical  monitoring  of  groundwater  has  covered  the  following  substances:  nitrate,  chloride,  trace-elements,  pesticides  and 
environmentally  dangerous  substances.  The  data  foundation  for  assessing  groundwaters’  chemical  status  has  improved  since  the  2nd 
RBMPs, as it now incorporates data from pesticide monitoring and water utility controls. However, despite the expanded data foundation 
and more homogenous water bodies, the 3rd RBMPs report ‘low confidence’ for most of the status assessment, whereas the 2nd RBMPs 
reported mostly ‘medium confidence.’ 

Pesticides are the group of substances most responsible for the failure to attain good status: almost two thirds of groundwater bodies in 
less than good status have too high pesticide concentrations (amounting to about 7% of all groundwater bodies). In addition, the drinking 
water test has a significant upward effect on the percentage of groundwater bodies in less than good status. Nitrates and trace particles 
are less prevalent causes. 

To a large extent, the pesticides pollution concerns a legacy effect as most of the pesticides concerned have been banned already. This 
implies that overall improvement will be slow as reflected by the small difference between the percentage of groundwater bodies in poor 
chemical status and the percentage of those expected to fail good status by 2027. 

9 

 
 
 
2. Horizontal aspects 

The Danish RBMPs have been mainly assessed on the basis of the traditional reporting of RBMPs (the 
national document and the reports for the 4 RBDs), which were submitted to the Commission in June 
2023, about a half year after the deadline. It has been possible to take account of the information 
by electronic reporting only to a limited extent, since many background documents and data have 
been submitted only in January 2024, this including apparent corrections and revisions. On top of 
this, the Danish authorities indicated in informal comments that they would revise the 3rd RBMPs in 
the  course  of  2024.  It  is  likely  that  the  ongoing  development  of  the  policy  to  combat  nitrogen 
emissions and the recent publication of the new Climate Change Adaptation Plan may also inform 
such revised RBMPs. 

2.1 Governance 

Denmark has a centralised approach to water management. The Danish Ministry of Environment is 
the competent authority for all four River Basin Districts. While the main roles are divided between 
the Ministry and the Danish EPA (Environmental Protection Agency), the overall responsibility belongs 
to the Ministry. 

Water councils are a unique Danish feature of water governance at local level. There are 23 water 
councils in Denmark, in which local stakeholders are represented. Each of them is responsible for one 
specific catchment area. In cooperation with municipalities, each of these water councils have created 
a sub-plan for the catchment area, thus incorporating local knowledge into water planning.  

In general, the Danish RBMPs do not provide a lot of further information on important governance 
issues. As regards public consultation, the authorities have succeeded to elicit a substantial support 
from the whole range of stakeholders, because the consultation was widely advertised and had an 
appropriate  consultation  period  (December  2021  to  June  2022).  In  addition,  stakeholders’  active 
involvement  was  facilitated  through  advisory  groups  and  even  participation  in  the  RBMP  drafting 
process. However, the RBMPs merely state these activities have had impacts on information base and 
measures, but they do not specify how stakeholder recommendations have been taken up.   

As regards the management of coastal waters, despite the large area of coastal waters, the RBMPs 
do neither include the MSFD objectives nor an account how and where the MFSD is implemented. 
While it is reported that the MSFD strategies are coordinated with neighboring countries, they do not 
mention the regional maritime conventions, namely OSPAR for the North Sea coast side and HELCOM 
as regards the Baltic Sea coast. Yet HELCOM plays an important role in coordinating the monitoring 
of the nutrient inputs into to the marine environment (nitrogen and phosphorus) and corresponding 
policies. 

As regards transboundary cooperation, for the Vidå-Kruså RBD, the only international river basin, the 
RBMP  does  not  present  measures  reflecting  coordination  with  Germany.  However,  the  Danish 
authorities have confirmed that such coordination is fully in place. 

2.2 Characterization of River Basin District 

Denmark has four River Basin Districts (RBDs) which function also as the “Units of Management” in 
implementing  the  Floods  Directive.  The  RBDs  are  Jutland  &  Funen;  Zealand;  Bornholm;  and  Vidå-
Kruså (an international RBD shared with Germany).  

10 

 
The first two RBDs cover over 90% of Denmark’s surface. Notably, the first three RBDs are separated 
from  one  another  by  international  waters.  Table  1  below  reports  on  the  number  of  surface  and 
groundwater bodies in these four RBDs, as reported in the 3rd RBMPs.  

Table 1: Number of delineated surface and groundwater bodies in Denmark according to the 3rd RBMPs 

RBD 

Name 

Rivers 

Lakes 

Coastal 
 Waters 

Territorial 
Waters 

Groundwater 
Bodies 

DK1 

DK2 

DK3 

DK4 

Jutland & Funen 

5301 

699 

76 

Zealand 

1109 

244 

30 

Bornholm 

145 

12 

Vidå-Kruså 

148 

31 

2 

3* 

9 

6 

1 

0 

1340 

667 

29 

14 

TOTAL 

6703 

986 

109 

14 

2050 

Note: * 2 of the waters in question are shared. There are no transitional waters in Denmark.  

Delineation 

The 3rd RBMPs (including the national document) reveal some significant changes in the delineation 
of water bodies, although the typology of water body types has reportedly remained largely the same 
per RBD and water categories.  

The number of groundwater bodies has increased fivefold vis-à-vis the 2nd RBMPs, as the result of a 
hydrological  review  of  groundwater  delineation  aiming  to  define  entities  with  more  homogenous 
conditions (more rigorous separation of shallow, regional or deep groundwater entities). This large 
change hinders in-depth status comparisons between the 3rd and 2nd RBMPs. 

The review of the delineation of surface waters has led to smaller changes. The number of rivers and 
of coastal waters have both decreased by roughly ten percent whereas the small number of territorial 
waters  has  remained  the  same.  In  contrast,  the  number  of  lakes  has  increased  by  about  fifteen 
percent as the net result of adding two hundred new lakes and excluding about fifty smaller lakes 
seen as not or no longer meeting the size or other criteria to qualify as a lake.  

The RBMP national document does not provide summary information on the percentage of surface 
water body types for which type-specific reference conditions have been established for biological, 
physico-chemical  or  hydromorphological  quality  elements.  Neither  is  it  reported  whether  the 
reference conditions for the international Vidå-Kruså RBD have been coordinated with Germany.  

It is not clear whether these gaps result from a reporting issue rather than a lack of implementation 
since the Danish authorities have submitted the relevant background documents to WISE’s / Eionet’s 
central  data  repository  in  January  2024  (thus  well  after  the  RBMPs’  submission  date),  and  they 
mention that they have intercalibrated type-specific reference conditions with other relevant Member 

11 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
States as part of the European Commission’s Intercalibration Decisions. However, the intercalibration 
of reference conditions is still in progress for macroalgae in coastal waters of both Baltic Sea and 
the Atlantic. 

Pressures  

The  RBMPs’  set  of  documents  does  not  provide  a detailed  account  of  the  definition  of  significant 
pressures  (detailing  the  relationship  with  threshold  and  risk  assessment),  but  they  provide 
information  on  the  main  pressures  on  water  bodies,  coming  from  the  assessments based  on  the 
findings  from  the  national  monitoring  programme  NOVANA,  authority  supervision  and  special 
investigations. 

Surface waters 

The key impacts on (chemical  and ecological) water quality come from nutrient (both nitrate and 
phosphorous), organic, and hazardous pollutants as well as morphological changes.  

In particular, most coastal water bodies and many lakes have been affected by nutrient pollution, 
with wastewater discharges and aquaculture as the key point source pressures and the ammonia 
and nutrient emissions from agriculture as the key diffuse source pressure.  

Nutrients  are  the  major  cause  of  the  persistent  failure  to  timely  improve  the  ecological  quality. 
Agricultural  activities  (involving  manure  and  fertilisers)  are  the  main  culprit  (although  there  are 
significant contributions from wastewater plants and aquaculture as well). Water courses transport 
these nutrients loads from the land into lakes and coastal waters, where they accumulate over time 
and significantly degrade the aquatic ecosystems. Phosphorus is considered as the main pressure 
factor for lakes, and nitrates for the coastal waters. Figure 1 shows the widespread and persistent 
impacts from sustained nutrient pollution. 

The  excess  of  nutrients  causes  leads  to  eutrophication,  i.e.  the  excessive  growth  of  bacteria  and 
algae.; In combination with higher water temperatures, it causes severe (seasonal) oxygen depletion 
and toxic residues on the water floor, killing off entire ecosystems. There appears to be much more 
information  on  the  nature  and  extent  of  ecological  damage  in  coastal  waters  than  for  lakes;  the 
problem concerns mostly the coastal waters at the Baltic Sea coast (see Figure 3 below). The coastal 
water’ s high fish mortality and the increasing occurrence of large marine “dead zones” without hardly 
any maritime life has been widely reported in the press1, noting that this longstanding problem has 
increased  to  (near)-catastrophic  proportions  raising  questions  on  the  adequacy  of  the  nitrogen 
abatement measures.  

1 It has been prominently reported since 2020, in Danish mass media (see as example,  this article (in Danish) from the 
Danish TV2 news) and even beyond (mostly in environmental news outlets, such as this one, and generic media, such as 
from France-international). 

12 

 
 
 
 
Figure 1: The impacts of nutrient pollution on the ecological quality of water: the trophic state of Danish surface water 
bodies 2016 – 2019 

Source: Joint Research Centre of European Commission (n.d.). JRC NITRATES DIRECTIVE - Reporting Period 7 (2016-2019) 
Trophic Status. [online] water.jrc.ec.europa.eu.  
Available at:  https://water.jrc.ec.europa.eu/portal/apps/dashboards/cb6034c2a75e4df282f8a62f90c16caa  

Indeed, since 2020, Aarhus University studies have signalled that, after some improvements in the 
previous decade, since 2019 the coastal water’s oxygen depletion issue has rapidly increased in both 
proportion  and  severity.  The  studies  are  an  important  input  to  the  Danish  government’s  scientific 
assessment of the Danish coastal and marine waters. One of their studies already raised the alarm 
in 2020, based on the observation that the total coastal sea area affected by oxygen depletion in 
that year was about twice as high as in the previous year2. Their study from August 20233 concludes 
that  the  extent  of  the  oxygen  depletion  in  2023  was  the  second  largest  one  ever  recorded  for 
September. It also identifies a worsening trend over the recent years (see Figure 2 below), reflecting 
both  the  shortfall  of  the  reductions  so  far  achieved  in  the  nitrogen  inputs  into  these  waters,  a 
significant part of which originates from agricultural activities in Denmark, and the increasing impact 
of  climatic  factors,  specifically  a  trend  towards  higher  water  temperatures  in  Danish  coastal  and 
marine waters.  

2 See as example of the press attention for this study, this article in phys.org. 
3 Aarhus University, “Oxygen depletion in Danish waters 29 August – 25 September 2024,” DCE (Danish Centre for Energy 
and Environment) advisory note (in Danish), 4 October 2024.  

13 

 
 
 
Figure 2: Reported area size of moderate and severe oxygen depletion in Danish coastal waters 

Source: see footnote 3 

Figure 3: Map on the geographic extent of oxygen depletion in Danish coastal waters 

Source: see footnote 3. The red and orange areas are with strong and moderate oxygen depletion respectively. 

14 

 
 
 
 
 
As regards the discharge of wastewater from treatment plants, it is a key pollution source, affecting 
about 1% of the length of all rivers. Larger wastewater treatment plans (i.e. with capacity over 30 
persons equivalents) constitute the largest contributor of nitrogen and phosphorus and the second 
largest contributor of organic material. In addition, the discharges from unconnected dwellings show 
comparably high discharges of the same pollutants, due to the lower degree of treatment; and the 
same applies to the incidental storm water overflows of sewage systems.  

In addition, morphological changes (including dams, barriers and locks) alter aquatic habitats and 
thus reduce the ecological water quality.  

As regards invasive alien species, some species of crayfish are included in the national list of invasive 
alien species and efforts are ongoing to map their distribution4. This will allow ascertaining to what 
extent  the  populations  of  invasive  crayfish  already  present  in  the  Danish  aquatic  environment  is 
significant or not. Likewise, the floating fern (Azolla filiculoides) is an aquatic plant present on the 
national invasive alien species list since it has been found in some water bodies in Denmark. These 
plants can form very dense mats in favourable habitats, causing many difficulties for boat transport, 
water animals and native plant species, and becoming a source of eutrophication. 

The  RBMPs  recognise  that  climate  change  impacts  can  be  expected  to  exacerbate  pressures  on 
surface  water  bodies,  which  may  contribute  to  them  not  achieving  good  ecological  status.  The 
increased rainfall leading to the acceleration of nutrient run-off from land into inland waters and 
then to coastal waters, as well as higher temperatures5 lead to higher eutrophication and oxygen 
depletion resulting in long-term damage. 

Groundwater  

The main pressures concern pollution, namely soil pollution as point source pressure and agriculture’s 
fertiliser and pesticide use as the main diffuse source pressure. While current pressures and impacts 
are  much  less  widespread  than  the  pressures  on  surface  waters,  the  pollution  concentration,  in 
particular in deep groundwater bodies, respond to emission volumes over time with long time lags. 

Nitrates concentrations in groundwater exceed the limits established in the Nitrates Directive in a 
considerable number of points. See the map in Figure 4 below. 

4 Søren Berg et al., “Mapping the distribution of crayfish and crayfish plague in Danish waters,” DTU Aqua-rapport nr. 401-
2022 (in Danish); available online. 
5 For rainfall and temperature alike, it concerns both average and peak levels. Run-offs can also lead to inflow of pesticides 
and sediments, putting further pressure on the ecological status. 

15 

 
 
Figure 4: Nitrates concentration from agricultural sources in groundwater- report on implementation of 
the Nitrates Directive6 

As further discussed in section 3.3, water is mainly abstracted from groundwater, with agriculture 
and public water supply as the major user destinations.  Similarly to the 2nd RBMPs, Denmark has 
not identified water abstraction (understood as consumptive use or net consumption) as a significant 
pressure at the RBD level or in significant portions of an RBD for any RBD in Denmark. However, the 
3rd RBMP’s economic analysis does not seem to explore whether on the longer term, there may be 
bottlenecks in water supply to meet the demand for abstracted water by the different user sectors. 
It appears that water scarcity is not seen as a significant problem as only 9 groundwater bodies fail 
to be in good quantitative status in 2021 and all  groundwater bodies are expected to be in good 
status by the year 2027. 

6 Taken from the country fiche for Denmark in the Nitrate Directive Reporting 7: groundwater. 

16 

 
 
 
3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

Monitoring 

The  RBMP  traditional  reporting  has  a  relatively  weak  coverage  on  the  state  of  play  regarding 
monitoring,  assessment  and  classification  of  ecological  status,  also  because  for  the  factual 
corroboration, it refers to missing or late electronic reporting on the relevant aspects. For instance, 
the data available to the RBMP assessment do not say anything on monitoring frequency. 

The 3rd RBMPs claim progress in the monitoring scope,  namely a clear increase in the number of 
water bodies covered and in their geographical spread. The vast majority of surface water bodies in 
all RBDs are monitored on the basis of the national guidelines NOVANA. Reportedly, all water types 
have  a  monitoring  programme,  and  the  monitoring  is  evenly  spread  out  over  the  country. 
Consequently, for each RBD, less than 10 % of the water bodies is in unknown ecological status. All 
coastal  waters  are monitored  and  classified.  Although  not mentioned  in  the  RBMPs,  grouping  has 
been used to classify smaller lakes. The remaining unclassified water bodies are mostly small lakes 
and watercourses.  

The monitoring has also improved through covering more quality elements, although it appears that 
for  none  of  the  surface  waters,  the  surveillance  monitoring  has  included  all  required  elements. 
Notably, it appears that there is no specific information on ecological flows. A clear picture is however 
difficult  to  obtain  due  to  a  lack  of  electronic  reporting  at  the  time  of  RBMP  submission  and 
assessment. With a view of the discussion further below, it merits highlighting that Denmark has not 
fulfilled its obligation to monitor all necessary quality elements. Most coastal water bodies have been 
monitored for all the required biological quality elements, but not for thermal conditions (neither in 
lakes), whereas for rivers, nutrients have not been monitored7. 

Of note, the Commission has expressed for some time concerns about the significant gaps in the 
monitoring systems for surface waters in Denmark, and, relatedly, about the very large number of 
unknowns in the status of many surface water bodies. In exchanges with the Danish authorities, it 
transpired that they have recognised that several of these monitoring and related knowledge gaps 
needed to be addressed. The 3rd RBMPs reflect these efforts, but it appears that many monitoring 
deficiencies and number of unknown status aspects remain, seriously  hindering the possibility for 
Danish surface waters to achieve compliance with the WFD objectives. 

Status assessment  

The 3rd RBMPs reveal that Denmark faces a huge persistent challenge to improve the overall bad 
ecological quality of Danish waters. Overall, in the year 2021, 95% of Danish coastal water bodies, 
64%  of  its  lakes  and  67%  of  the  rivers  are  reported  to  be  in  less  than  good  ecological  status  / 
potential, and quite a high proportion of them (73% of coastal waters and 43 % for both lakes and 

7 Nutrients do not constitute a compulsory monitoring item for rivers. 

17 

 
 
rivers) are found to be in poor to bad ecological status / potential.  The traditional RBMP reporting 
does not discuss the confidence of the ecological status assessments. 

Overall, the situation appears to have hardly improved over the 2nd RBMP period. 29.9% of all Danish 
water bodies are recorded to be in at least good status / potential in the year 2021, versus 28.2 % 
in 2015. This is depicted in Figure 5. Nutrients are the major cause of the persistent failure to timely 
improve the ecological status. 

Unfortunately, the changes in the numbers of water bodies delineated and classified hinder a more 
robust  comparison.  However,  as  regards  the  fully  classified  category  of  coastal  waters,  while  the 
share in good status has increased somewhat, the much larger fall in the share of moderate status 
is nearly matched in size by an increase in the share of poor to bad status, strongly suggesting a 
significant deterioration8.  

Figure 5: Ecological status of surface water bodies 

The expected ecological status in 2027 varies strongly over the surface water categories. While the 
RBMPs expect all rivers will achieve good ecological status by 2027, a clear majority of lakes and 
95% of coastal waters are expected to reach good status with the planned measures only well after 
2027. 

The  Danish  RBMPs  point  to  an  interesting  trade-off  in  nature-based  attempts  to  improve  the 
ecological quality of surface waters. It is claimed that when properly executed, frequent weed-cutting 
contributes  to  mitigating  high  levels  of  nutrients,  but  at  the  expense  of  the  diversity  and  hence 
robustness of the involved aquatic ecosystems, both as regards flora and fauna. 

8 Both tendencies need to be interpreted with some care in view of the about ten percent reduction in the number of coastal 
waters. 

18 

 
 
 
3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

The relative low share of heavily modified and artificial water bodies (see Table 2 below) suggests 
that level of human intervention in the physical aspects of Denmark’s water system is not very high.  

Table 2: Number of heavily modified and artificial surface water bodies in Denmark according to the 3rd 
RBMPs 

Modifications 

Rivers  
(% of total 
rivers) 

Lakes  
(% of total 
lakes) 

Coastal 
Waters  
(% of total 
CWs) 

Territorial 
Waters  
(% of total) 

Total 
(% of total 
SWBs) 

HEAVILY MODIFIED 

5.64% 

0.00% 

3.67% 

0.00% 

0.00% 

ARTIFICIAL 

3.21% 

0.20% 

0.00% 

0.00% 

0.00% 

Note: SWB = Surface Water Bodies. There are no transitional waters in Denmark.  

Both in absolute numbers and percentages, there are more rivers qualifying as heavily modified and 
artificial  than  is  the  case  for  the  other  surface  water  categories  (see  Figure  6).  Denmark  has  no 
transitional and territorial waters, and there are only 2 artificial lakes and 4 heavily modified coastal 
waters. The low reported number for lakes may be related to the delineation restrictions, such as on 
size and specific regulatory use (it concerns lakes that according to the regions’ raw material plans 
lakes are located in active digging areas, or lakes that are appointed as wastewater technical facilities 
in the municipality’s wastewater plan). Coastal waters can be heavily modified due to the presence 
of locks which protect the inland catchment area against high sea levels during severe storms (cf the 
lock in Vejle fjord).  

Figure 6: Number of heavily modified and artificial surface water bodies in Denmark according to the 3rd 
RBMPs 

6,00%
5,00%
4,00%
3,00%
2,00%
1,00%
0,00%

Rivers

Lakes

Coastal
Waters

Total

HEAVILY MODIFIED

ARTIFICIAL

19 

 
 
The 3rd RBMPs do not indicate the change vis-a-vis the 2nd RBMPs. However, when comparing the 
reported percentages of HMWBs and AWBs, the percentages reported in the 3rd RBMPs appear the 
same or a bit smaller than those reported9 in the 2nd RBMPs.  

On  a  positive  note,  Denmark  has  defined  good  ecological  potential  for  all  heavily  modified  and 
artificial surface waters. The assessment appears to use more or less the same elements as used in 
the assessment of ecological status.  

HMWBs and AWBs do not have to reach good ecological status but just good ecological potential, 
which reflects a lower level of ambition. Yet only a minority of HMWBs and AWBs appear to be in 
good  ecological  potential.  The  3rd  RBMPs  report  that  about  one  fifth  of  the  heavily  modified  and 
artificial water courses (“rivers”) have at least good ecological potential. Of the two artificial lakes, 
one is reported to have ‘moderate’ ecological status, while the status of the other one is unknown.  
None of the four heavily modified coastal waters are in good ecological potential. Due to the lack of 
detailed reporting in the traditional RBMP reporting, it is not possible to assess progress vis-à-vis the 
situation reported in the 2nd RBMP. 

3.3 Groundwater bodies - have they sufficient water – quantitative status 

Monitoring 

All  groundwater  bodies  have  been  monitored  for  the  3rd  RBMP.  Municipalities  closely  monitor  the 
status  of  groundwater,  as  they  issue  and  regularly  review  abstraction  permits  as  regards  the 
environmental  objectives. Their  assessment includes  the increase  in  chloride  contents  because  of 
saline intrusion and an increase in the concentration of toxic metals.   

Status assessment  

Almost all groundwater bodies have been found to be in good status in the year 2021 (99.6% of the 
total number of groundwater bodies). The good state of affairs is important because in Denmark, 
water  is  mainly  abstracted  from  groundwater,  and  85%  of  the  Danish  groundwater  bodies  are 
designated as potential zones for drinking water abstraction.  

The  assessment  has  used  grouping  within  a  RBD  over  groundwater  bodies  of  similar  sub-type 
(shallow,  regional  or  deep  groundwater  bodies),  and  the  assessment  concerns  a  model-based 
approach,  including  as  appraisal  elements  the  water  balance,  the  quality  of  aquatic  ecosystems 
associated  with  groundwater,  as  well  as  saline  intrusions.  The  needs  of  depending  terrestrial 
ecosystems have not been included because a study found only limited indications or evidence of 
the related impacts on the status.10 As for other status dimensions, the traditional RBMP reporting 
does not discuss the confidence of the quantitative status assessments. 

However, although the level of precipitation has not fallen over time, there are 9 groundwater bodies 
failing to reach good status. They are all located in the larger two RBDs (namely 3 in Jutland & Funen 
and 6 in Zealand). Hence over-abstraction seems to be the main cause. Yet, the 3rd RBMPs say that 

9 See Figure 7.1 in the European Commission’s assessment of Denmark’s 2nd RBMPs, SWD(2019) 38, February 2019. 
10  The  study  was  one  of  the  so-called  knowledge  increasing  measures  from  the  2nd  RBMPs.    The  3rd  RBMPs  conclude, 
however, that more research is needed. Hence, this factor contributes to the uncertainty of quantitative status assessments. 

20 

 
 
all  groundwater bodies are expected  to maintain or achieve good quantitative status by the year 
2027. 

The situation overall appears quite similar to the one in the 2nd RBMP. However, a precise quantitative 
assessment of the progress since the 2nd RBMP is difficult due to the five-fold increase in groundwater 
bodies due to the new delineation (see section 2.1.2 above).   

The 3rd RBMPs introduce as new measure the cross-municipal cooperation on water abstractions in 
order  to  ensure  that  abstractions  are  drawing  from  more  groundwater  bodies  and,  thus,  a  more 
sustainable utilisation of each individual groundwater body. 

Climate scenarios indicate as key challenge the saline intrusion into coastal wells, due to the rise in 
sea level rise. This implies that in the future the groundwater abstractions will have to be limited 
accordingly, and hence that the availability and quality of surface water as water supply source will 
increase in importance. 

3.4 Protected Areas (identification, monitoring, objectives and measures) 

There  are  different types and  reasons  why  certain water  bodies  are  protected  under  the  law.  For 
surface water bodies, protected areas have been designated under the Drinking Water, Bathing Water, 
Habitats  and  Birds  Directives  as  well  as  for  areas  designated  for  the  protection  of  economically 
significant aquatic species (i.e. aquaculture).  

The 3rd RBMPs contain a register for protected areas, including a map, showing that Denmark has 
identified protected areas for all types associated with surface and groundwater. However, due to the 
traditional RBMP reporting’s unclear reporting, it has been difficult to form a picture of the current 
status and the changes compared to the previous cycle. 

The Danish authorities have declared the whole  country as a nutrient sensitive area. This implies 
there is no differentiation over the country area as regards Nitrate Vulnerable Zones designated under 
the  Nitrates  Directive  and  sensitive  areas  under  the  Urban  Waste-Water  Treatment  Directive,  but 
there is a single, national Nitrate Action program in place that includes measures such as restrictions 
for the spreading of livestock manure as well as permitting and approval requirements for a range 
of activities that could affect the drinking water supply.  

The  3rd  RBMP  report  1705  out  of  the  total  of  2050  groundwater  bodies  as  protected  areas  for 
drinking water, about 40% of which are registered for active abstraction and thus subject to more 
stringent monitoring. These monitoring efforts also appear more focussed as before. While the 2nd 
RBMPs had indicated that all groundwater bodies (402 in total) functioned as drinking water source, 
the  current  1705  drinking  water  bodies  represent  more  than  99  %  of  the  total  volume  of  all 
groundwater,  thus  smaller  water  bodies  are  no  longer  subject  to  the  additional  monitoring 
requirements. The RBMP explains that this is a result of a revised designation process concomitant 
to  the  substantial  revision  of  groundwater  delineation  (see  section  2.1.2  above),  but  it  does  not 
provide clear details on the drivers of the increase.  

21 

 
 
 
Municipalities  are  required  to  develop  action  plans  for  groundwater  protection  in  these  protected 
areas. These plans cover approximately 40 % of Denmark's area and should address the challenges 
identified in the national groundwater mapping.11 In their capacity as abstraction permitting authority, 
municipalities can set permit conditions to prevent potential negative effects.  

As regards the other types of protected areas, the national 3rd RBMP mentions Natura 2000 areas 
protecting  water-dependent  habitats  and  species,  as  well  as  a  few  shellfish  protected  areas  and 
bathing areas, for which specific protection rules from EU legislation apply. The national RBMP PDF 
does not explain why the number of habitats protected areas has fallen considerably vis-à-vis the 
2nd RBMPs, namely12 from 417 to 269.  

As mentioned above, in general, the reporting on the protected areas suffers from two significant 
gaps, making it difficult to assess progress. First, the 3rd RBMPs do not present an overview of the 
status of the water bodies associated with protected areas. Second, regrettably, despite an explicit 
Commission recommendation for Denmark’s in the 2nd RBMPs, the report does not clearly identify the 
additional objectives and the corresponding additional measures adopted for these areas (while they 
may be subsumed in the Programme of Measures’ basic measures). 

3.5 What is being done to prevent/reduce hydromorphological pressures 

Denmark has a permitting regime controlling abstractions and water impoundments. Each RBD has 
a register of impoundments.  

River restoration is the main focus of the hydromorphological measures in the PoM, aiming to achieve 
good ecological status (or potential) for all rivers at the end of the programming period (thus the 
year 2027), despite the backlog in the implementation of measures in the 2nd RBMPs and an explicitly 
acknowledged lack of impact from the measures defined in the current programme. The expected 
benefits come from the planned  wastewater measures, the removal  of about 750 barriers in the 
watercourse  system  (and  other  measures  to  promote  free-flowing  water  courses),  and  from  the 
ongoing effects from already completed measures. Jointly, it is expected that these measures will 
improve the status of up to 5500 km of rivers falling short in terms of the  total kilometres below 
good status (and for some river stretches perhaps also as regards the extent of the improvements).  

The  authorities  have  stated  explicitly  that  they  will  define  the  remainder  of  the  measures  in  an 
updated version of the 3rd RBMP foreseen for later this year, but it remains unclear whether this is 
related to the measures aimed to reduce nitrates emissions from agricultural activities (mostly via 
run-offs from the fields) or also hydromorphological pressures. 

As regards measures involving nature-based solutions (NBS), there are prominent NBS measures, 
including  wetland  restoration,  and  the  establishment  of  wetlands  and  ponds  aimed  at  capturing 
phosphorous and nitrogen. However, the RBMPs do neither present a systematic overview of their 
potential and actual implementation, nor do they mention any national or regional strategy.  

11 This mapping from the Environment Agency has identified the specific nitrate-sensitive and pesticide-sensitive abstraction 
areas. Municipalities also have the authority to develop additional action plans beyond designated areas and, if necessary, 
enforce the action plans’ measures.  
12 The 2nd RBMP figures are from Table 15.1 in SWD(2019) 38, and the 3rd RBMP figure is mentioned in Annex 15 of the 
national 3rd RBMP document. 

22 

 
 
As  regards  HMWBs  and  AWBs,  the  3rd  RBMPs  do  not  contain  much  information  describing  or 
assessing whether the hydromorphological modifications could be changed or mitigated. This is a 
cause  of  concern  since  a  large  number  of  such  modified  water  bodies  are  not  reaching  good 
ecological potential. There is only some information for the four coastal water bodies designated as 
HMWB, namely the requirement to operate the installed locks so that it supports the achievement of 
good ecological potential. 

3.6 What Denmark is doing for abstractions and water scarcity 

As said in section 3.3 already, municipalities are responsible for abstraction permits. They regularly 
review  these  permits  to  ensure  that  all  water  bodies  can  achieve  their  environmental  objectives, 
including an assessment of the abstraction activity’s impact on the water flows in rivers (streams). 
However, the RBMPs do not appear to indicate the frequency of the review and they do not provide 
specific information on ecological flows.   

It is important to note that there seems to be no measures proposed to reduce pressures on the 9 
ground water bodies which are in bad quantitative status due to over abstractions.   

While the RBMPs mention a few measures on droughts and scarcity, they do not discuss a medium 
to  long  planning.  Notably,  the  RBMPs’  economic  analysis  does  not  explore  either  whether  on  the 
longer term, bottlenecks in water supply side could occur to meet the demand for abstracted water 
by the different user sectors. The key programme measure concerns water retention through nature-
based solutions for river restoration (promote the free-flowing of water courses and planting trees 
along riverbanks).  However, it is of note that the water abstraction tax is only paid by households 
and industry, but not by agriculture, and that the tax rate is not informed at all by an estimate of the 
resource costs of water scarcity. 

3.7 Adaptation to climate change 

The Danish RBMPs include a general presentation of expected types of impact from climate change 
on  Danish  lakes,  rivers  and  coastal  water  bodies  and  the  extent  to  which  the  impacts  of  climate 
change will be mitigated by the proposed measures, but without providing detailed information. There 
are nevertheless background documents that include more detailed climate proofing of the RBMPs. 

Specific climate change adaptation measures have not been reported as such in the Programmes of 
Measures, however a range of measures are explicitly highlighted as having co-benefits for climate 
change adaptation. This includes measures such as river flow restoration efforts that aim to alleviate 
the  adverse  impacts  of  heavy  precipitation  in  terms  of  floods  risk,  or  floodplain  restoration  and 
meandering,  that  are  anticipated  to  positively  affect  nitrogen  retention  and  reduce  nitrous  oxide 
emissions,  while  also  supporting  natural  water  retention.  Furthermore,  securing  coastal  areas 
throughout Denmark against floods is an ongoing theme of the RBMPs. 

As regards risk of droughts, it should not be noted while the issue was not considered relevant for 
Denmark in the 2nd RBMPs, in the 3rd RBMPs, the potential risk of drought as a climate change impact 
is explicitly mentioned even if in generic terms only, without specifically highlighting drought as major 
climate change challenge and without  presenting specific measures to tackle  them.  Yet, Denmark 
faces the emergence of seasonal droughts spells and corresponding seasonal water scarcity. At first 

23 

 
sight, climate change does not seem to pose a water availability challenge in Denmark, since climate 
scenarios point to a likely increase of the annual precipitation volume. However, it is necessary to 
consider the variation in water availability as well as vividly illustrated by the drought spells in 2022 
and Spring 202313, with the ensuing water scarcity impacting agricultural production and public water 
supply in some regions.  

Despite this recent experience, as well as mounting evidence on the increased risk of drought across 
Europe14, there is no mention of any plan drought management plan in development and the PoMs 
of  the  3rd  RBMPs  do  not  include  specific  measures  against  droughts,  but  only  provide  a  cross-
reference to the fact that some of the restoration measures (as mentioned above) also contributes 
to climate adaptation. In addition, the underlying economic analysis does not explore whether on the 
longer terms there may be bottlenecks in water supply to meet the demand for abstracted water by 
the different user sectors (see section 5.2).  

As regards floods, fluvial and sea water floods are considered as potentially significant sources of 
flooding in Denmark and are expected to become more frequent and severe in the future. The Floods 
Directive  requires  to  consider  the  impacts  of  climate  change  on  the  occurrence  of  floods,  and 
therefore in the preparation of Flood Hazard and Risk Maps (FHRMs) and Flood Risk Management 
Plans (FRMPs). More information on these can be found in Section B. However, considering the close 
relationship  between  overall  water  management  and  floods  management  and  the  importance  of 
climate change effects on both, climate change effects are jointly addressed in this section.   

The impacts of climate change on flood risk have been considered in Denmark at the time of the 
second preliminary flood risk assessment. The spatial extent of all APSFRs is assessed based on an 
extreme event (historic extreme event or 1 000 years statistical event, whichever was more extreme) 
plus a climate factor. The climate factor used was determined in a previous study specifically for 
Denmark  and  is  for  fluvial  flooding  and  storm  floods  based  on  the  scenario  RCP8.5  of  IPCC’s  5th 
assessment report. 

In the first FHRMs future scenarios were related to the years 2050 and 2100, in the current FHRM 
cycle the same time intervals were used, but updated, resulting in future scenarios for 2065 and 
2115. Both in the first and second FHRMs the results were used to inform the maps. RCP8.5 emission 
scenarios are used in the current modelling to consider climate change, in the first FHRMs it was 
unclear which IPCC information/data was used. 

Denmark’s two UoM-level FRMPs, as well as the three municipal FRMPs assessed, indicate that the 
likely impact of climate change on flood extent and frequency is considered (some plans note that it 
is addressed in the FHRMs used to develop  the FRMPs). In the second FRMPs, while they refer to 
coordination with local adaptation plans, no progress was  found concerning coordination between 
the FRMPs and the national climate change adaptation strategy, nor how this strategy impacted the 
selection of flood risk management objectives and measures. On the other hand, some municipal 
FRMPs include measures to address floods in the context of climate change or indicate an intention 
to integrate flood and climate change plans more closely in the future. 

13 These droughts are not a fully new phenomenon given the droughts in 2008 and 2018. 
14 European Drought Risk Atlas, EEA European Climate Risk Assessment 

24 

 
 
4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring 

The Danish authorities report that out of the 7812 surface water bodies, there are monitoring data 
for 6769 water bodies (87%). The monitoring coverage varies a bit over the various surface water 
body  types.  Almost  all  coastal  water  bodies  are  monitored  (99%),  more  or  less  in  line  with  the 
percentage  of  coastal  waters  with  a  known  status.    However,  the  RBMP  does  not  provide  a  clear 
explanation why the high monitoring rates for rivers and lakes (respectively 88% and 79%) do not 
result in more status classifications. 

Status assessment  

The  problems  to  assess  and  classify  chemical  status  are  widespread  within  and  over the various 
inland surface water categories: 97.4% of rivers and 70.3% of lakes are reported to be in unknown 
status15  (corresponding to 6532 rivers and 693 lakes). In contrast, this is so for only two coastal 
waters (1.8%)16. Overall, 92.7% of surface water bodies (excluding territorial waters) do not have a 
status. In addition, the traditional RBMP reporting does not discuss the confidence of the chemical 
status assessments. 

Strangely, the reported high coverage of monitoring starkly contrasts with the widespread lack of 
status  classification.  Two  large  barriers  impede  a  good  view  on  the  chemical  state  of  Denmark’s 
surface waters, namely the large share of surface waters without a status classification, despite the 
reported increased geographical coverage of the monitoring, and the exclusion of about half of the 
priority substances in the chemical status definition or its determination.  

With these large gaps, it is far from assured that the RBMP figures on the share of water bodies in 
good status are representative, and hence, it cannot be excluded that the actual situation is different 
and perhaps less favourable than reported.  

The prevalence of surface water bodies in unknown status has been a persistent problem, where only 
limited  and  uneven  progress  has  been  made.  The  2nd  RBMPs  reported17  that  for  99.7%  of  rivers, 
95.7% of lakes and 41.1% of coastal waters, the status was unknown; for all surface waters, it was 
98.5%. Hence, only for coastal waters has this problem be largely solved, with little progress for lakes 
and hardly any at all for rivers. 

15 Following difficulties to extract the relevant information from the 3rd RBMP PDFs, the Danish authorities kindly provided 
for each of the different surface water types, the percentages of water bodies in unknown status as well as those in good 
status and less than good status, the latter two both in terms of all surface water bodies of the type in question and of 
those  with  known  status.  The  corresponding  percentages  were  not  provided  for  the  total  of  all  surface  water  bodies 
(apparently without terrestrial waters). 
The corresponding number of water bodies have been calculated at the hand of the figures from Table 1 above and the 
provided percentages. These numbers have a margin of error because the percentages were reported in round numbers 
and because of an apparent inconsistency in the percentages reported for lakes (a discrepancy of 10 lakes).   
16 This figure is based on the  EEA dashboard. Table 6.9 of the national RBMP mentions 3 coastal water bodies in good 
status. 
17 SWD(2019) 38, Table 4.1 

25 

 
 
Of note, the Commission has expressed for some time concerns about the significant gaps in the 
monitoring systems for surface waters in Denmark, and, relatedly, about the very large number of 
unknowns in the status of many surface water bodies. In exchanges with the Danish authorities, it 
transpired that they have recognised that several of these monitoring and related knowledge gaps 
needed to be addressed. The 3rd RBMPs reflect these efforts, but it appears that many monitoring 
deficiencies and number of unknown status aspects remain, seriously hindering the possibility for 
Danish surface waters to achieve compliance with the WFD objectives. 

However, even with the current limited knowledge on status, the reported figures on chemical status 
are reason for concern (see Figure 7 below). 7% is reported to be in good status and 5.6 % in less 
than good status (corresponding to 136 and 435 surface water bodies). For rivers (water courses), 
lakes  and  coastal  waters,  these  percentages  are  respectively  0.6,  9.3  and  5.5%,  for  good  status 
(corresponding to 38 rivers, 92 lakes and 6 coastal water bodies); and 2.0, 20.4 and 92.7% for less 
than good status (corresponding to 133 rivers, 201 lakes and 101 coastal water bodies).18 

Figure 7: Chemical status of surface water bodies 

As regards (observed) good status, there has been very modest progress since the 2nd programming 
cycle  for  inland  surface  waters  and  a  marked  deterioration  for  coastal  waters  The  2nd  RBMPs 
reported19 a mere 0.1% of rivers (7 in total) and 0.4% of lakes (3 in total) in good status, while about 
half of the coastal waters (48.7% amounting to 58 coastal waters) was in good status, whereas for 
most of other ones (41%) the status was unknown. The observed deterioration in the Danish coastal 
waters’ chemical status matches the overall decline in their ecological status (as reported in section 
3.1 above), although there is no information whether this is due to common underlying drivers.  

18 In terms of water bodies with known status, 22 % of rivers is in good status (rather than less than good status), and 
31% of lakes, and 7% of coastal waters. For all surface water bodies, it is 23.8%. 
19 See footnote 17. 

26 

 
   
 
The Danish authorities classify the chemical status of surface waters at the hand of an assessment 
that overall includes only 25 priority substances out of the 45 required by the EQSD.20 The national 
RBMP  document  does  not  provide  the  reasons  for  this  assessment  gap.  Without  the  necessary 
information  on  the  presence  and  concentrations  of  the  substances  ignored,  it  is  not  possible  to 
ascertain as to whether their inclusion would have led to a worse percentage of water bodies failing 
to achieve good chemical status.  

While the traditional RBMP reporting does not inform how often specific priority substances cause 
surface water bodies to fail good status, these data are publicly available.  

In decreasing order of occurrence, these chemicals with observed exceedances concern: mercury (280 
water bodies), anthracene (205), lead (88), cadmium (64), nonylphenols (36), BDE (23), PFOS (19), 
naphthalene (16), octylphenol (1). Two of these substances (mercury and PFOS) are part of the set 
of substances considered uPBT.  

Above  all,  mercury  pollution  ranks  first.  For  about  one  in  three  water  bodies  failing  good  status, 
mercury is (one of) the reason(s)21. 

A comparison with the most common pollutants in the 2nd RBMP and their occurrence, gives reason 
for concern. For mercury, in terms of the percentage of all surface water bodies (2.9%), it concerns 
a huge four-fold increase since the 2nd RBMP, equally worrisome be it an effect of better monitoring 
or an increase in pollution.  

The 3rd RBMP also reports for other priority substances a higher prevalence of causing status failure 
than before. The second ranking priority substance, anthracene, is just behind mercury in prevalence 
(2.6%), while in the 2nd RBMP, it was reported for just one water body. Lead and cadmium lead to 
status failure for about 1% of all surface water bodies, and nonylphenol for about 0.5% (with 88, 64 
and 32 water bodies respectively ranking 3rd, , 4th and 6th); for all three, this implies a strong increase 
in the percentage share of water bodies affected. Just as nonylphenol, the priority substances PFOS 
and naphthalene are found to cause status failure for the first time (in 19 and 16 water bodies, which 
is about 0.2%). PBDE is found as a cause for status failure for 23 water bodies (about 0.3%). Nickel 
and benzopyrene are no longer reported as leading to water bodies failing to attain good status, 
whereas nickel was found in eight water bodies in the 2nd RBMP.   

This increases might be partly due to a more accurate monitoring but regrettably are not reflected in 
the status assessment which are largely unknown. 

20 In subsequent communication, the Danish authorities have confirmed they include in the chemical status assessment: 
(1) Anthracene, (2) atrazine, (3) benz(a)pyrene, (4) cadmium, (5) chloroform, (6) chlorpyrifos, (7) Di(2-ethylhexyl)phthalate 
(DEHP), (8) dioxins and furans, (9) diuron, (10)  fluoranthene, (11)  HBCDD, (12)  hexachlorbenzene,  (13)  isproturon, (14)  
lead, (14)  mercury, (16)  naphthalene, (17)  nickel, (18)  nonylphenol, (19)  octylphenol, (20)  PBDE, (21)  perfluorooctane 
sulphonic acid (PFOS),  (22)  simazine, and (23) terbutryn, while assessing (24) DDT and (25) cypermethrin (25) at the hand 
of alternative matrices.    
21  Mercury  would  lead  to  this  failure  with  or  without  other  priority  substances  crossing  the  threshold  (“one-out-all-out 
principle”) 

27 

 
 
 
 
4.2 Groundwater Bodies: what is their chemical status 

Monitoring 

The regulation of the chemical state of Denmark’s groundwater appears to have improved overall, 
both  as  regards  the  degree  of  monitoring  and  the  extent  of  groundwater  bodies  in  good  status. 
However, a solid comparison with the situation in the 2nd RBMPs is marred by the five-fold increase 
in the number of groundwater bodies (see section 2.2) as well as by late or unclear and incomplete 
reporting on key aspects in the set of the 3rd RBMPs. 

The overall assessment of chemical status is based on a more solid and larger data set than before, 
incorporating  data  from  pesticide  monitoring  and  water  utility  controls,  and  thus  including  more 
substances and tests. The assessment includes nitrates, chloride, trace elements (aluminium, arsenic, 
cadmium, lead, mercury, nickel, and, for the first time, also chromium, copper and zinc), pesticides, 
environmentally hazardous pollutants (the substance groups BTEXN, chlorinated solvents, cyanides, 
PFAS, phenols, MTBE, and water-soluble solvents)22 as well as the drinking water test. The latter is a 
verification  whether  in  a  groundwater  body,  pollution  requires  increased  treatment  of  the  water 
abstracted for drinking water or even that abstraction points for drinking water had to be taken out 
of service.   

The RBMP PDFs do not provide the RBMPs much further detail on the chemical assessments which 
hinders  to  obtain  a  clear  picture  on  drivers  and  trends.  Importantly,  just  as  for  the  other  status 
dimensions, the traditional RBMP reporting does not discuss the confidence of the status assessments 
It  does  not  say  much  either  about  monitoring,  grouping  methodology,  trend  and  trend  reversal 
analysis, despite an explicit Commission recommendation on this point in the 2nd RBMPs23. E-reporting 
of figures on these elements (submitted well after the 3rd RBMPs’ publication) cannot replace such a 
discussion. 

State Assessment  

The 3rd RBMPs suggest the chemical state of Danish groundwaters has overall improved, but a solid 
comparison with the situation in the 2nd RBMP is marred by the five-fold increase in the number of 
groundwater  bodies  (due  to  the  overhaul  of  groundwater  body  delineation)  as  well  as  by  late  or 
unclear and incomplete reporting on key aspects. 

As depicted in Figure 8, the national RBMP document reports 1820 out of the 2050 groundwater 
bodies (88.8%) are reported to be in good chemical status in 2021, whereas 192 (9.4%) are below 
good status and for 38 (1.9%) the chemical status is unknown. As mentioned in the 2nd RBMPs24, 44.3 
% (178 out of 402) of groundwater bodies (as delineated then) were in good status in 2015, 25.1% 
were failing and 30.6% in unknown status. Even while the overhaul in groundwater body delineation 

22 This list of substances fully covers the ‘minimum list of pollutants’ from the Groundwater Directive 2006/118/EC, Annex 
2, part B, apart from ‘saline intrusion’ which has been discussed in section 3.4 above in the context of protected drinking 
water areas.  
23 SWD(2019) 38, pp 19-20  
24 SWD(2019) 38 – p 93 

28 

 
 
stands of a direct comparison of these percentages, these changes indicate an overall improvement, 
both as regards the degree of monitoring and the quality of groundwater.25 

Figure 8: Chemical status of groundwater bodies 

Pesticides are the group of substances most responsible for the failure to attain good status: almost 
two thirds of groundwater bodies in less than good status have too high pesticide concentrations26. 
It  is  worth  noting  that  a  majority  of  them  concern  already  banned  and  phased-out  pesticides, 
demonstrating the long-time lag between emission and pollution concentrations.  

In  contrast,  the  corresponding  percentages  for  nitrates,  the  group  of  trace  elements  and  all 
environmentally hazardous pollutants combined are only around ten percent. This highlights that the 
drinking water test has a significant upward effect on the percentage of groundwater bodies in less 
than  good  status:  pushing  it  up  from  7.5  to  9.4%.  This  underlines  the  importance  attached  to 
protecting groundwater bodies which are in Denmark the nearly exclusive source of drinking water. 

Regrettably, the 3rd RBMPs do not inform about the expected date for achieving good chemical status 
for all ground water bodies, but the later submitted e-reporting indicates that 86 groundwater bodies 
(4.2% of the total) are at risk of failing good chemical status by 2027. Neither do the RBMPs provide 
much  detail  on  the  chemical  assessments  which  hinders  to  obtain  a  clear  picture  on  drivers  and 

26 This proportion as well as the one in the next paragraph are derived from Table 1.4 in the national 3rd RBMP for Denmark.  
To note, to a large extent, this pesticide pollution concerns a legacy issue:  the national RBMP notes that the majority of 
pesticides found in groundwater bodies, have been banned and phased out already. 

29 

 
 
 
 
 
trends.  They  do  not  say  much  either  about  monitoring,  grouping  methodology,  trend  and  trend 
reversal analysis, despite an explicit Commission recommendation on this point in the 2nd RBMPs27.   

30 

 
 
 
 
 
 
4.3 What Denmark is doing to combat pollution from agriculture 

Agriculture is by far the largest contributor to the discharge of nitrates and phosphorus into surface 
waters (coastal waters and lakes respectively) and the key source of pesticides pollution.  

Measures on nitrates emissions (mainly, but not exclusively from agriculture) have so far not been 
sufficient to achieve the reductions necessary to achieve good ecological status. Up to now, Denmark 
has enjoyed extensions on its derogation under the Nitrates Directive, which have allowed to spread 
abatement measures over time. At the time of the submission of the 3rd RBMPs, Denmark had opted 
to prolong this derogation which would otherwise expire at the end of July 2024. However, in Spring 
2024, well after the submission of the RBMPs, Denmark has decided to relinquish this derogation.  

Yet,  it  has  become  clear  that  further  substantial  reductions  are  required  to  stop  the  built-up 
accumulation of nitrates in coastal waters and then have natural forces reduce it over time. Now that 
the possibilities for incremental measures appear to have largely been exhausted, more ambitious 
measures are needed.  The recognition that inter alia the required sustained nitrates reduction efforts 
in this sector can only be successfully pursued with wide political support, has led to a “broad political 
agreement  on  the  green  transition  of  Danish  agriculture,”  concluded  between  all  major  Danish 
political parties in October 2021.28 The 3rd RBMPs have taken this 2021 agreement into account, and 
the upcoming revised 3rd RBMPs are expected to take on board the measures reflecting the so-called 
“tripartite”  agreement  “on  a  Green  Denmark,”  concluded  in  June  2024  between  agricultural 
associations, nature protection NGOs and municipalities29. Reportedly, the agreement includes a focus 
on nutrient emission reduction through a conversion of farmland into nature area. 

It is welcomed that the RBMPs indicate the ‘distance to target’ for nitrogen reduction, the estimated 
or envisaged effects of the various types of measures, indicating, importantly, two remaining gaps, 
namely  one  between  the  foreseen  and  required  reductions  and  one  indicating  the  size  of  the 
reductions attributed to hitherto unspecified measures. Figure 9 presents this information in a stack 
diagram. 

The diagram first shows the shortfall of the 2021 political agreement on nitrate reduction and thus 
also the RBMP’s program of measures: by 2027 an annual reduction in nitrogen (mostly nitrates) of 
about 13 thousand tonne is required to meet the objective of good ecological status in Danish coastal 
water, but the political agreement concerns a commitment to reduce 10.8 thousand tonne only30.  It 
should  be  noted  that  these  reduction  figures  are  inherently  uncertain  also  because  they  are 
contingent  on  nitrates  reduction  assumed  to  be  realized  already  within  the  baseline,  reflecting 
estimations on respectively autonomous trends in agricultural production as well as the impact of 
pre-existing policy measures. 

28 See Denmark’s “National Reform Program 2022” (Danish Ministry of Finance, April 2022) and the “Second opinion on the 
need for reduction of nitrogen in the third RBMP for 2021- 2027, Phase I” (COWI for Danish Ministry for the Environment). 
The former source focuses much more on the agreement’s carbon reduction dimension in view of the envisaged financial 
support from the EU Recovery and Resilience Facility, requiring regular reporting.  
29 “Agreement on a Green Denmark” (in Danish), June 2024.  
30 Two remarks are in order. First, this apparent lack of effort may not qualify as lack of technical feasibility, as ground for 
an exemption under WFD article 4(4), which the RBMP only calls on for a minority of coastal water bodies expected to fail 
good ecological status in the year 2027; see further section 2.1.8. Second, a modest  0.4 out of the 10.8 Ktonne concerns 
the reductions achieved by the measures but occurring outside of catchment areas and thus with an ecological effect on 
Danish waters. 

31 

 
 
Apart from a small reduction related to wastewater plants, these reductions are supposed to take 
place in the agriculture sector. The Danish CAP Strategic Plan for 2023-2027 has set out much of 
the  foreseen  measures  in  the  3rd  programming  period.  They  allocate  20%  of  direct  payments  to 
voluntary measures by farmers beneficial for the climate, environment and animal welfare. 19% of 
the rural development funds is reserved for farmers taking multi-annual management commitments 
benefitting nature and biodiversity, e.g. to double the area for organic farming by 2030 (13% of UAA 
in 2022)31 and by afforestation.32 

However,  the  diagram  reports  a  further  second  gap  that  also  need  to  be  addressed  with  further 
measures in the upcoming revised 3rd RBMPs. While the policy has set fixed reduction tasks of 6.5 
and  1.5  thousand  tonne,  respectively  from33  “targeted  regulation”  and  “collective  measures,”  the 
additional 2.8 tonne reduction needs to come from “new implementation measures,” that have not 
yet been defined. The 2021 political agreement foresees decisions on these measures in the course 
of the year 2024, based on a “second opinion” by experts that has now arrived34.  

Danish authorities have already  indicated to come with revised  3rd RBMPs that hopefully  address 
these two gaps in a satisfactory manner. 

Figure 9:  The stack of nitrate reductions of various measure types vis-à-vis the 2027 reduction objective 

31 File:Organic-area-2022.jpg - Statistics Explained (europa.eu) 
32 At a glance: Denmark’s CAP Strategic Plan (europa.eu) 
33 The “targeted regulation” includes measures on cover crops, energy crops, fallow areas, precision agriculture and catch 
crops. The “collective measures” concern “voluntary” measures on wetland restoration, set-aside of low lying soils, et cetera, 
with a so-called “environmental guarantee” that in case the resulting impact are below expectation, mandatory buy-outs 
with financial compensation will be pursued in order to meet. 
34 See footnote 28 

32 

 
 
 
Source: mimeo Danish government 

In  relation  to  phosphorus  pollution  from  diffuse  agricultural  sources,  the  RBMPs  include  the 
establishment  of  wetlands  capturing  phosphorus,  the  location  of  which  is  informed  by  risk-maps 
developed in the previous programming period.  

In line with the pesticide strategy 2022-2026, a range of specific measures aims to reduce pesticide 
emissions into water, such as a pesticide-fee,35 a pesticide authorisation scheme related to inter alia 
a broad screening for pesticides in the groundwater, and the assignment of water protection areas 
around all drinking water supply stations. 

4.4 What Denmark is doing to combat pollution from other sectors 

In  general,  the  RBMPs  do  not  provide  detailed  assessments  on  the  gaps  in  implementation  of 
measures for the pollution coming from other sources than agriculture. In addition, the corresponding 
policy responses tend to be presented through mere references to basic measures. 

However, the reduction of nutrient point source pollution with nutrients has been included in an overall 
gap assessment of the required nitrogen (and phosphorous) load reductions. There is no reference to 
the  deposition  into  water  of  NOx  and  ammonia  emissions  into  the  air,  apart  from  a  mention  of 
measures to reduce emissions from ships.  

As regards the discharge of wastewater from treatment plants, measures to reduce the pollution 
from these sources build on the efforts in previous programming cycles. Denmark has a nation-wide 
authorisation and permitting regime in place to control wastewater point source discharges. There 
are no thresholds in Denmark below which wastewater discharges do not require registration and 
permits, while direct discharges to groundwater are prohibited in all RBDs.  

For pond farming and aquaculture, the number of facilities and general pollutants are indicated per 
water district, however, without indicating the quantity of pollution associated with them. As measure, 
the RBMPs mention a buy-out scheme (to be bought and closed down) for aquaculture firms in inland 
waters. 

While an Annex to the RBMPs lists the measures per priority substances or substance (groups), they 
are not linked to KTMs, as requested in a Commission recommendation on the 2nd RMBP. In addition, 
the main drivers of chemical pollution as well as mitigating measures are explained, but often without 
sufficiently  concrete  indications  on  the  expected  effectiveness  of  the  measures,  rendering  it 
impossible to assess the expected reduction of the chemical pollution concentration. To some extent, 
this  seems  a  reporting  issue  as  much  of  this  information  may  be  retrieved  from  the  e-reporting 
(which became available well after the RBMP transmission). The same seems to be the case for the 
information gaps on the type and quantity of pollutants of industrial discharges at local level, and 
how they are measured and monitored.  

35 In order to incentivise a change to less harmful pesticides, the fee is differentiated at the hand of the active ingredients’ 
toxic potential to harm human health and nature. 

33 

 
 
 
The RBMPs stresses continuation with the measures in the previous programming period, which has 
comprised efforts to extend monitoring, a review in 2020 of the existing permits and licenses for 
priority substances36 where their pollution concentrations exceed the thresholds in water bodies, as 
well as a wide array of actions under national and EU chemical and sectoral legislation.37  

The description of the new measures appears to focus on the first half of the programming period: 
setting new and revising existing Environmental Quality Standards (EQS) and addressing the large 
data  knowledge  gaps  concerning  the  provenance  of  the  pollution  and  the  chemical  status  of 
waterbodies. Reportedly by 2024, this should lead to a comprehensive inventory of pollution sources, 
and, where EQS exceedances are found, to revision of permits, as long as provided for by standing 
legislation.  The  overall  ambition  level  and  concrete  abatement  actions  in  the  second  half  of  the 
programming  period  appear  to  have  been  left  open,  as  the  RBMP  refers  to  a  “partnership  for 
substances dangerous for the environment” between authorities and stakeholders to contribute to 
the development of “an instrument catalogue.” 

4.5 What  Denmark  is  doing  to  combat  significant  pressures  –  overall 

assessment of the Programmes of Measures 

As Denmark’s RBMPs are structured by types of water bodies (coastal, rivers, lakes and groundwater), 
rather  than  according  to  KTMs,  they  do  not  provide  a  clear  comprehensive  overview  of  the 
prioritisation of measures, including their timing, and of the mandatory gap analysis, including gap 
indicators. The later e-reporting of the relevant descriptive data and figures (submitted well after the 
RBMP publication) cannot replace such a discussion in the RBMP.  

However, the RBMPs seems to provide a clear account of the intervention logic for key challenges, 
also indicating where measures will not fully close the gap: 

•  Nitrogen load in coastal  waters: the RBMPs describe the measures to reduce the nitrogen 
loads that have led to widespread eutrophication and oxygen depletion in coastal waters. 
There is an assessment of the annual loads, an estimation of the maximum load compatible 
with good ecological status and of the resulting need for reduction of the loads. The RBMPs 
describe a baseline assuming that 75 % of the estimated load reductions planned in the 2nd 
RBMP period are expected to be implemented. The planned measures on top of the baseline 
cover  around  80%  of  the  estimated  of  nitrogen  reduction  need.  The  RBMP  refers  to  the 
political commitment to define the additional measures to meet the 2027 nitrogen reduction 
target (while good status in coastal waters remains out of reach at that time horizon). See 
further section 2.1.11 above.   

•  Wastewater discharge to rivers and lakes: the RBMPs describe the measures implemented to 
improve the wastewater treatment and reduce polluting discharges into water courses and 
lakes, and explicitly consider their effect on top of the measures from the 2nd RBMPs that 

36 According to section 1.2.2 of the national RBMP document, the environmental authorities have carried out this review 
between  April  and  September  2020  with  the  aim  of  pursuing  any  necessary  revisions.  The  scope  and  outcome  of  this 
exercise are not specified.  
37 Annex 5 to the national RBMP document provides a list of actions which unfortunately lacks specific indications as to 
whether they concern 2nd or 3rd RBMP measures, and neither of their date of implementation, stringency, individual and 
overall impact.  
Section 7.1.1 outlines the new measures. 

34 

 
 
have  not  yet  been  fully  implemented.  The  nitrogen  and  phosphorous  reductions  are 
considered in the light of the required overall reductions. 

•  Water  course  restoration  measures:  the  3rd  RBMPs  identifies  the  need  to  address  the 
situation in 5,500 km of rivers as contribution to the goal / expectation that all rivers will 
attain  good  ecological  status  by  2027.  However,  they  present  measures  to  address  the 
situation in 3,850 km of rivers. The Danish authorities indicate that the remaining gap will 
be handled by a planned update of the RBMP in 2024, although they may also reassess the 
size of the gap. 

•  Environmentally hazardous chemicals: While there appear data on discharges, the RBMP does 
not  appear  to  base  the  measures  on  a  specific  gap  assessment  in  relation  to  priority 
substances, river-basin-specific pollutants and pesticides, based on reaching good chemical 
status by 2027. The widespread lack of chemical status classification appears to constitute 
a major barrier for such an assessment. Annex 5 to the national RBMP PDF lists the measures 
from the previous and current programming period (mostly the first half),  and the RBMPs 
propose  to  further  extend  the  knowledge  and  monitoring  on  the  pollution  sources.  This 
suggests possibly significant gaps in ambition and implementation vis-à-vis the pressures 
and impacts, in particular in lakes and coastal waters. 

•  Groundwater: Recognising that groundwater pollution poses a long-term challenge (due to 
slow natural regeneration), the RBMP refers mostly to existing strategies and regulations as 
providing the basis for ultimately achieving good status for groundwater  bodies, including 
the 2022-2026 Pesticide Strategy as well as basic and supplementary agricultural measures 

The RBMPs also list a number of pressures without accompanying information about any specific 
measures to address them. Examples include harbours and associated dredging, and the dumping of 
dredging material. 

5. Exemptions and economics 

5.1 To what extent are exemptions applied in Denmark 

Denmark makes a very considerable use of exemptions. The 3rd RBMPs report that only 1816 water 
bodies out of the total of 9848 (excluding territorial waters) have already attained good status in 
2021 (amounting to almost one fifth)38. Most of them are groundwater bodies (1801), nearly 90% of 
the total number of groundwaters39. In view of the WFD’s general obligation of “no deterioration,” 
these water bodies do no longer need an exemption, as long as there are no temporary deteriorations 
due to natural causes or force majeure, or due to structural changes affecting the water body. The 
3rd RBMPs imply that this is indeed so, because they do not report any corresponding exemptions, 
respectively on basis of WFD article 4(6) and 4(7). For the other water bodies, the 3rd RBMPs present 
8745 targets and deadlines. 

38 National RBMP PDF, Table 6.1.  
39 It has not been possible to verify in the EEA dashboards the provided figures on water bodies without an exemption as 
well as those with an exemption or rather the number of exemptions. 
The cited figure implies that there are very few surface water bodies for which both good ecological and good chemical 
status has been ascertained. A major reason for this is the high percentage of water bodies with unknown chemical status. 

35 

 
 
The RBMPs report that almost all river water bodies have an exemption of the time extension type 
(WDF article 4(4)) on the grounds that it is technically only feasible to reach good status (or potential 
where applicable in this paragraph or the next ones) by the year 2027, the end of the 3rd programming 
cycle, and not earlier. As there are 6700 of such exemptions reported for a total of 6703 rivers, one 
may infer that many river water bodies have such an exemption (even taking account of multiple 
chemical exemption per individual river water body). In the light of the very large share of rivers with 
unknown  chemical  status  in  2021,  it  is  not  entirely  clear  on  what  data  and  assessment  the 
expectation is based that good status will be reached by 2027.  

As regards lakes, there are 950 article 4(4) exemptions reported40, with less than half (423) on the 
grounds of technical infeasibility and / or disproportionate costs, with the status condition expected 
to become good by the year 2027. The remainder (527) gets such an exemption on the grounds of 
natural conditions, as the measures in place are expected to deliver good status only after 2027. The 
main pressure comes from the emissions of nutrients (nitrogen and phosphorous) and in some cases 
pesticides and hazardous substances from agricultural run-offs, as well as point source pollution of 
residential and industrial wastewater discharges and overflows.  

Similar to rivers, article 4(4) exemptions are applied for nearly all coastal waters41, as only 3 out of 
the 109 coastal water bodies have been found in good status in 2021. In line with the widespread 
nutrient and oxygen depletion problems as discussed in section 3.1 above, the RBMPs invoke a total 
of 120 article 4(4) exemptions, 12 of which on the ground of technical feasibility and disproportionate 
costs (which is expected to be no longer necessary by the year 2027), and the remaining 108 on the 
grounds of natural conditions (as good status can be attained only well after 2027). Remarkably, only 
14 deadline extensions are reported for chemical status, while 101 coastal water bodies are reported 
to be in poor status.  

Article 4(4) exemptions are called upon for 223 groundwater bodies42 out of a total of 2050 (thus 
for about 10%). For all but one, this is justified for reason of natural conditions. This is understandable 
in view of the long-time lags between nutrient and pesticides emission at the source and their filtering 
into groundwater bodies, which for the deeper ones can amount to multiple decades, implying an 
impact of emissions dating back from even before the entry into force of the European Nitrates and 
Pesticides Directives43. 

Article  4(5)  exemptions,  i.e.  lowering  the  environmental  ambitions  for  the  time  being,  have  been 
applied in a much lower degree. It concerns 31 lakes (amounting to only 0.4 % of the total number 
of surface water bodies) which have been constructed as the most cost-effective solution to capture 
excess nutrients,44 as well as, at most45, 26 groundwater bodies (1.3 % of their total number) where 
either  contaminated  land  renders  it  technically  impossible  to  remove  the  pollution  inflow  into 
groundwater by 2027 or where natural recharge needs more time to reduce too high concentrations 
of trace element caused by over-abstraction.  

40 The Danish authorities have provided the disaggregation of the figure reported in Table 6.7 of the national RBMP PDF.  
41 All figures are from Table 6.9 of the national RBMP PDF. 
42 All figures are from Table 6.11 of the national RBMP PDF. 
43 Directive 91/676/EEC and Directive 2009/128/EC 
44 National RBMP PDF, section 5.3. It is not clear how this related to the definition of “ecological potential” for these water 
bodies, which is already lower than ecological status.  
45 ‘At most’ because there can be more than one exemption concerning chemical status. 

36 

 
 
Apart from the specifications in the previous paragraphs, the RBMPs do not provide a split between 
exemptions regarding chemical status (for either groundwater or surface water), ecological status or 
quantitative status.  

It is a source of strong concern that the RBMPs do not provide a specific justification for the invoked 
exemption  grounds  for  individual  water bodies.  The Danish  authorities  have  pointed  out  that  this 
information can be made available by the Danish Environmental Protection Agency, but the reporting 
issue remains as the RBMPs do not provide a clear, accessible reference to it as required by the law.  
In line with ECJ jurisprudence on the restrictive interpretation of exemptions, the RBMPs should not 
give the impression that across-the-board exemptions have been applied for water body categories 
in their (near) entirety (in this case rivers and coastal waters). 

The national RBMP PDF appears to suggest46 that further minor modifications of “individual lake or 
wetlands  rivers,  including  adjacent  rivers”  may  cause  a  temporary  deterioration  requiring  an 
exemption according to WFD article 4(7). However, it does not provide specific details on the number 
of  these  exemptions  and  their  reasons  but  provides  a  general  reference  to  the  Environmental 
Protection  Agency.  Hence,  it  remains  unclear  how  much  these  exemptions  have  been  applied, 
including whether article 4(7) exemptions still apply for ongoing large infrastructure projects. 

5.2 Use of economic analysis and water pricing – cost recovery 

The economic analysis is provided in a background document to the RBMP(s). It provides a detailed 
description of the financial costs of the broad water services (drinking) water supply and sanitation 
service and the cost recovery arrangements. Whether publicly owned or privately owned, each water 
utility or company is required to set its charges so as to fully recover its costs at municipal level. This 
implies  that  the  water  service  charges  vary  both  within  and  across  RBDs,  and  that  the  Danish 
authorities  do  not  lower  cost  recovery  for  economic  and  social  reasons.  These  cost  recovery 
arrangements  imply  that  the  RBMPs  need  not  report  on  the  factors  mitigating  the  cost  recovery 
efforts and can relegate details on costs to a background document. 

The (updated) economic analysis seems to have two weaker aspects: the long-term outlook of the 
analysis, specifically on water consumption, and the cost-effectiveness assessment.  

There is a rough long term forecast on the demand for drinking water until 2035, basically noting 
that population growth would increase demand counteracting the ongoing trend of decreasing water 
consumption per capita, but without a clear conclusion on the net outcome. In addition, there is no 
long-term scenario on total water consumption in the absence of forecasts on water abstraction by 
industry and agriculture. It appears that the strong decentralisation in decisions on water services 
provision would explain the absence in the RBMPs of fully developed water demand and supply long 
term scenarios as well as a comprehensive forecast of investments. Hence, the emergence of future 
potential bottlenecks does not seem to have been systematically explored. It also renders the RBMP’s 
indication that water scarcity is not an issue for Denmark, a rather short-term notion, not sufficiently 
explored for the longer term and the related emerging impacts of climate change in the water sector 
and corresponding required investments.  

46 National RBMP PDF, section 6.2 “Specific environmental objectives for rivers.”  

37 

 
 
The second major flaw in the economic analysis concerns the unclear reporting on the outcomes of 
the  cost-effectiveness  assessment.  While  the  RBMPs  declare  cost-effectiveness  as  the  guiding 
principle for the selection of measures, they do not report on the conclusions of the cost-effectiveness 
assessment of either individual measures or the overall set of measures. The background documents 
referred to do not clearly identify which measures in the catalogue have been introduced for the first 
time, which ones are selected and which ones concern (selected) investments. 

The RBMPs do not provide a complete account of water pricing and whether they provide “adequate 
incentive”  to  efficient  water  use,  but  the  available  information  suggests  that  the  pricing  policy 
provides  some  clear  incentives.  It  concerns  full  cost  recovery  at  municipal  level  resulting  prices 
varying with local cost conditions as well as the large variable element in all water charges. However, 
there  is  no  information  as  to  whether  prices  vary  by  broad  user  sectors  (households,  industry, 
agriculture), neither whether unit rates increase with individual water consumption volume, whether 
there is a social tariff, and whether the “additional taxes” are included in or put on top of cost recovery.  

There  is  no  discussion  on  whether  the  (broad)  water  user  sectors  (households,  industry  and 
agriculture) provide an adequate contribution to the (full) cost recovery. This is related to the lack of 
information  on  possible  sectorial  variation  in  water  charges.  For  example,  it  is  not  clear  why 
agriculture47  is  exempt  from  the  water  abstraction  tax.  A  positive  element,  worth  highlighting 
however, is the “tax” on water utilities varying on the degree on leakages in water distribution network. 

On a related point, the RBMPs reveal a mixed track record on the application of the polluter pays 
principle. On the one hand, the reports suggest it is applied because the revenues from (gross) water 
prices exceed the financial costs basically because of the water abstraction tax, the leakage tax and 
the  tax  on  organic  matter  and  nutrients  from  treated  wastewater.  As  the  destination  of  these 
revenues is not specified, it remains unclear however whether the polluters pay for the broader costs 
of water services or rather for a part of the Program of Measures or both. On the other hand, the 
green basis of these taxes is rather weak because they are explicitly not based on an estimate of the 
environmental and resource costs. The RBMP justifies this some arguments, namely a presumed lack 
of agreement on the estimation method; that the environmental costs are equal to the costs of the 
abatement measures (leaving the remainder pollution out of the picture), and that there is no water 
scarcity and hence no resource costs (not discussing seasonal water stress).  

6. WFD recommendations 

On the basis of the assessment performed, Denmark should: 

1.  Denmark is invited to come as soon as possible with the set of revised 3rd RBMPs as announced in the 

submitted RBMPs, taking on board already, to the extent possible, the recommendations below.  

2.  Address the identified lack of compliance of achieving good status by increasing the level of ambition and 
reducing the knowledge and compliance gap as much and as soon as possible until the next reporting 
cycle. 

47 The RBMPs point out that agriculture covers all the irrigation costs (fed by abstraction from groundwater) 

38 

 
 
This means in particular, that: 

Denmark is invited to adopt and submit as soon as possible the set of revised 3rd RBMPs as announced in 
the current RBMPs, taking on board already, to the extent possible, the recommendations included in this 
assessment.  

Where the objectives of the Directive for a specific water body cannot be met and exemptions are invoked, 
Denmark should do so in line with ECJ jurisprudence on the restrictive interpretation of exemptions and 
better justify the use of exemptions, providing sufficiently detailed justifications at the level of the water 
body  and  ensure  that  their  application  is  regularly  reviewed.  Importantly,  they  should  explain  how  an 
exemption is justified in the case that the status of the water body is not known. This implies: 

a)  Providing clear, accessible references to the justification for the invoked exemption grounds (for both 
time extensions and lowered objectives, according to respectively WFD article 4(4) and 4(5)) as well as 
a  clear  split  on  the  exemptions  invoked  for  attaining,  on  the  one  hand,  good  ecological  status  (or 
potential) or quantitative status, and, on the other hand, good chemical status.  

b)  Ensuring that the lowering of objectives (Article 4(5) is well documented and justified, in particular as 
regards  disproportionate  cost  and  unfeasibility  taking  into  account  the  shortcomings  in  the 
implementation to date. 

c)  Recognising that the possibilities for time extensions (Article 4 (4)) are extremely limited and will no 

longer be allowed after 2027 (except if duly justified for natural conditions). 

d)  Much more information on the exemptions under Article 4(7) WFD for new projects, including new dams 
and  water  transfers.  This includes better  justifications  of  the  use  of these exemptions  by detailing 
cumulative  effects,  the  assessment  of  better  environmental  options,  and  the  measures  taken  to 
mitigate the adverse impacts of new developments. 

3.  Continue strengthening the economic dimension of the RBMPs: 

a) 

improve  the  content  of  or  reporting  on  the  economic  analysis  as  regards  its  long-term  outlook, 
specifically on water consumption and investments, linking this outlook specifically and extensively 
with their recent national Climate Adaptation Strategy;  

b)  Make  more  and  more  clearly  use  of  the  cost-effectiveness  assessments  in  the  selection  and 

prioritisation of measures, including investments; 

c)  Present in the revised RBMP a long-term planning / forecast of the investments, clearly identifying the 
timeline, as well as the funding; more generally, identify the source of financing for implementation of 
all measures; 

d)  Strengthen  the  application  of  the  ‘polluter-pays  principle’  and  eliminate  environmental  harmful 
subsidies whilst ensuring affordable, just and fair pricing mechanisms for all water users in line with 
Article 9 WFD;  

4. 

Identify  and  put  in  place  supplementary  and  other  additional  measures  to  reduce  existing  persistent 
environmental challenges (pressures) preventing the achievement of good status, and based on robust gap 
analysis, as those pressures are aggravated by climate change (pollution concentrates in times of less 
water availability). 

This implies, inter alia: 

a)  Address the explicit shortfall of nitrate reduction measures in the current Program of Measures, based 
on the measures currently under consideration as follow-up to Denmark’s decision to relinquish their 
derogation under the Nitrates Directive as well as in the framework of the broad agreement on the 

39 

 
green  transition  in  Danish  agriculture  of  October  2021  and  the  “tripartite  agreement  on  a  Green 
Denmark” of June 2024; 

b)  Addressing key emerging water pollution issues, such as the observed marked increase of water bodies 
failing good status because of exceeding pollution concentration for priority substances: mercury or 
other metals, as well as anthracene, nonylphenol, PFOS and naphthalene. Measures should include 
adequate permit conditions for industrial installations and addressing the pollution coming from the 
sewage sludge, storm overflows and wastewater from unconnected houses;  

c)  Addressing diffuse chemical pollution, e.g. including nutrient and pesticide pollution i including through 

reducing their use and phasing out unsustainable practices; 

d)  Take  immediate  action  for  pollution  problems  discovered  in  water  bodies  which  are  currently  in 
unknown  chemical  status,  and  for  priority  substances  that  have  not  yet  been  included  in  the 
assessment; 

e)  Expanding  the  efforts  on  the  deployment  of  nature-based  solutions  including  renaturalisation  and 
ecosystem restoration, including the upgrading and expansion of wetland areas as well as measures 
that  bridge  the  gap  between  the  river  restoration  targets  and  the  expected  results  of  the  current 
measures. 

5.  As regards climate change start developing a policy response to emerging seasonal droughts and water 
scarcity, taking a long-term perspective, and with an explicit Drought Management Plan which includes the 
identification  of  surface  water  bodies  as  candidate  water  abstraction  source  as  well  as  adaptation 
measures in all major water user sectors and further nature-based solutions. 

6.  Step up the efforts to meet the requirements set out in the WFD as regards monitoring, assessment, data 

management and reporting. In particular, Denmark should:  

a) 

b) 

identify the main causes of the widespread lack of chemical status classification for surface waters 
and  take  the  appropriate  measures  to  address  this  lack  as  much  as  possible  within  the  current 
programming cycle;  

include all priority substances in the assessment of chemical status (or explain why the substances left 
out would not have a material impact on the quality of Danish surface waters); 

c)  For the water bodies without a known status, explain the robustness of the reported expected date of 
achieving good status, and also why the 31 lakes built for nutrient removal are not included in the 
reported number of artificial and heavily modified water bodies.  

7. 

In cooperation with the Commission and the EEA, ensure timely submission of the RBMPs in line with the 
WFD requirements and fully covering all topics. To meet the reporting requirements in a more transparent 
manner, the RBMPs should refer more clearly to background documents, to publicly available data, and to 
the  electronic  reporting,  coupled  with  explanations  in  the  RBMPs  on  the  regulatory  aspects  and 
assessments. For future cycles, Denmark should ensure that they make the electronic reporting available 
about  the  same  time  as  the RBMPs  and  that they  are  fully  consistent  with  the submitted  RBMPs  and 
provide a more extensive coverage of the important technical details. 

40 

 
 
SECTION B: 
FLOODS DIRECTIVE 

41 

 
 
 
7. Flood risk management under floods directive (FD) 

The Directive requires each Member State (MS) to scan its territory for flood risks, assess the potential 
adverse  consequences  of  future  floods  for  human  health,  the  environment,  cultural  heritage  and 
economic  activity,  identify  the  significant  risks,  map  the  flood  extent  and  the  potential  adverse 
consequences, and take measures to reduce the flood risk. These activities are reflected in (a) the 
preliminary  flood  risk  assessments,  or  PFRAs  (including  the  identification  of  areas  of  potential 
significant flood risk, or APSFRs), (b) the preparation of flood hazard and risk maps, or FHRMs, and (c) 
the establishment of flood risk management plans, or FRMPs. The preliminary assessments, mapping 
and planning for flood risk are repeated in six-yearly cycles. 

There are four Units of Management (UoMs) in Denmark, which are the same as the Water Framework 
Directive’s  River  Basin  Districts  (RBD).  Fluvial  and  sea  water  floods  are  considered  as  potentially 
significant sources of flooding in Denmark. Denmark has designated in two of its UoMs (for which 
UoM level FRMPs were prepared) 14 Areas of Potential Significant Flood Risk (APSFRs)48.  

7.1 Flood hazard and risk maps 

Denmark is using a national web-GIS viewer49 for their FHRMs. FHRMs were prepared at the national 
level and show the whole country. Maps for floods with low probability (1/100 years for fluvial and 
1/1 000  years  for  coastal),  with  medium  probability  (1/50  years  for  fluvial  and  1/100  years  for 
coastal) and with high probability (1/20 years) are provided. Flood extent is shown on all maps. Water 
depth is shown on all maps. Number of inhabitants is shown on all maps. Likewise, type of economic 
activity is shown on all maps. There are neither maps with IED installations available on the national 
web-GIS portal nor is this mentioned in the methodology report. However, the information has been 
reported to EIONET50. Potentially affected protected areas identified in Annex IV(1)(i), (iii) and (v) to 
Directive 2000/60/EC are shown in the FHRMs. 

In terms of changes of contextual information (i.e. the way in which information about the maps is 
conveyed to the public) since the first FHRMs, the following improvements were made: 1) address 
level information of critical infrastructure and potentially polluting installations are included instead 
of only grid-based information as was the case before, 2) the descriptions and order of data layers 
on the web-GIS portal is more concise, i.e. information is easier to find, and 3) additional APSFRs and 
expanded APSFR areas were included.  

In terms of changes in methodologies used to prepare flood hazard maps since the first FHRMs, the 
main  differences  are:  1)  for  fluvial  floods,  since  the  first  FHRMs,  the  scenario’s  probabilities  were 
changed from 1 000 years (low probability) and 100 years (medium probability) to 100 years for low 
probability and 50 years for (medium probability). No explanation for this change was found in the 
assessed documents (the FD mentions a 100-year return period as the medium scenario), and 2) 
data  series  used  as  input  were  updated  to  also  include  recent  years  since  the  first  FHRMs  were 

48 The main observed changes are that additional APSFRs were identified and included and for two exiting APSFR the area 
was expanded. This led to additional and expanded FHRMs in the GIS web-viewer. For all FHRMs the same approach was 
used to generate the maps, so for all APSFRs, FHRMs of the same quality and detail exist. 
49  https://kms.maps.arcgis.com/apps/webappviewer/index.html?id=63f098e64248465abbd7a3283e5e2707 
2023.08.18) 
50  Denmark  clarified  that  IED  and  IPPC  installations  are  shown  in  the  web-GIS  portal  for  each  APSFR  in  a  layer  called 
“polluting organisation" (DK: Forurenende virksomheder). 

(accessed: 

42 

 
 
developed.  Scenarios  are adapted  accordingly  i.e.,  2019  as  base  year,  2065  and  2115  for  future 
scenarios.  

In terms of changes in methodologies used to prepare flood risk maps since the first FHRMs, the 
methodologies and approaches used were largely the same and are based on an approach developed 
by  a  research  project  in  Germany.  The  approach  was  further  refined  i.e.,  by  considering  losses  to 
airports in the category infrastructure and losses for businesses. The total risk is displayed in the 
second  FHRMs  as  economic  damage  in  Danish  currency  per  grid-cell.  The  input  data  to  calculate 
damage costs per unit damaged or per grid cell was updated so that the damage costs are displayed 
in 2019 values.  

Climate change in the second FHRMs 

As regards the consideration of climate change effects in the preparation of flood hazard and risk 
maps, reference is made to section 3.7 on ‘adaptation to climate change’. 

7.2 Flood risk management plans 

Objectives and measures 

The UoM-level FRMPs (which are summary documents of the municipal FRMPs) can be downloaded 
from a webpage51 of the Ministry of Environment’s web portal for the FD. The UoM-level FRMPs can 
also be found on the front page of the web portal52.  

Objectives are recommended at national level for inclusion in Denmark’s FRMPs, which are prepared 
at municipal level. All three municipal FRMPs assessed incorporate these objectives and set detailed 
sub-objectives.  

Objectives recommended at national level call for the reduction of potential adverse consequences, 
as do more detailed sub-objectives in all three municipal FRMPs assessed. Sub-objectives in all three 
municipal  FRMPs  assessed  include  non-structural  initiatives,  such  as  strengthening  emergency 
responses  for  flood  events.  The  general  objective  recommended  at  national  level  refers  to  the 
reduction of adverse consequences of floods for human health, the environment, cultural heritage 
and economic activities. Each of the three municipal FRMPs assessed includes objectives related to 
the protection of citizens. In terms of the economy, the three municipal FRMPs address this topic 
indirectly, for example by making businesses aware of their flood risk and their options to reduce it. 
Reduction  of  adverse  consequences  for  the  environment  is  incorporated  in  the  general  objective 
recommended  at  national  level  and  is  indirectly  addressed  by  objectives  in  the  FRMPs  (e.g.  the 
Copenhagen  FRMP  has  an  objective  to  address  wastewater  treatment).  While  incorporated  in  the 

51 https://oversvommelse.kyst.dk/planperioder/planperiode-2016-2021/plantrin-3 This website also contains national 
templates and guidance to support municipalities in preparing their FRMPs, notably:  
- Guide for the preparation of FRMPs 
- MS Word template for preparing new FRMPs 
- MS Word template for reassessing and updating FRMPs 
- Action/measures planning table in Excel 
- A risk management plan checklist 
- FAQ on FRMPs 
52 https://oversvommelse.kyst.dk/  

43 

 
 
general objective recommended at national level, the protection of cultural heritage is not included 
in the objectives of the municipal FRMPs assessed.  

Denmark  has  reported  measures  to  EIONET.  Denmark’s  reporting  to  EIONET  includes  prevention, 
protection  and  preparedness  measures,  as  do  the  three  municipal  FRMPs  assessed.  All  three 
municipal FRMPs assessed contain tables listing measures and priorities, and the UoM-level FRMPs 
list the total number of measures across all municipal FRMPs (these totals do not match the numbers 
that Denmark reported to EIONET).  

Denmark  indicates  the  priority  of  all  measures  reported  to  EIONET.  In  its  reporting  to  EIONET, 
Denmark’s measures are divided between all five possible categories of priority: critical priority (36 
measures, 6 % of the total), very high priority (203 measures, 34 %), high priority (142 measures, 
24  %),  moderate  priority  (156  measures,  26  %),  and  low  priority  (55  measures,  9  %).  All  three 
municipal FRMPs assessed contain tables listing their measures and the priority of each on a three-
point scale.  

Denmark’s two UoM-level FRMPs report on the status of completion of measures in the first FRMPs. 
The second FRMPs state that the municipalities will track the progress of their measures; they do not, 
however, identify clear targets or indicators for assessing whether measures have been implemented. 
None  of  the  FRMPs  assessed  (either  at  UoM  or municipal  level)  provide  a baseline  against  which 
progress can be monitored and assessed. 

Denmark reported (to EIONET) the following categories of completion for its measures: Completed 
(170 measures, 29 % of all measures); Ongoing construction (six measures, 1 %); Ongoing recurrent 
(e.g. maintenance works) (15 measures, 3 %); In preparation (304 measures, 51 %); Not started (77 
measures, 13 %); Abandoned/interrupted (20 measures, 3 %).  

The  highest  share  of  completed  measures  is  in  protection  measures,  at  46  measures  completed 
(46 % of protection measures), compared to 24-26 % of the prevention, preparedness and ‘other’ 
measures. For both prevention and preparedness measures, 60 % were reported in preparation, as 
were  51 %  of  ‘other’  measures.  Between  three  and  eight  measures  of  each  measure  type  were 
reported as abandoned/interrupted, with the largest number and share in protection measures (eight 
measures, 8 % of all protection measures). T 

he distribution of progress is similar across the two UoMs. In each, the greatest share of measures 
are in preparation (60 % or 193 measures for Jutland and Funen (DK1); 41 % or 111 measures for 
Seeland (DK2)). The Seeland UoM has a slightly higher share of completed measures (37 %, 100 
measures) compared to Jutland and Funen (22 %, 70 measures).  

As  noted  earlier,  Denmark’s  two  UoM-level  FRMPs  provide  a  different  number  of  measures  than 
reported to EIONET. These plans report on the status of completion of measures in the first FRMPs. 
They indicate that 10 % (13 of 30) of measures in the Jutland and Funen UoM (DK1) and 5 % (6 of 
125) of the measures in the Seeland UoM (DK2) were cancelled. This information cannot be compared 
to Denmark’s reporting to EIONET, which identified only 28 measures for its first FRMPs.  

Denmark  has  not  reported  the  costs  of  its  measures  to  EIONET.  Only  one  of  the  three municipal 
FRMPs (Odense municipality) provides information on costs, and not for all of its measures. The five 
FRMPs assessed do not specify how their measures should be funded. There is an indication in the 
Copenhagen  FRMP  that  at  least  some  measures  are  to  be  financed  by  combined  public-private 
financing. 

44 

 
Neither the municipal FRMPs that were assessed nor the two UoM-level FRMPs report using CBA.  

Both  Denmark’s  reporting  to  EIONET  and  the  FRMPs  reviewed  include  natural  water  retention 
measures  (NWRMs).  FRMPs  assessed  refer  to  the  WFD  objectives,  with  the  Odense  FRMP  noting 
synergies for one measure and the Slagelse FRMP stating that projects will be assessed for potential 
impacts. However, they provide few other details on how WFD objectives are considered.  

Spatial planning and land-use measures are included in the measures Denmark reports to EIONET, 
as well as in the FRMPs assessed.  

Nature conservation (especially at Natura 2000 sites) is considered in developing the FRMPs and in 
specific measures reported to EIONET and listed in the three municipal FRMPs assessed. The second 
FRMPs assessed do not provide detail on progress towards the achievement of the objectives in the 
first FRMPs, though they state that such an assessment should be made (in each municipal FRMP it 
is at least briefly described the status of objectives set in the first FRMP).  

Governance 

Denmark  reported  that  neither  UoM  featured  coordination  at  international  level,  since  Denmark, 
although  sharing  a  border  with  Germany,  no  APSFR  has  been  identified  as  being  shared  with  a 
neighbouring  Member  State.  The  FRMPs  assessed  do  not  have  any information  on  transboundary 
cooperation. 

The two UoM-level FRMPs levels state that ‘all the municipalities have a focus on the fact that risk 
management affects many stakeholders, including citizens, and they all plan for involvement during 
the implementation of the plan. Furthermore, all municipalities have had their risk management plan 
in six months of consultation before it was adopted, where several municipalities held public meetings 
etc. along the way’53. The three municipal FRMPs assessed state that the draft plans were provided 
for consultation for six months. The Copenhagen and Odense FRMPs do not include details on how 
the consultation was carried out. The Slagelse FRMP mentions public meetings and dialogue meetings 
with relevant stakeholders in the consultation period.54 

Consideration of climate change 

As regards the consideration of climate change effects in the preparation of flood risk management 
plans, reference is made to section 3.7 on ‘Adaptation to climate change’ above. 

 Progress identified in the second FRMPs 

The second FRMPs assessed followed a similar structure based on national guidance. While the first 
FRMPs presented FHRMs only for 100-year return floods, the second FRMPs assessed provide more 
maps, including some related to flash floods.  

Nearly  all  of  Denmark’s  second  municipal  FRMPs  explicitly  address  the  reduction  of  adverse 
consequences and more generally the risk of flooding, an issue found in the objectives of only some 
of the first FRMPs assessed.  

53 UoM-level FRMPs, p. 4.  
54 Slagelse FRMP, p. 26. 

45 

 
 
The second FRMPs provide details on the process to monitor measures.  

On coordination with RBMPs, the second FRMPs provide more information. Two of three municipal 
second FRMPs assessed (Copenhagen and Odense) state that the effects of some measures were 
assessed for their WFD objectives, while the third plan assessed (Slagelse) indicates that this will be 
done.  

Also, the second FRMPs assessed provide further information on how nature protection is addressed 
by  measures.  In  addition,  it  appears  from  Denmark’s  reporting  that  there  is  greater  attention  to 
nature-based solutions in the second FRMPs.  

It continues to be unclear in two of the three municipal FRMPs assessed how stakeholder input was 
used  –  the  exception  is  the  Odense  FRMP,  which  describes  how  consultation  responses  were 
addressed.  Some  municipal  FRMPs  include  measures  to  address  floods  in  the  context  of  climate 
change or indicate an intention to integrate flood and climate change plans more closely in the future. 

8. FD recommendations 

On the basis of the assessment performed, and in addition to the progress already achieved, Denmark should:  

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

link the flood risk maps for pluvial and sewerage flooding produced by the municipalities to the national 
web-GIS portal; 

provide detail on how the FHRM was used in the choice of objectives and measures of the FRMP; 

set more specific objectives in the FRMP and where possible linked to quantitative indicators and be 
timebound. An assessment of the progress made towards the achievement of the objectives should 
be included in the FRMP; 

provide information on the costs, budgets and funding sources for measures 

provide more information on the  prioritisation of measures in the FRMP; 

provide information on the role of insurance in flood risk management, since provisions appear to be 
in place; 

depending  on  the  nature  of  the  measures,  the  subject  the  FRMP  to  a  Strategic  Environmental 
Assessment, next to the screenings carried out at the municipal level; 

set out a clear overview of the use of Cost Benefit Analysis and the methodology behind it in the FRMP; 

better coordinate the  discussion on the impact of climate change  between the various FRMPs and 
national/sub-national adaptation plans or strategies; 

include information on transboundary cooperation in the FRMP in view of potentially worse future flood 
risk conditions even if the cooperation is basic for the time being; 

46 

 
• 

provide detail on the public consultation and active stakeholder involvement in the FRMP, in particular, 
the comments received, and how they were taken into account; 

•  where appropriate, consider flow velocity or relevant water flow in the FHRM and flood conveyance 

routes in the FRMP, as these are relevant to emergency response. 

47