COMMISSION STAFF WORKING DOCUMENT EU Overview Third river basin management plans Second flood hazard and risk maps and second flood risk management plans 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: EU Member State, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

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  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2025  SWD(2025) 13 final  COMMISSION STAFF WORKING DOCUMENT EU Overview         Third river basin management plans        Second flood hazard and risk maps and second flood risk management plans 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) 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) 34 final} - {SWD(2025) 35 final}  
 
 
© Pexels.com | Stepan Vrany 

Staff working document 

EU overview 

ENVIRONMENT 

 
 
 
 
 
1. 

Introduction 

This Commission Staff Working Document accompanies the Commission’s 7th implementation report 
prepared as required by Article 18 of the Water Framework Directive1 (WFD) and Article 16 of the 
Floods  Directive2  (FD)  respectively.  It is based  on  the  Commission’s  assessment  of  the  third  River 
Basin Management Plans (RBMPs) and second Flood Risk Management Plans (FRMPs), and second 
Flood Hazard and Risk Maps (FHRMs), prepared and reported by Member States for the period 2022-
2027. This document is complemented by country-specific Staff Working Documents describing the 
results of the assessment by the Commission of the RBMPs and the FRMPs, and FHRMs, for each 
Member State that reported on time. 

Twenty Member States have adopted and reported their third RBMPs and twenty-one Member States 
adopted  and  submitted  their  second  FRMPs  in  time for  this  7th  implementation  report  (see  more 
detail in section 2 below). 

Bulgaria, Cyprus, Greece, Malta, and Portugal failed to submit both their RBMPs and FRMPs in time to 
be  considered  for  the  assessment  in  this  report3.  Slovenia  and  Ireland  only  reported  their  FRMPs, 
whilst Slovakia only reported its RBMPs. For Spain, RBMPs for the Canary Islands have not yet been 
reported. Therefore, the present report does not cover these countries or regions.  

The State of European Waters 2024 report by the European Environment Agency (EEA) published on 
15 October 20244 provides further insights on the status of Europe’s water bodies, as reported by 
the Member States. It should be noted however that the EEA report covers a slightly smaller (19 EU 
Member States) and different subset of Member States, since it is purely based on electronic data 
submitted in WISE as of a June 2024. –Additional information, including country dashboards, will be 
made available through the Freshwater Information System for Europe (WISE Freshwater) portal in 
the coming months5. WISE is a web-portal hosted by the European Environment Agency containing 
water-related information ranging from inland waters to marine. 

1.1  Approach to the assessment of the River Basin Management Plans 
(RBMPs) and Flood Risk Management Plans (FRMPs) 

Both RBMPs and FRMPs are comprehensive documents, consisting of hundreds to thousands of pages 
of  information,  published  in  national  languages.  Their  assessment,  entailing  processing  extensive 
information in more than 20 languages, has been a very challenging and complex task. 

Member States agreed that besides submitting their RBMPs and their FRMPs to the Commission they 
would report pre-defined key information electronically through the WISE Freshwater portal.6  

The  quality  of  the  Commission  assessments  relies  on  the  quality  of  the  Member  States'  reports. 
Incomplete or deficient reporting can lead to wrong and/or incomplete assessments. It is recognised 
that reporting is a big effort for Member States, in particular the electronic reporting to WISE. There 

1 2000/60/EC; supplemented by Groundwater (2006/118/EC) and Environmental Quality Standards (2008/105/EC) 
Directives. 
2 2007/60/EC 
3 The cut-off date for consideration in this report was September 2023. 
4 EEA Report 7/2024, Europe's state of water 2024. The need for improved water resilience published on 15 Oct 2024 
(https://www.eea.europa.eu/en/analysis/publications/europes-state-of-water-2024). 
5 https://water.europa.eu/freshwater  
6 https://water.europa.eu/freshwater 

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are  examples  of very  good,  high-quality  reporting. However,  there  are  also  cases  where  reporting 
contains gaps or contradictions. 

According to the Directives, the deadline for reporting was March 2022. Regrettably, many Member 
States adopted their Plans late and most reported with significant delays. This led the Commission to 
launch legal proceedings against all Member States in breach of their legal requirements. Even at the 
time of the finalisation of this assessment, not all Member States had adopted and submitted to the 
Commission their RBMPs and FRMPs.7 

While all FRMPs considered in this analysis were submitted by the Member States electronically, many 
Member States were late in reporting their third RBMPs through the WISE and some did not do it at 
all.  As  a  result,  the  Commission  had  to  rely  for  its  assessment  on  a  mixture  of  comparable  and 
electronically submitted data and information manually extracted from the RBMPs, as well as other 
relevant sources. The reasons for this include technical challenges with the reporting platform, as well 
as limited progress in Member States as regards the digitization of water data. In the context of the 
preparation of its assessment, the Commission maintained regular contact with the Member States 
to validate its findings and to ensure that the assessment reflects reality. 

7 Updated information on the adoption of the 3rd RBMPs and 2nd FRMPs is available respectively at  
https://environment.ec.europa.eu/topics/water/water-framework-directive_en#state-of-play-of-3rd-rbmp-adoption-in-eu-
27 and https://environment.ec.europa.eu/topics/water/floods_en#state-of-play-of-2nd-frmp-adoption-in-eu-27  

3 

 
 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

4 

 
 
 
2.  Main elements of the WFD 

The WFD introduced  objectives to protect aquatic ecosystems in a more holistic way, considering all 
uses and users of water, and managing water on the scale of river basins. It included a number of 
key principles into the management and protection of aquatic resources: 

1)  The  integrated  planning  process  at  the  scale  of  river  basins,  from  characterisation  to  the 

definition of measures to reach the environmental objectives. 

2)  A comprehensive assessment of pressures, impacts and status of the aquatic environment, 

including from the ecological perspective. 

3)  The economic analysis of the measures proposed/taken and the use of economic instruments. 
4)  The 
targeting 

resources  management  principle  encompassing 
environmental objectives with water management and related policies objectives. 

integrated  water 

5)  Public participation and active involvement in water management. 

The key objective of the WFD is to achieve good status for all water bodies by 2015, or by 2027 at 
the latest8. This comprises the objectives of good ecological and good chemical status for surface 
waters and good quantitative and good chemical status for groundwater. 

The  key  tool  for  the  implementation  of  the  WFD  are  the  River  Basin  Management  Plans  and  the 
accompanying Programs of Measures (POMs). The RBMP is a comprehensive document describing the 
implementation of water management and identifying all actions to be taken in the river basin district 
(RBD). 

The PoMs reflect how the Member States respond to the relevant pressures identified at River Basin 
District level. 

The first RBMPs covered the period 2009-2015. The Commission adopted its assessment of the first 
RMBPs  in  20129,  while  a  dedicated  report,  in  2015  assessed  the  state  of  implementation  of  the 
associated 1st Programmes of Measures which were due in 2012. 

The second RBMPs covered the period 2016-2021. The Commission adopted its assessment of the 
second RMBPs in 201910, with an additional report in 202111, on the implementation of the second 
Programmes of Measures which were due in 201812. 

Implementation of the WFD continues to be supported by an informal network of Member States, 
EEA/EFTA countries and stakeholders under the banner of the Common Implementation Strategy (CIS), 
led  by  Water  Directors  of  Member  States  and  the  European  Commission,  with  participation  from 
relevant  stakeholders.  The  CIS  has  successfully  delivered  38  guidance  documents13;  served  as  a 
valuable platform for exchange of experience and best practice on implementation among Member 
States, but also for exploring common issues of concern and joint responses. All documents produced 
under the CIS are made public on CIRCABC14, a collaborative platform.  

8 Article 4(4) of the WFD allows for an extension of the deadline for achieving good status or potential beyond 2015 (as set 
by Article 4(1)) under well-defined conditions linked to technical feasibility, disproportionate costs or natural conditions. 
9 http://ec.europa.eu/environment/water/water-framework/impl_reports.htm#third 
10 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2019%3A095%3AFIN  
11 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2021:0970:FIN  
12 http://ec.europa.eu/environment/water/water-framework/impl_reports.htm#third 
13 https://circabc.europa.eu/ui/group/9ab5926d-bed4-4322-9aa7-9964bbe8312d/library/b44c5c7a-508f-4800-91a4-
9acc99c4eec4?p=1&n=10&sort=modified_DESC  
14 https://circabc.europa.eu/ui/group/9ab5926d-bed4-4322-9aa7-9964bbe8312d/library/a3c92123-1013-47ff-b832-
16e1caaafc9a 

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2.1  Governance and horizontal aspects 

2.1.1  Governance 

The WFD creates a robust framework for the integrated management of all aspects of water policy. 
The Directive defines the RBD as the main unit for management of river basins. Some of the key 
governance aspects are: an adequate territorial approach, the clear identification of responsibilities, 
coordination  and  cooperation  across  sectors,  interests  and  borders  as  well  as  ensuring  adequate 
human and financial resource are allocated. 

Member  States  have  designated  a  range  of  competent  authorities  for  the  implementation  of  the 
WFD15. Most have more than one competent authority. 

Out of the 20 Member States assessed, significant changes in governance were reported in the third 
RBMPs only by 6 Member States (Estonia, France, Germany, Italy, Poland, Sweden). 

In France, an important step has been taken to strengthen coordination at the scale of River Basin 
District16. Since 2014, France has undergone a significant reform of local authorities, aiming for a 
more efficient implementation at the local level and a better integration of the ecological and flood 
management aspects. This resulted in assigning a mandatory competence for the management of 
the aquatic environment and flood prevention to all municipalities17. In Italy, River Basin Authorities 
have now full competence to elaborate the RBMPs, while the Regions can elaborate regional plans 
(Piani di Tutela della Acque) which are now developed and adopted under the umbrella of RBMPs and 
constitute  subplans  of  the  RBMPs.  In  Estonia,  while  the  Ministry  of  Environment  has  the  overall 
coordination of the implementation, the number of authorities in charge of water management has 
risen from three to nine compared to the second RBMPs. Germany has streamlined its governance 
with the river basin approach by reducing the number of competent authorities to one for each of the 
10 (instead of 16 before) RBDs thereby improving coordination arrangements between the German 
federal states (‘Länder’). This may be one reason why all 10 RBDs have been finalised and published 
on time. In Poland, the number of RBMPs published decreased from 10 to 9 for the third RBMPs. This 
is due to the new division specified in the updated Water Law from 2017. Poland did not provide 
further information on the reason of this change.  In Sweden, sub-plans have been produced for the 
third  RBMPs  regarding  drought  and  water  scarcity  in  the  South  Baltic  due  to  the  clear  effects  of 
climate change in this RBD. The other water basins did not proceed with a sub-plan regarding drought 
and water scarcity, but instead incorporated the issue as into the RBMPs. 

Public consultation and the active involvement of stakeholders 

Member  States  must  ensure  consultation  and  access  to  background  information  used  for  the 
development of RBMPs and to encourage active involvement of all interested parties. 

This  requirement  was  respected  in  almost  all  Member  States  that  have  generally  undertaken 
considerable efforts in consulting stakeholders and the public and have used a variety of different 
outreach methods, which during the pandemic were adapted, exploring also new methods for online 
public consultations. However, there are also examples where consultation could have been better 

15 Please note that in their RBMP reporting, Member States indicated the names of their competent authorities: the 
categories and the categorisation were created for the purpose of the assessment for this report. It should also be noted 
that the Member States have indicated authorities responsible for key aspects of the development and implementation of 
their RBMPs: these may include authorities additional to those reported under Article 3 of the WFD. 
16 With the Law 221/2015, and in particular Article 51 “Norms concerning River Basin Authorities”. 
17 This new decentralised competence is called “GEMAPI” - gestion des milieux aquatiques et la prévention des 
inondations. 

6 

 
 
since in some cases incomplete set of documents were submitted for public consultation. For instance, 
in Latvia and Poland, there was no consultation on an overview of the significant water management 
issues. In France, for the Mayotte RBD, only the draft RBMP was made available for consultation and 
in Italy for the North Apennines RBD, the draft RBMP presented for consultation was incomplete and 
not  comprehensive  enough  to  allow  proper  public  feedback.  In  Lithuania,  the  draft  RBMPs  were 
available for public consultation only for 5 months instead of the mandatory 6 months. In Croatia, no 
information  is  provided  regarding  the  duration  of  the  consultation  of  the  timetable  and  work 
programme. In addition, a lack of actual engagement (diversity of sectors reached, activities put in 
place) was noted in some countries or RBDs. 

Despite clear improvements, it is not clear for all Member States or RBMPs whether the stakeholder 
consultations  significantly  influenced  the  adopted  RBMPs  and  whether  this  has  contributed  to 
enhanced ownership by all parties involved.  

In line with the requirement of the WFD to involve all interested parties in its implementation, most 
of  the  Member  States  established  advisory  groups  and  involved  stakeholders  in  the  drafting. 
Stakeholder groups (such as water supply and sanitation, agriculture, local and regional authorities, 
non-governmental organisations and nature protection groups) were actively involved in all or some 
of the RBDs in all Member States assessed. 

In Romania, the RBMP mentions that thematic meetings were held, in which ad hoc working groups 
were established, so that the most relevant stakeholders could actively participate in the consultation 
process. In Sweden, the mechanisms for active involvement were the establishment of Water councils, 
advisory groups involved in drafting of the RBMPs. In Finland organised feedback was sought from 
advisory groups (called “cooperation groups”) with a wide representation of key stakeholders from 
both  governmental  and  non-governmental  organizations.  In  Austria,  mechanisms  for  active 
involvement  of  stakeholders  included  advisory  groups  (Bundesministerium  für  Land-  und 
Forstwirtschaft, Regionen und Wasserwirtschaft), formation of alliances, regular exhibitions, digital 
tools,  involvement  in  drafting,  and  other  outreach  activities  such  as  stakeholder  meetings  and 
roundtables.  

In  some  RBDs,  participative  activities  were  targeted  to  specific  issues.  In  Belgium,  the  region  of 
Flanders set up a co-creation process for the water scarcity and drought plans that are included in 
the RBMPs. In Estonia, four online meetings were held during the consultation period, together for all 
draft RBMPs on several thematic areas: flooding, water management, abstraction and wastewater, 
residual pollution; dams; marine environment; agriculture and land reclamation. 

Coordination with the Floods Directive (FD) 

Competent authorities under the FD may differ from the ones appointed under the WFD and in certain 
Member States “units of management” (UoMs) identified in accordance with the FD are not the same 
as  the  RBDs  under  the  WFD.  As  required  by  Article  9  of  the  FD,  Member  States  shall  also  take 
appropriate steps to coordinate actions under the Floods Directive and the WFD.  

Overall,  15  of  the  21  Member  States  assessed  provided  strong  evidence  in  their  Flood  Risk 
Management Plans that coordination was ensured with the WFD, while the remaining six had at least 
some evidence.  

The Figure 2-1 below shows that most Member States include coordination between authorities in all 
UoMs. Denmark was the only Member State not to report coordination between authorities, and is 
thus not shown in the figure, and Poland and Belgium reported it only for some UoMs. 

7 

 
We can distinguish two approaches to the synergies between WFD and FD implementation. Only in 2 
Member States (Croatia and Latvia), the Flood Risk Management Plans are fully integrated as a single 
plan in all the RBMPs, while for Belgium this was done only for three out of seven RBMPs. The most 
integrated plan is the one from Latvia, where the  RBMPs and FRMPs are now consolidated in one 
single  plan  for  each  RBD,  which  also  includes  mandatory  measures  from  the  Marine  Strategy 
Framework Directive. They share a common PoM and undergo a joint public consultation. In the case 
of Croatia, the document includes separate PoMs for the RBMP and the FRMP. However, some of the 
measures (mainly measures related to hydromorphological issues) in the RBMP reference flood risk 
management among the relevant sectors. 

Figure 2-1: Number of Member States providing evidence of coordination between FRMPs and RBMPs 

Source: MS reporting to EIONET 

In a vast majority of Member States, RBMPs and FRMPs remain separate planning documents, whose 
elaboration has been coordinated to a different degree. In the Netherlands, the RBMPs and FRMPs 
are both annexes to the Dutch National Water Programme. 

The great majority of the Member States has carried out a joint consultation of their RBMPs and the 
FRMPs for all RBDs (Austria, Croatia, Czechia, Estonia, Germany, Hungary, Lithuania, Latvia, Poland, 
Romania, Spain) or only some RBDs (Belgium, Finland and France). 4 Member States did not carry out 
joint consultations (Italy, Luxembourg, Slovakia, Sweden) and 2 did not indicate this information in 
their RBMPs (Denmark, the Netherlands). The reasons why certain Members States or RBDs did not 
conduct a parallel consultation are mainly related to practical issues, such different timings of the 
two planning processes or delays. For instance, in Slovakia, RBMP and FRMP are no longer integrated 
in a single plan – as it was the case for the second cycle – and did not undergo a joint process of 
elaboration because flood risk maps were not ready soon enough to allow a joint process with the 
elaboration of the RBMPs.  

Other ways to coordinate the implementation of the two Directives (see Figure 2-2 below) are: 

1)  inclusion of the FD objectives among the RBMP’s objectives (Estonia, Hungary, Luxembourg, 
Netherlands, and Romania); and on the other hand, assessing and mitigating the potential 
impact  of  the  FRMP  measures  on  the  RBMP’s  objectives.  As  an  example,  in  Belgium,  the 

8 

 
 
Wallonia  RBMP  indicate  that  40%  of  the  measures  included  in  the  FRMPs  support  the 
objectives  of  the  WFD  (e.g.  hydromorphology  and  flow).  Yet,  10%  of  the  measures  in  the 
FRMPs have been identified with potential negative impact on the objectives of the WFD and 
for these, special attention is required to mitigate/compensate such impacts. 

2)  inclusion of measures related to the FD in the RBMPs’ PoMs. These measures often combine 

the aim of both ecological and flood management such as the case of Czechia. 

Figure 2-2: Integration of objectives in RBMPs and FRMPs 

Source: Member State reporting to EIONET 

All Member States reported to EIONET that their coordination with the WFD, included natural water 
retention and green infrastructure measures, (though for six Member States, this was in some but 
not always in all their UoMs (see the Figure 2-3 below). Drought management was identified by 11 
Member States (Czechia, Finland, Croatia, Hungary, the Netherlands, one UoM in Spain and Sweden, 
three UoMs in France and Poland, five UoMs in Belgium and 29 UoMs in Italy). Overall, the assessment 
shows a significant increase in the number of measures reported as delivering on both WFD and FD 
objectives. 

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Figure 2-3: Number of Member States reporting synergies between FRMP and RBMP measures18 

Coordination with the MSFD 

The  framework  established  by  the  WFD  covers  coastal  waters  and  contributes  inter  alia  to  the 
protection of territorial and marine waters. It hence contributes directly to achieving the objectives of 
the Marine Strategy Framework Directive (MSFD) and requires a more integrated approach between 
freshwater  and  the  marine  environment.  This  is  particularly  true  for  issues  such  as  reduction  of 
nutrient  load  and  eutrophication,  reduction  of  pollution  source  from  the  land,  spread  of  invasive 
species, fish migration, and aquaculture. 

The assessment highlights that the level of coordination on the implementation of the WFD and MSFD 
varies across Member States. 

The strongest evidence of coordination on the implementation of the directives and of coordinated 
public  consultations  are  shows  in  Latvia,  Lithuania,  Estonia  Sweden  and  France.  In  Lithuania,  the 
National Water Plan for 2022-2027 integrates the objectives of the WFD, FD and MSFD. In Estonia, 
a  joint  consultation  was  held  for  the  third  RBMPs  together  with the  FRMPs  and  the  PoMs  for  the 
MSFD. Furthermore, the implementation of the MSFD and its PoMs is included in the Estonian RBMPs 
PoMs basic measures The French law provides that the RBMPs and the FRMPs must be compatible 
with the environmental objectives of the Action Plan for the Marine Environment (the operational plan 

18 Full terms for the categories shown in the tables: 

• 

• 

• 

• 

• 

• 

Use of sustainable drainage systems, such as the construction of wetland and porous pavements, considered to 
reduce urban flooding and contribute to the achievement of the environmental objectives in the WFD 
Design of new and existing structural measures, such as flood defences, storage dams and tidal barriers, 
adapted to take environmental objectives of the WFD into account 
Consistent and compliant application of Article 4(7) of the WFD and designation of heavily modified water 
bodies with measures taken under the FD, e.g. flood defence infrastructure 
Permitting or consenting of flood risk activities (e.g. dredging, flood defence maintenance or construction) 
requires prior consideration of WFD objectives and RBMPs 
Planning of ‘win-win’ and ‘no regret’ measures in the FRMP and RBMP included NWRMs and green infrastructure 
measures 
Planning of ‘win-win’ and ‘no regret’ measures in FRMP and RBMP included drought management measures 

10 

 
 
 
for  the  implementation  of  the  MSFD)  and  take  into  account  the  objectives  and  measures  of  the 
Strategic Coastal Plan (the strategic document for the implementation of the MSFD). In Sweden, the 
PoMs for the MSFD, the FRMP and the RBMP are coordinated. In Latvia mandatory measures from 
the MSFD are included in the joint RBMPs/FRMPs developed for each RBD. 

Other Member States, such as Finland and Romania, have a clear integration of the objectives of the 
MSFD in their RBMPs. In these countries, as well as in those mentioned above, the objectives of the 
MSFD were clearly taken into account in the RBMP’s PoMs.  

In Germany, Italy, Spain and Belgium, there are differences across the RBDs in terms of modalities 
and extent of the coordination between WFD and MSFD implementation. 

In Italy, the RBMP for the Po River makes the link between its measures and the environmental targets 
sets in the MSFD; the North Apennines RBMP includes a gap  analysis based on existing measures 
which  preliminarily  identified  25  possible  new  measures  aimed  at  reaching  MSFD  environmental 
objectives and to be included in the  update of the MSFD  PoM. However, the Sicily RBMP does not 
mention the MSFD.  

In Belgium, the North Sea RBMP is coordinated with the plans established under the MSFD. The RBMP 
mentions the need to achieve targets defined for the WFD, MSFD and Natura2000, and acknowledges 
overlaps between the application area of the MSFD and the WFD. For the evaluation of chemical and 
ecological  status,  the  intention  is  to  streamline  objectives  and  monitoring  as  much  as  possible. 
However,  the  Flanders  RBMP  does  not  contain  information  regarding  coordination  with  the  MSFD. 
Wallonia’s RBMPs refer to the specific RBMP that covers the coastal region of Belgium to which all 
three regions participate (i.e. Groupe directeur Mer du Nord).  

In Spain, there are difference across the RBMPs. For instance, the Ebro RBMP includes the objectives 
of  the  MSFD  among  its  objectives.  In  the  Segura  RBMP  instead,  the  MSFD  it  is  not  mentioned 
specifically,  but  the  Marine  Strategy  of  Levantino-Balear  aiming  to  restore  the  Mar  Menor  is 
mentioned as a key challenge. The Guadiana RBMP does not refer to the MSFD specifically, however 
some of measures included would be also beneficial for the marine environment (e.g. restore marine 
ecosystems. reduce marine litter by 50 % and release of microplastics by 30 %). Positively, coastal 
and marine waters are considered in the methodology for ecological flows. 

In Germany, for instance, the Weser RBMP does mention the MSFD and includes some of its objectives, 
as well as detailed interlinkage as regards substances to be measured that are included in both the 
WFD and the OSPAR agreement19. However, the Rhine RBMP does not name the MSFD directly when 
reporting  on  additional  measurements  from  other  regulations. The  Elbe  RBMP  explains  the 
interlinkages between the MSFD and WFD, but this is not translated into concrete action for the Elbe 
basin. 

Some Member States or RBDs do not show signs of coordination between the RBMPs and the MSFD. 
For instance, the Danish RBMPs do not mention the MSFD. In  Poland, the Oder and Vistula RBMPs 
mention the National Marine Water Management Plan, which is the plan at the national scale for the 
implementation of the Marine Strategy Framework Directive (MSFD). However, no explicit link is made 
between this plan and the objectives or measures of the RBMPs. The situation is the same in Croatia, 
where the MSFD is mentioned only once in the RBMP as being under the responsibility of a different 
administration.  Yet  the  RBMP  contains  several  references  to  the  Barcelona  Convention  and issues 
related to marine environment pertaining to coastal areas and rivers that discharge into the Adriatic. 

19 OSPAR is the mechanism by which 15 Governments and the EU cooperate to protect the marine environment of the 
North-East Atlantic. 

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Regarding the national RBMPs in the landlocked countries (Austria, Czechia, Hungary, Luxembourg, 
Slovakia), most of them do not refer explicitly to the MSFD. However, the Czech RBMPs’ PoMs include 
specific measures to prevent the pollution of marine waters. The Hungarian RBMP does not mention 
the  MSFD,  except  in  connection  with  the  implementation  of  the  Urban  Wastewater  Treatment 
Directive, to mitigate eutrophication. 

In the Baltic Sea basin 

The Latvian RBMPs state that attention has been paid to the assessment of the state of the marine 
environment in the marine eutrophication status assessment, as it is in the area of eutrophication 
that measures to reduce pressures on (river catchments) are essential for improving the status of 
marine  waters.  The  measures  in  the  Programmes  of  the  RBMPs  are  mandatory  measures  in  the 
context of the Marine Strategy Framework Directive and are therefore fully applicable to the Baltic 
Sea management.  

In Lithuania, the second objective of the National Water Development Plan 2022-2027 is to achieve 
and/or  maintain  good  environmental  status  in  the  Baltic  Sea.  The  priority  is  to  reduce  pollution 
reaching  the  Baltic  Sea  and  the  Curonian  Lagoon  through  river  runoff.  Further  objectives  in  the 
National Water Development Plan relevant for the MSFD include ensuring a more sustainable use of 
marine resources, continuing research and developing national action plans to improve the status of 
specific populations. This document states that improvement of the legal framework to reduce the 
release of hazardous chemicals into the marine environment is foreseen, as well as an increased 
focus on limiting the spread of invasive species, the problem of marine litter, and the negative impacts 
of noise and other forms of energy.  

The PoMs of the Estonian RBMPs include measures to reduce pollution and facilitate fish migration 
that are designed to achieve a good state of the marine environment.   

In Finland, the reduction of the nutrient load necessary to improve the state of the sea has been taken 
into account when designing the water management measures and their magnitude. On the other 
hand, marine management measures are designed to help achieve the environmental goals of water 
management set for coastal waters. 

In the North Sea 

In Germany, as mentioned earlier, the Weser RBMP elaborates on the interlinkages with the MSFD. It 
includes the nitrogen load reduction needed to achieve good ecological status in coastal waters.  It 
also refers to substances to be measured, which are included in the WFD and the OSPAR-agreement. 
On  the  other  hand,  the  Dutch  RBMP  only  contains  general  references  to  coordination  for  some 
objectives of the MSFD (e.g. the objective to limit litter and microplastics). 

The French Rhine-Meuse RBMP explicitly links its objectives and measures with the marine strategy 
of the Netherlands regarding migratory fishes, nutrients and pollutants loads, and macro-plastics. 

In Belgium, the North Sea RBMP shows a clear alignment between the two policy areas and makes 
explicit  references  to  the  MSFD  assessment  for  Phytobenthos,  the  impact  of  human  activities  on 
hydrology and hydromorphology. The PoMs are coordinated. The RBMP lists the measures from the 
MSFD  PoMs  which  may  contribute  to  achieving  a  good  ecological  status  and  contribute  to  the 
objectives of the WFD. 

12 

 
In the Black Sea 

In Romania, the common objectives focus mainly on addressing impacts of wastewater (wastewater 
treatment measures), aquaculture industry and conservation of sturgeon species and of protected 
areas. 

The coordination with the MSFD also takes place at the Danube International River Basin District level, 
with projects carried out by the International Commission for the Protection of the Danube River. 

In the Mediterranean 

In Italy, the Po RBMP states that wastewater treatment and chemical quality of water resources are, 
per se, directly linked to the environmental targets set in the MSFD. The North Apennines includes a 
table on the correspondence between WFD Key Type Measures and their relevance for the MSFD. 

In Spain, for example, 492 measures outlined in the Ebro RBMP have been recognised for their role 
in  advancing  the  achievement  of  environmental  objectives  in  the  second  cycle  of  the  Levantine-
Balearic Marine Strategy and aim to effectively  contribute to attaining good environmental  status 
(GES). 

In  France,  on  the  Rhone-Mediterranean  RBD  (FRD),  objectives  are  coordinated  with  the  MSFD, 
particularly for preserving the Mediterranean marine environment from the introduction of invasive 
exotic species and reducing land-based inputs of hazardous substances into the Mediterranean Sea. 

2.1.2  Characterisation of the River Basin District 

Introduction 

Article 5 of the WFD requires Member States to undertake an analysis of the characteristics of each 
RBD or portion of an international RBD falling within their territory. They should identify all relevant 
categories  and  types  of  water  bodies  within  the  RBD.  For  surface  waters,  specific  typologies  and 
reference conditions have to be established. Characterisation also involves correctly identifying water 
bodies at risk of failing objectives. 

Assessment of implementation and compliance with WFD requirements in third RBMPs  

Delineation of surface and Groundwater bodies 

Table 2-1 provides an overview of the number of surface water bodies in each Member State for 
which third RBMP reporting was available. These numbers will change once all Member States have 
reported their third RBMPs. From the information available so far, covering 20 Member States, 78.4% 
of surface water bodies are delineated as river water bodies,  18.9% are delineated as lake water 
bodies, 0.5% are delineated as transitional water bodies, 2.1% are delineated as coastal water bodies 
and 0.1 % are delineated as territorial water bodies20. This is very similar to what was reported for 
the previous cycle.  

20 Percentages are expected to change once all Member States have reported their 3rd RBMPs and the number of surface 
water bodies per surface water category in all Member States is known.  

13 

 
 
Table 2-1 - Number of water bodies per water category in Member States21 

Member State 

Rivers 

Lakes 

Transitional 

Coastal 

Territorial 

Groundwater 
bodies 

Austria (AT) 

8116 

Belgium (BE) 

521 

Czechia (CZ) 

Germany (DE) 

Denmark (DK) 

Estonia (EE) 

1045 

8923 

6703 

635 

62 

30 

73 

738 

986 

93 

0 

7 

0 

5 

0 

0 

Spain (ES) 

4136 

888 

186 

Finland (FI) 

1960 

4639 

0 

France (FR) 

10714 

397 

116 

Croatia (HR) 

1752 

Hungary (HU) 

886 

Italy (IT) 

6876 

Lithuania (LT) 

826 

109 

186 

347 

361 

Luxembourg (LU) 

104 

2 

Latvia (LV) 

492 

Netherlands 

234 

The 
(NL) 

276 

492 

Poland (PL) 

3161 

1068 

Romania (RO) 

2741 

278 

Sweden (SE) 

15688 

7453 

Slovakia (SK) 

1328 

23 

35 

0 

147 

4 

0 

3 

6 

7 

2 

0 

0 

0 

1 

0 

71 

109 

16 

255 

276 

179 

81 

0 

393 

2 

0 

5 

9 

4 

4 

654 

0 

0 

1 

0 

7 

14 

2 

0 

0 

1 

0 

142 

81 

174 

1291 

2050 

31 

804 

3913 

689 

51 

185 

10 

1007 

1 

0 

4 

4 

0 

1 

19 

0 

20 

6 

25 

23 

174 

143 

3702 

106 

As regards surface water bodies, Figure 2-4 below shows that there are changes in the number of 
surface  water  bodies  between  the  second  and  third  RBMPs  in  all  the  Member  States  that  were 

21 Data for Austria, Belgium, Croatia, Czechia, Estonia, France, Germany, Hungary, Italy, Lithuania, Latvia, the Netherlands, 
Poland, Romania, Slovakia and Spain is from WISE electronic reporting and data for Denmark, Finland, Luxembourg and 
Sweden is from data mining from the PDFs of the RBMPs. 

14 

 
 
 
included in the assessment. Only in some cases, these changes are particularly significant. Reasons 
for changes are described in the RBMPs of some of the concerned Member States, but not all. 

Figure 2-4: Number of surface water bodies in Member States in the third and second RBMPs22 

AT

BE

CZ

DE

DK

EE

ES

FI

FR

HR

HU

IT

LT

LU

LV

NL

PL

RO

SE

SK

  0

 5 000

 10 000

 15 000

 20 000

 25 000

2nd RBMPs

3rd RBMPs

As shown in Figure 2-5 below, between the second and third RBMPs there are also changes in the 
delineation of groundwater bodies in most Member State. This are particularly significant for countries 
such  as  Denmark  and  Sweden.  Reasons  for  changes  are  described  in  the  RBMPs  of  some  of  the 
concerned Member States. 

22 Data for the 3rd RBMPs for Austria, Belgium, Croatia, Czechia, Estonia, France, Germany, Hungary, Italy, Lithuania, Latvia, 
the Netherlands, Poland, Romania, Slovakia and Spain is from WISE electronic reporting and from data for Denmark, 
Finland, Luxembourg and Sweden is from data mining from the RBMP PDFs.  

15 

 
 
 
Figure 2-5: Number of groundwater bodies in Member States in the third and second RBMPs23 

AT

BE

CZ

DE

DK

EE

ES

FI

FR

HR

HU

IT

LT

LU

LV

NL

PL

RO

SE

SK

0

500

1000

1500

2000

2500

3000

3500

4000

2nd RBMPs

3rd RBMPs

Reference conditions 

Member States are required to establish the ecological status of water bodies by comparing current 
status  with  near  natural  or  undisturbed  (reference)  conditions  which  show  no  or  only  very  minor 
evidence of distortion.  Reference conditions have to be established for each of the surface water 
body types for biological, physico-chemical and hydromorphological quality elements. 

Notwithstanding significant progress made in most Member States with setting reference conditions 
for  all  quality  elements,  as  well  as  improving  coherence  and  comparability  of  biological  quality 
elements  in  the  so  called  intercalibration  exercise  at  EU  level24,  there  is  still  some  lack  of 

23 Data for the 3rd RBMPs for Austria, Belgium, Croatia, Czechia, Estonia, France, Germany, Hungary, Italy, Lithuania, 
Latvia, the Netherlands, Poland, Romania, Slovakia and Spain is from WISE electronic reporting and from data for 
Denmark, Finland, Luxembourg and Sweden is from data mining from the RBMP PDFs. 
24 OJ L, 2024/721, 8.3.2024: http://data.europa.eu/eli/dec/2024/721/oj 

16 

 
 
 
harmonization at EU level and room for improving the comparability of overall status assessment 
based on biological, physico-chemical and hydromorphological quality elements.  

Pressures and impacts 

The  assessment  of  this  ‘characterisation’  carried  out  by  Member  States  confirms  that  European 
waters remain under significant pressure from pollution generated by both diffuse (e.g. agriculture, 
transport)  and  point  (e.g.  industry  or  energy  production)  source,  as  well  as  over-abstraction  and 
hydromorphological changes25, stemming from a range of human activities.  

As shown in Figures 2-6, 2-6a and  2-6b below , the most significant pressures for surface water 
bodies in  the reporting  Member States  for which the data is available  electronically are pollution 
from atmospheric deposition (affecting 59% of waterbodies), hydromorphological changes (57% 
- stemming from drainage and irrigation for agriculture, hydropower, flood protection, navigation or 
drinking water supply, and diffuse pollution from agriculture (32% of affected water bodies). Other 
main  pressures  across  the  Union  include  urban  wastewater  discharges  (14%),  discharges  not 
connected to the sewage system (9%), and abstraction (9%) for multiple purposes. Other pressures 
most commonly identified in the RBMPs include pollution from urban run-off (8%) storm overflows 
(5%), as well as discharges from industrial installations (6%). It should be noted that the same 
water body can be subject to multiple pressures, so the total does not add up to 100%. 

Regrettably,  13%  of  EU’s  water  bodies  continue  to  be  affected  by  yet  unidentified  anthropogenic 
pressures, which would indicate that the pressures and impacts have not been fully apportioned to 
activities or sectors, so there is still room for increasing our knowledge to better tackle such pressures. 
No significant pressure is identified in only 10% of the reported water bodies. 

Aquatic  ecosystems  in  Europe  are  also  under  increased  pressure  from  invasive  alien  species 
affecting both freshwater and marine ecosystems and several of these species have been included 
in the list of invasive species of Union concern. Despite the direct impact that these species can have 
on  the  achievement  of  the  WFD  objective  of  ecological  status,  the  issue  is  only  identified  as  a 
significant pressure in 2.2% of surface water bodies and information on invasive alien species and 
the measures taken to tackle the problem is often totally missing or not very detailed in the RBMPs.  

25 Hydromorphological changes are, for instance, changes to physical characteristics surface waters and natural flow of 
rivers and transitional waters, or water levels of lakes or freshwater flow and natural current of coastal waters. 

17 

 
 
Figure 2-6: Top pressures which have been reported in surface water bodies (from WISE Freshwater – only 
countries with electronic reporting) 

Atmospheric deposition

Hydromorphology

Diffuse sources

Point sources

59%

57%

38%

20%

Unknown anthropogenic pressure

13%

Abstraction

9%

Introduced species and litter

3%

Historical pollution

Other anthropogenic pressure

2%

2%

0%

10%

30%

20%
50%
Percentage of total surface water bodies

40%

60%

70%

Figure 2-6a: Diffuse pollution pressures for  surface water bodies in 3RBMPs (from WISE  Freshwater  – 
only countries with electronic reporting) 

Agricultural

32%

9%

8%

Discharges not connected to sewerage network

Urban run-off

Transport

Other

3%

3%

Forestry

1%

Mining

1%

Contaminated sites or abandoned industrial sites

1%

0%

5%

10%

15%

20%

25%

30%

35%

18 

 
  
 
Figure 2-6b: Point pollution pressures for surface water bodies in 3RBMPs (from WISE Freshwater – only 
countries with electronic reporting) 

14%

Urban waste water

Storm overflows

IED plants

Contaminated sites or abandoned industrial sites

Non IED plants

Other

Waste disposal sites

Mine waters

Aquaculture

1%

1%

1%

1%

5%

4%

2%

2%

0%

2%

4%

6%

8%

10%

12%

14%

16%

While  a  majority  of  groundwater  bodies  in  the  EU  (71%)  is  reported  as  not  being  subject  to  any 
significant pressures, almost one third of groundwater bodies is affected by a range of pressures. As 
shown in the Figures 2-7, 2-7a and 2-7b below, the main pressures affecting groundwater bodies26 
across the EU are diffuse agricultural pollution (e.g. pesticides and fertilisers) which affect 59% of 
the impacted groundwater bodies and abstraction for public water supply (25% of the impacted 
groundwater  bodies),  followed  by  abstraction  for  agriculture  (22%)  industrial  (12%)  and  other 
purposes  (12%).  Diffuse  pollution  from  other  sources,  in  particular  urban  run-off  (16%)  and 
discharges not connected to sewerage network (6%) are also important pressures, as are pollution 
from contaminated or abandoned industrial sites (17%) and historical pollution (13%). 

26 Based on WISE Freshwater data covering 16 out of the 20 Member States for which the data is available electronically. 

19 

 
 
 
Figure 2-7 – Top pressures reported for impacted groundwater bodies (from WISE Freshwater) 

Diffuse sources

Abstraction

Point sources

35%

25%

68%

Historical pollution

13%

Unknown anthropogenic pressure

7%

Groundwater recharge or water level

5%

Atmospheric deposition

Other anthropogenic pressure

Introduced species and litter

Hydromorphology

2%

2%

1%

1%

0%

10%

20%

30%

40%
Percentage of total surface water bodies

50%

60%

70%

80%

Figure 2-7a: Diffuse pollution pressures for groundwaters in the third RBMPs (from WISE Freshwater – 
only countries with electronic reporting) 

Agricultural

59%

Urban run-off

16%

Discharges not connected to sewerage network

7%

Other

5%

Transport

4%

Mining

3%

Contaminated sites or abandoned industrial sites

Forestry

2%

2%

0%

10% 20% 30% 40% 50% 60% 70%

20 

 
 
 
Figure 2-7b: Point pollution pressures for groundwaters in third RBMPs (from WISE Freshwater – only 
countries with electronic reporting) 

Contaminated sites or abandoned industrial sites

18%

Waste disposal sites

5%

Other

4%

Urban waste water

3%

IED plants

Mine waters

2%

2%

Non IED plants

1%

0% 2% 4% 6% 8% 10% 12% 14% 16% 18% 20%

Programme of Measures (PoMs) 

The WFD requires Member States to identify a Programme of Measures (PoMs) 27 to prevent or limit 
the identified pressures and timely achieve good status.  

The reports by Member States confirm that a considerable number of  measures announced in the 
second RBMPs could not be turned into action.  

As it was the case for the 1st PoMs, insufficient funding of measures has been identified as the most 
significant obstacle for the implementation of measures in the  second RBMPs (86%), followed by 
unexpected delays (81%), lack of mechanisms (70%, i.e. national regulations or other measures not 
yet adopted) and governance issues (57%). Difficulties in acquiring land required to implement certain 
measures is also regularly raised as key challenge. 

As regards the third PoMs presented in the 2022-2027 RBMPs, it can be observed that Member States 
continue to have different approaches to the development and reporting of PoMs.  The PoMs often 
contain a fairly long set of measures. While the use of Key Type Measures was intended to harmonize 
reporting, differences remain. There is no uniform definition of what count for one measure. Hence 
while  some  Member  States  may  report  granularly  on  individual  measures  (i.e.  investment  in  an 
individual wastewater treatment plant), other Member States may include a single entry for multiple 
interventions in the same area. The number of measures is therefore not a very informative indicator 
for the effort. More importantly, not in all Member States the PoMs are based on clear assessment 
of the gap to be bridged to reach good status. In addition, there is generally limited information on 
prioritisation of measures based on the cost-effectiveness analyses.  

Costs of the planned measures is also not clearly identified and considering the persistent funding 
challenges  reported  by  Member  States  it  can  be  understood  that  the  required  resources  for  the 

27 The next interim reports on the implementation of the planned PoMs should be reported to the Commission by 22 
December 2024. 

21 

 
 
 
implementation  of  the  PoMs  are  not  always  secured  upfront.  This  severely  hampers  their 
effectiveness. 

While  limited  information  is  provided  in  many  of  the  RBMPs,  it  is  worth  noting  that  EU  funding 
instruments  including  the  Common  Agricultural  Policy,  the  Cohesion  Policy  and  the  Recovery  and 
Resilience  Facility  played  a  significant  role  in  supporting  the  implementation  of  RBMP  and  FRMP 
measures  across  Member  States.  Furthermore,  the  Commission  through  the  Horizon  Europe 
programme is providing extensive support for research to close the knowledge gaps and promote the 
deployment of innovative solutions, including through the Mission on Oceans and Freshwaters. Finally, 
through  the  Technical  Support  Instrument,  the  Commission  is  also  supporting  Member  States  in 
designing, developing and implementing reforms in water policy. 

3.  How  the  implementation  of  the  third  RBMPs  have 
contributed to addressing the triple planetary crisis 

3.1  POLICY ELEMENTS CONTRIBUTING TO BIODIVERSITY AND CLIMATE 
CHANGE ADAPTATION 

3.1.1 

 Surface Water: what is their ecological status or potential 

Introduction  

The main objectives of the WFD include the achievement of Good Ecological Status (GES) or Potential 
(GEP) by 2015, or by 2027 at the latest. Member States must establish surface water monitoring 
networks  to  provide  a  coherent  and  comprehensive  overview  of  ecological  (and  chemical)  status 
within each river basin district that allows for the classification of water bodies. The quality elements 
used  for  the  classification  of  ecological  status  comprise  biological  quality  elements  (BQEs), 
hydromorphological quality elements supporting the BQEs; general physico-chemical quality elements 
and RBSPs supporting the BQEs. 

Each Member State is required to develop methods to assess ecological status for all biological quality 
elements and apply them for the purpose of surveillance and operational monitoring28. Assessment 
methods  for  the  supporting  quality  elements  must  be  linked  to  the  biological  quality  elements, 
according to the normative definitions given in Annex V of the WFD. Methods should be developed for 
the full range of quality elements to allow detection of all pressures on surface water bodies and 
together provide a holistic picture of the ecological status of the aquatic environment.   

Monitoring 

The  knowledge  on  biodiversity  and  ecosystem  health  in  EU  rivers,  lakes,  transitional  and  coastal 
waters has generally improved significantly. This is the result of better monitoring and assessment 
of  ecological  status  of  surface  water  bodies  which  has  been  enabled  by  a  general  increased 
coverage of water bodies and water quality elements monitored29. This has allowed to better assess 

28 For operational monitoring (results of which are used for status classification, only the parameters indicative of the 
biological quality element (s) most sensitive to the pressures to which the water bodies are subject, must be monitored. 
29 It should be noted however that because lack of electronic reporting, the overview of the monitoring and its coverage 
can be derived for only 13 Member States. 

22 

 
 
the  status  for  an  increased  number  of  water  bodies,  reducing  further  the  uncertainty  present  in 
previous cycle.  

However, major gaps in ecological status monitoring remain, both in terms of spatial coverage and 
assessment confidence.  

One of the most evident conclusions is that the monitoring approaches are very different between 
the  Member  States.  This  diversity  can  be  seen  in  the  practices,  frequencies  of  monitoring  and 
parameters measured by the Member States. It can also be seen in the very different approaches 
pertaining to grouping of water bodies30 and the use of expert judgement replacing empirical and 
quantitative measurements. 

Overall, monitoring of quality elements in each water category is patchy at best, overly relying on 
grouping of several different water bodies and expert judgment, rather than on a more thorough and 
empirical assessment of each relevant water body under the specific WFD parameters. Modelling is 
increasingly being used by Member States, potentially contributing, if well done, to provide a robust 
picture for larger areas and longer time periods with connection to various hydrological conditions, as 
well  as  the  impact  of  changing  climate.  However,  models  need  regular  maintanence  to  be  kept 
updated as well as wide and frequent monitoring data of water quality and quantity to be calibrated 
and validated accordingly. 

Selection of quality elements monitored 

Despite improvements, there are still significant gaps in the quality elements monitored in each water 
category.  This  is  particularly  so  for  the  hydromorphological  quality  elements,  but  there  are  still 
significant gaps also in the monitoring of biological and physico-chemical quality elements.  

Overall, regarding biological quality elements, the largest gap in monitoring is seen for angiosperms 
and macroalgae in coastal and transitional water bodies, since only few Member States monitor these 
quality elements. As for hydromorphological quality elements, the largest gaps are noted in coastal 
and transitional water bodies. For example, more than half of the Member States with coastal waters 
do not monitor morphological conditions, and half do not monitor tidal regime. Lastly, for physico-
chemical  quality  elements,  the  largest  gaps  are  noted  for  thermal  and  salinity  conditions31.  A 
summary of the information reported is presented in Table 3-1 below.

30 Whereby monitoring results are extrapolated to a series of water bodies subject to similar pressures/impacts.   
31 Note that salinity conditions of coastal waters are used for the characterisation of water bodies and not assessment of 
status. 

23 

 
 
Table 3-1. Member States that monitor each quality element within each surface water category (green indicates the quality element that is required by the WFD 
to be monitored for classification of each surface water category, grey indicates the quality element that is not required by the WFD to be monitored for 
classification of each surface water category) 

24 

 
Quality Element 

Rivers 

Phytoplankton 

Macrophytes 

Phytobenthos 

Benthic 
invertebrates 

Fish 

Austria, Belgium, Czechia, Germany, 
Estonia, Croatia, Lithuania, Latvia, 
Romania 

Austria, Belgium, Czechia, Germany, 
Estonia, Spain, France, Croatia, Italy, 
Lithuania, Latvia, Romania 
Austria, Belgium, Czechia, Germany, 
Estonia, Spain, France, Croatia, Italy, 
Lithuania, Latvia, Romania 
Austria, Belgium, Czechia, Germany, 
Estonia, Spain, France, Croatia, Italy, 
Lithuania, Latvia, Netherlands, 
Romania 
Austria, Belgium, Czechia, Germany, 
Estonia, Spain, France, Croatia, Italy, 
Lithuania, Latvia, Netherlands, 
Romania 

Lakes 
Austria, Belgium, Czechia, Germany, 
Estonia, Spain, France, Croatia, Italy, 
Lithuania, Latvia, Netherlands, 
Romania 
Austria, Belgium, Germany, Estonia, 
Spain, France, Croatia, Italy, Lithuania, 
Latvia, Romania 

Coastal 

Transitional 

Belgium, Germany, Estonia, Spain, 
France, Croatia, Italy, Lithuania, 
Latvia, Netherlands, Romania 

Belgium, Spain, France, Croatia, 
Italy, Lithuania, Latvia, 
Netherlands, Romania 

Lithuania 

Belgium, France, Italy, Lithuania 

Belgium, Germany, Estonia, Croatia, 
Italy, Lithuania, Romania 

Lithuania 

Lithuania 

Austria, Belgium, Germany, Estonia, 
Spain, Croatia, Italy, Lithuania, Latvia, 
Netherlands, Romania 

Belgium, Germany, Estonia, Spain, 
France, Croatia, Italy, Lithuania, 
Latvia, Netherlands, Romania 

Belgium, Germany, Spain, France, 
Croatia, Italy, Lithuania, Latvia, 
Netherlands, Romania  

Austria, Germany, Estonia, France, 
Croatia, Italy, Lithuania, Latvia, 
Netherlands, Romania 

N/A 

Angiosperms 

Macroalgae 

N/A 

N/A 

N/A 

N/A 

Other aquatic flora  Germany, Netherlands 

Germany, Spain, Netherlands 

Germany, Estonia, Spain, France, 
Croatia, Italy 
Germany, Estonia, Spain, France, 
Croatia, Italy, Lithuania, Latvia 
Germany, Spain, Lithuania, 
Netherlands, Romania 

Hydrological 
tidal regime 

or 

Continuity 

River 
conditions 

Austria, Czechia, Germany, Estonia, 
Spain, France, Croatia, Italy, Lithuania, 
Latvia, Romania 
Austria, Czechia, Germany, Estonia, 
Spain, France, Croatia, Italy, Lithuania, 
Latvia, Romania 

Austria, Czechia, Germany, Estonia, 
Spain, France, Croatia, Italy, Lithuania, 
Latvia, Romania 

Germany, France, Romania, 

Germany, France, Italy, Romania 

Estonia, France, Romania 

France 

France 

Morphological 
conditions 

Austria, Belgium, Czechia, Germany, 
Estonia, Spain, France, Croatia, Italy, 
Lithuania, Latvia, Romania 

Austria, Czechia, Germany, Estonia, 
Spain, France, Croatia, Italy, Lithuania, 
Latvia, Romania 

Germany, Estonia, Spain, France, 
Croatia, Italy, Romania 

Belgium, Germany, Spain, France, 
Croatia, Italy, Romania 

25 

Belgium, Germany, Spain, France, 
Croatia, Italy, Lithuania, 
Netherlands  

Spain, France, Croatia, Lithuania 

France, Lithuania 

Germany, Lithuania, Netherlands 

l
a
c
i
g
o
l
o
i
B

l
a
c
i
g
o
l
o
h
p
r
o
m
o
r
d
y
H

 
 
 
l
a
c
i
m
e
h
C
-
o
c
i
s
y
h
P

Transparency 
conditions 

Belgium, Germany 

Thermal conditions 

Oxygenation 
conditions 

Salinity conditions 

Acidification 
status 

Nitrogen conditions 

Phosphorus 
conditions 

Belgium, Czechia, Germany, Spain, 
France, Croatia, Italy, Netherlands, 
Romania 
Belgium, Czechia, Germany, Estonia, 
Spain, France, Croatia, Italy, Lithuania, 
Latvia, Netherlands, Romania 
Belgium, Germany, Spain, Croatia, 
Italy, Netherlands, Romania 
Belgium, Czechia, Germany, Estonia, 
Spain, France, Croatia, Italy, 
Netherlands, Romania 
Belgium, Czechia, Germany, Estonia, 
Spain, France, Croatia, Italy, Lithuania, 
Latvia, Netherlands, Romania 
Belgium, Czechia, Germany, Estonia, 
Spain, France, Croatia, Italy, Lithuania, 
Latvia, Netherlands, Romania 

Czechia, Germany, Estonia, Spain, 
France, Croatia, Italy, Lithuania, 
Latvia, Netherlands 

Germany, Estonia, Spain, France, 
Croatia, Italy, Lithuania, Romania 

Spain, Croatia, Italy, Romania 

Czechia, Germany, Spain, Croatia, 
Italy, Netherlands 

France, Croatia, Italy, Netherlands, 
Romania 

Netherlands, Romania 

Belgium, Czechia, Germany, Spain, 
France, Croatia, Italy, Netherlands 

Germany, Spain, France, Croatia, 
Italy, Netherlands, Romania 

Belgium, Spain, France, Croatia, 
Italy, Latvia, Netherlands, Romania 

Belgium, Germany, Spain, Croatia, 
Italy, Netherlands 
Belgium, Czechia, Germany, Estonia, 
Spain, Croatia, Italy, Netherlands, 
Romania 
Belgium, Germany, Estonia, Spain, 
France, Croatia, Italy, Lithuania, 
Latvia, Netherlands, Romania 
Belgium, Czechia, Germany, Estonia, 
Spain, France, Croatia, Italy, Lithuania, 
Latvia, Netherlands, Romania 

Croatia, Italy, Romania 

Croatia, Romania 

Italy, Romania 

Belgium, Spain, Romania 

Belgium, Germany, Estonia, Spain, 
France, Croatia, Italy, Lithuania, 
Latvia, Netherlands, Romania 
Belgium, Germany, Estonia, Spain, 
France, Croatia, Italy, Lithuania, 
Latvia, Romania 

Belgium, Germany, Spain, France, 
Croatia, Italy, Lithuania, Latvia, 
Netherlands, Romania  
Belgium, Germany, Spain, France, 
Croatia, Italy, Lithuania, Latvia, 
Romania 

Source: third RBMPs electronic reporting by 

(Austria, Belgium, Czechia, Germany, Estonia, Spain, France, Croatia, Italy, Lithuania, Latvia, Netherlands, Romania)

26 

 
 
Considering only the 13 Member States that reported information electronically for which the data is easily 
retrievable and comparable, Figure 3-1 reflects the number of Member States that monitor biological quality 
elements  for  different  types  of  water  bodies.  It  is  clear  that  some  aquatic  plants  (macrophytes, 
phytoplankton,  invertebrates  and  fish)  are  the  most  monitored  while  large  differences  between  Member 
States appear for other biological quality elements. It should be noted that, for the purpose of operational 
monitoring (used for status classification), Member States have to monitor the quality  elements that are 
most  sensitive  to  the  pressures  to  which  the  water  bodies  are  subject;  whereas,  for  the  purpose  of 
surveillance monitoring (carried out during one year of the six year cycle, to determine changes in pressures 
and impacts and inform the operational monitoring programmes), all quality elements should in principle be 
monitored.  

Figure 3-1. Number of Member States that monitor each biological quality element for rivers, lakes, coastal, and 
transitional water bodies 

s
e
t
a
t
S

r
e
b
m
e
M

f
o

r
e
b
m
u
N

12

10

8

6

4

2

0

Phytoplankton Macrophytes

Phytobenthos

Benthic
invertebrates

Fish

Angiosperms

Macroalgae

Other aquatic
flora

Rivers

Lakes

Coastal

Transitional

Source: third RBMPs electronic reporting 

Additionally, the coverage of the monitoring of biological quality elements, regarding the number of water 
bodies, is depicted  in  Figure  3-2 below. It is worth noting that there are some  elements which are being 
monitored, i.e. fish in coastal waters and macroalgae in rivers and lakes, although it is not required by the 
WFD. 

27 

 
 
 
 
 
Figure 3.2. The average proportion (% of number water bodies) of the monitoring of biological quality elements 
for rivers, lakes, coastal waters, and transitional waters 

Source: third RBMPs electronic reporting 

Figure 3-3 depicts the monitoring of hydromorphological quality elements for the 13 Member States that 
reported electronically. 

Figure 3-3. Number of Member States that monitor various hydromorphological quality elements for rivers, 
lakes, coastal, and transitional water bodies (Note: Continuity conditions are mandatory for Rivers only) 

Source: third RBMPs electronic reporting 

28 

 
 
 
Finally, in relation to the monitoring physico-chemical quality elements, Figure 3-4 below depicts the number 
of Member States which are monitoring each physico-chemical quality element, depicted to water categories.  

Figure 3-4. Number of Member States that monitor each physico-chemical quality element for rivers, lakes, 
coastal, and transitional water bodies. 

s
e
t
a
t
S
r
e
b
m
e
M

f
o
r
e
b
m
u
N

12

10

8

6

4

2

0

Transparency
conditions

Thermal
conditions

Oxygenation
conditions

Salinity
conditions

Acidification
status

Nitrogen
conditions

Phosphorpus
conditions

Rivers

Lakes

Coastal

Transitional

Source: third RBMPs electronic reporting 

Status assessment 

Overall, the ecological status or potential of EU water bodies has not significantly improved as compared 
to  the  previous  cycles  (Figure  3-5).  Comparing  the  same  set  of  (both  electronically  and  PDF  reported) 
Member States between the two cycles, the Commission concludes that in the third RBMPs, 39,5% of surface 
water bodies in Europe were in good ecological status or potential32 which is about the same as in the previous 
report in 2015 (39.1%). 

In general,  lakes and coastal waters are in better status than rivers and transitional  waters. The nutrient 
loads are causing a significant pressure on surface waters leading to eutrophication of wate bodies. According 
to the 2021 reporting on Nitrates Directive, at EU level, 36% of river stations and 32% of lake stations, 31% 
of coastal and 32% of transitional water stations are reported as eutrophic.33 

Unsurprisingly, the ecological status of natural water bodies is generally better than the  status of heavily 
modified and artificial water bodies. 

32 Good Ecological Potential is the objective to be reached by a heavily modified or artificial water body. 
33 See the Report of the European Commission on the implementation of the Nitrates Directive from 2021, page 5, available at 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021DC1000.  

29 

 
 
 
 
 
 
Figure 3-5. Change in ecological status assessment of EU’s surface water bodies from first, second and third 
RBMPs (source: WISE freshwater and PDF data mining) 

It  must  be  noted  that  the  comparability  between  cycles  is  hampered  by  the  changes  in  the  number  and 
redelineation  (e.g.  new  water  body  type)  of  water  bodies,  as  well  as  in  monitoring  methodologies  and 
parameters in many Member States. 

When comparing the third RBMP with the second (see Table 3-2 below), the biggest improvement in ecological 
status  has  been  observed  in  Latvia  (+11.4%),  Sweden  (+4.2%),  Hungary  (+3%),  Austria  (+2.8%),  Spain 
(+2,2%)  and  Finland  (+2.1%).  However,  a  significant  reduction  in  the  number  of  water  bodies  in  good 
ecological status or potential was reported by Poland (-22.9%), Lithuania (-5.5%), Slovakia (-14.9%), Czechia 
(-13.3%), Croatia (-9.1%) and Estonia (-7.6%). These changes can partially be explained by changes in the 
number and in the characteristics of the water bodies as well as by a much better knowledge of the status 
of various quality elements of their water bodies compared to the second RBMPs rather than to an actual 
deterioration. 

Table 3-2. Ecological status/potential of water bodies (% of all water bodies) in each Member State for both the 
second and third RBMPs. (Source: electronic reporting and PDF mining)  

Member State 

EU proportion 

Austria 

Belgium 

Croatia 

Czechia 

Denmark 

Estonia 

Finland 

second RBMPs 

third RBMPs 

High/Good 

Moderate/ 
Less 

Unknown 

High/Good 

Moderate/ 
Less 

Unknown 

Change in good 
status 
in  % 
points 

39.1% 

46.6% 

26.2% 

42.1% 

19.2% 

28.2% 

60.1% 

73.2% 

56.4% 

52.1% 

71.1% 

57.9% 

79.1% 

47.9% 

39.7% 

25.3% 

4.5% 

1.3% 

2.7% 

0.0% 

1.7% 

23.8% 

0.1% 

1.4% 

30 

39.5% 

49.3% 

27.4% 

33.0% 

5.9% 

29.9% 

52.6% 

75.3% 

57.1% 

49.4% 

70.5% 

66.8% 

94.1% 

57.8% 

47.4% 

24.6% 

3.4% 

1.2% 

2.1% 

0.2% 

0.0% 

12.3% 

0.0% 

0.1% 

0.4% 

2.8% 

1.1% 

-9.1% 

-13.3% 

1.7% 

-7.6% 

2.1% 

 
 
France 

Germany 

Hungary 

Italy 

Latvia 

Lithuania 

Luxembourg 

The Netherlands 

Poland 

Romania 

Slovakia 

Spain 

Sweden 

44.2% 

8.1% 

8.3% 

41.8% 

21.1% 

51.9% 

2.7% 

0.3% 

31.2% 

66.1% 

56.2% 

55.6% 

36.8% 

55.5% 

89.1% 

78.3% 

39.8% 

78.9% 

48.1% 

97.3% 

99.3% 

68.7% 

33.7% 

43.8% 

42.3% 

63.2% 

0.4% 

2.8% 

13.5% 

18.4% 

0.0% 

0.0% 

0.0% 

0.4% 

0.0% 

0.2% 

0.0% 

2.1% 

0.0% 

43.6% 

9.3% 

11.3% 

43.6% 

32.5% 

36.4% 

0.0% 

0.0% 

8.4% 

66.6% 

41.3% 

57.8% 

41.0% 

56.1% 

88.8% 

88.7% 

46.8% 

67.5% 

63.6% 

100.0% 

99.7% 

63.7% 

33.4% 

58.7% 

41.4% 

59.0% 

0.3% 

1.9% 

0.0% 

9.7% 

0.0% 

0.0% 

0.0% 

0.3% 

27.9% 

0.0% 

0.0% 

0.9% 

0.0% 

-0.6% 

1.1% 

3.0% 

1.8% 

11.4% 

-15.5% 

-2.7% 

-0.3% 

-22.9% 

0.4% 

-14.9% 

2.2% 

4.2% 

Notwithstanding the overall lack of progress, there is clear evidence of some improvement in some individual 
biological  and  chemical  quality  elements  underpinning  the  good  ecological  status  which  may  reflect  the 
positive  effects  of  measures  taken  during  the  previous  planning  cycles.  According  to  the  EEA  State  of 
European Waters 2024, the status of phytoplankton, benthic flora, and invertebrates has improved in lakes34, 
while rivers and transitional waters have seen improvements in benthic invertebrates35. This confirms that 
some of the key measures taken in the previous RBMPs, especially improving wastewater treatment which 
has  contributed  significantly  to  reduced  organic  pollution  and  nutrients,  have  had  an  immediate  positive 
effect. At the same time, pressure caused by diffuse pollution remains significant, especially from agriculture, 
and there is growing concern on the impacts of emerging chemical pollutants on aquatic ecosystems and on 
the  ecological  status  of  surface  waters.  These  partial  improvements,  while  notable,  are  not  sufficient  to 
improve  the  overall  ecological  status  of  water  bodies  and  to  reduce  the  associated  risk  to  health  and 
environment. This also implies that these improvements tend to be overlooked since the WFD applies a “one 
out  all  out”  approach  which  implies  that  a  water  body  can  only  achieve  good  status  if  all  biological  and 
supporting quality elements are assessed at least as good.  

This may explain, at least partially, why the assessment of the ecological status in the third RBMPs for the 
period 2022-202736 shows an overall limited improvement in comparison to the second RBMPs (covering the 
2009-2015 period). In addition, as already outlined, this lack of progress can be due to:  

•  an increase in knowledge and accuracy,  
•  a possible exacerbation of pressures on water,  
• 
• 

inefficient or inadequate measures or  
lack of progress in putting the planned measures in motion. 

It is difficult, on the basis of the information provided, to ascertain among these reasons which is the main 
one and this largely varies from country to country. 

34 Based on lakes in western, eastern, central and southern Europe, due to data missing from SE and FI. 
35 EEA Report 7/2024, Europe's state of water 2024. The need for improved water resilience published on 15 Oct 2024 
(https://www.eea.europa.eu/en/analysis/publications/europes-state-of-water-2024). 
36 It should be noted that MS preparations for the 3rd RBMPs started in 2018 hence this document are based on data collected up 
to 2018. This means that the data submitted to the Commission may not reflect possible positive impact of actions taken in 
subsequent years, as well as the effect of action taken by the EU in the context of the European Green Deal. 

31 

 
 
Comparability of results may also be affected by the fact that Member States use different approaches to 
river basin specific pollutants (RBSPs) which should be identified by individual Member States and should 
be used to support the assessment of ecological status. For instance, while the Netherlands is monitoring 
dozens of substances of national relevance, other Member States have only identified and monitor a much 
more limited subset of RBSPs and/or monitoring them in a  small proportion of  all water bodies. There is 
generally limited information in the reports on the subject and it is generally unclear to what extent these 
substances are considered in the status assessment. 

As regards expectations in relation to the achievement of good ecological status by 2027, most Member 
States do not expect to meet the good ecological status or potential for all their water bodies.  The more 
optimistic are Austria, Romania, and Spain, while Croatia, Czechia, Germany and the Netherlands have the 
lowest  expectations. All these estimates are based on  different assumptions of the achievement of WFD 
objectives and they already anticipate, to a certain extent, the intention of the Member State on making use 
of Article 4 WFD exemptions in the 4th RBMPs.  

3.1.2  Hydromorphological changes and artificialization (HMWBs and AWBs) 

For hundreds of years, human activities in Europe have physically changed the shape of our rivers, lakes, 
estuaries and coastal waters by eliminating natural features, introducing concrete infrastructures (i.e. heavily 
modified water bodies), or creating  new canals or reservoirs (i.e. artificial water bodies) which all resulted in 
new, but non-natural water systems. 

Heavily  Modified  Water  Bodies  (HMWBs)  are  bodies  of  water  which,  because  of  physical  alterations  by 
human activity, are substantially changed in character and cannot, therefore, meet "good ecological status" 
(GES). Artificial Water Bodies (AWB) are water bodies created by human activity. Instead of "good ecological 
status",  the  environmental  objective  for  HMWB  and  for  AWB  is  Good  Ecological  Potential  (GEP)37.  In 
addition, according to WFD Article 4(3), the designations of HMWBs and AWBs and the reasons for them shall 
be specifically mentioned in the RBMPs and reviewed every six years.  

All Member States describe a methodology for designating HMWB/AWB, albeit with different levels of detail. 
Many Member States (in particular Austria, Czechia, Finland, France, Hungary, Romania, Spain, and Sweden) 
made updates to the methodologies used for the designation.  

The RBMPs show a very big difference among Member States on the degree of human intervention on surface 
waters. The proportion of heavily modified water bodies and artificial water bodies has slightly increased 
in third RBMPs, with 12.4% of water bodies designated as heavily modified and 4.4% as artificial in the 20 
Member States considered in the analysis compared to 11.9% and 4.1% in the second RBMPs. Figure 3-6 
below reveals the very high level of human intervention in some Member States (e.g. Netherlands, Hungary, 
Germany, and Belgium) and the pronounced naturalness remaining in some others (e.g. Finland and Sweden).  

Three  Member  States  (Austria,  Croatia,  Slovakia)  reported  significant  increases  in  the  number  of 
HMWBs/AWBs. This could be partly due to changes in the classification of certain water bodies, rather than 
introduction of new alterations to the physical or hydrological characteristics. Designation of HMWBs/AWBs 
is still in progress in both Croatia and Slovakia, while Sweden has recently revised its methodology and an 
increase in the number of HMWBs is expected in Sweden’s 4th RBMPs. 

37 Good Ecological Potential is the objective to be reached by a heavily modified or artificial water body. 

32 

 
 
Figure 3-6. Percentage of surface water bodies that have been designated as heavily modified or artificial in 
the third (2021) RBMPs by Member State 

The main uses for which water bodies have been designated as heavily modified (see figure 3-7 below) are 
flood protection (37%), agriculture (land drainage 23%, irrigation 15%), hydropower (21%), drinking water 
supply (11%) and other urban development (10%). Other uses are represented in less than 10% of HMWBs. 
Uses  behind  designation  of  artificial  water  bodies  are  not  reported  in  WISE.  According  to  the  electronic 
reporting  which  covering  13  Member  States,  the  main  physical  alterations  behind  designation  are 
channelisation,  straightening,  bed  stabilisation,  and  bank  reinforcement  affecting  58%  of  water  bodies 
designated as HMWBs, as well as weirs, dams, and reservoirs affecting 51%. These two main groups are 
followed  by  land  reclamation  (19%),  dredging  /  channel  maintenance  (11%),  land  reclamation  /  coastal 
modifications / ports (7%) and locks (2%). Other physical alteration is reported for 9% of HMWBs. 

33 

 
 
Figure 3-7. Activities for which surface water bodies have been designated as heavily modified or artificial in 
the third RBMPs  

Good Ecological Potential (GEP) - the objective to be reached in heavily modified or artificial water body - is 
a less stringent objective than GES38. Indeed, it caters for ecological impacts resulting from those physical 
alterations that (i) are necessary to support a specified use or (ii) must be maintained to avoid adverse effects 
on the wider environment. The assessment revealed some methodological improvements on the way Member 
States assess when a heavily modified water body or an artificial water body can be considered to have 
achieved Good Ecological Potential. Poland has developed a new methodology while improvements were 
made in other Member States (e.g. in Czechia and various French RBDs) by adding new quality elements or 
updating the class boundaries. It is noted positively that most Member States now report comparison of GEP 
and GES, while in the second RBMPs only half of them did so. 

As regards the achievement of good ecological potential for heavily modified water bodies, based on the 
information reported to WISE by the time of preparing this report, it is noted that only 16.8% of these water 
bodies are in GEP. There are nevertheless big differences among Member States (ranging between none of 
the HMWBs reaching GEP in Belgium and the Netherlands to about half of the relevant water bodies in Spain 
and Romania).  

Taking into account the estimations provided by Member States, GEP is expected in 53% of HMWBs in 2027, 
with very big differences among countries (from only 2% in the Netherlands to 100% in Estonia). That leaves 

38 Article 4(3) WFD allows to set lower objectives to the quality elements which are sensitive to impacts caused by uses behind the 
designation of a water body as heavily modified or artificial. 

34 

 
 
 
around  40%  for  which  GEP  will  be  achieved  beyond  2027.  Some  HMWBs  are  also  reported  in  the  “less 
stringent objective already achieved” and “unknown” categories.  

As regards artificial water bodies, GEP is already achieved in 16% of these water bodies. Again, difference 
among countries are significant with 0% in the Netherlands to 88% in Estonia. In 2027, GEP is expected in 
29% of AWBs (ranging from only 4% in Belgium and to 100% in Estonia and Spain), while in 61% GEP is 
expected to be achieved after this date. Some AWBs were also reported in the “less stringent objective already 
achieved” and “unknown” categories. 

Measures for achieving GEP are reported in all Member States where GEP has been defined. They relate to 
“restoration of bank structure”, “fish ladders”, “setting of ecological flows” and “removal of structures” that 
are applied to more than 40% of RBDs . More than 30% of RBMPs also reported “habitat restoration, building 
spawning and breeding areas”, “restoration of modified bed structure” and “sediment/debris management”. 
Some Member States provided information in their RBMPs or background documents regarding the expected 
ecological  improvements,  though  these  are  mainly  qualitative  given  the  persistent  challenge  faced  by 
Member States as regards the quantification of the expected impacts of measures. 

3.1.3  Groundwater bodies - have they sufficient water – quantitative status 

The Water Framework Directive establishes several criteria to define when a groundwater body is in good 
quantitative status. These are:  

• 

• 

the  available  groundwater  resource  is  not  exceeded  by  the  long-term  annual  average  rate  of 
abstraction; and  
the  groundwater  levels  and  flows  are  sufficient  to  meet  environmental  objectives  for  associated 
surface waters and groundwater dependent terrestrial ecosystems (GWAAES); and  

•  anthropogenic alterations to flow direction resulting from level change does not cause saline or other 

intrusion.  

Monitoring 

Also as regards the monitoring of the quantitative status of groundwater bodies, the assessment confirms a 
general improvement with an increased coverage of the number of water bodies and in some cases also an 
increase  in  the  number  of  monitoring  sites.  Monitoring  is  very  often  done  in  situ,  rather  than  through 
modelling or expert judgement as it is the case for other types of monitoring. This shows the importance is 
given by the Member States to have an accurate picture of the reserves they have of groundwater to feed 
the different societal needs.  

Status Assessment 

As  regards  the  quantitative  status  of  groundwaters,  comparing  the  same  set  of  Member  States,  it  is 
encouraging to observe a small improvement with 95% of groundwater bodies being reported in good status 
as compared to 92.4% in 2015. The data reported  shows that largely the replenishment of groundwater 
bodies, a big share of the EU’s reserves, appears mostly secured. It needs to be stressed however that not 
all  Member  States  adequately  consider  the  needs  of  groundwater-dependent  ecosystems,  and  that  this 
picture taken in 2021 does not capture the impacts of subsequent years which have been the driest this 
century.  

35 

 
Figure 3-8. Change in the quantitative status assessment of EU’s groundwater bodies from first, second and 
third RBMPs (source: WISE freshwater and PDF data mining) 

GWB quantitative status for EU average

3rd

2nd

1st

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Good

Poor

Unknown

This may be an indication that climate change has not (yet) affected the groundwater across the EU. There 
are nevertheless significant geographical variations across the EU which can be seen in Figure 3-9 below. 
Furthermore, it is important to flag that this analysis does not cover countries such as Cyprus, Greece and 
Malta where achieving good quantitative status was a challenge in the second RBMPs. 

 Figure 3-9. Overview quantitative status for groundwater bodies by Member States in 2021

When comparing the data from the third RBMP with the ones from the second (see Table 3-3 below), it can 
be  observed  that  5  Member  States  (Austria, Luxembourg,  Lithuania,  Latvia  and  Romania)  confirmed  that 
100% of their groundwater bodies were in good quantitative status. As regards other countries, the biggest 

36 

 
 
 
improvement in the quantitative status has been observed in Czechia (+24,7%), Slovakia (+20%), and Italy 
(+18,4%), while a noticeable worsening is reported by the Netherlands (-4.3%), Estonia (-3.9%), Belgium (-
2.3%).  The  situation  remained  largely  stable  for  most  of  the  other  Member  States  with  either  a  slight 
improvement or reduction of the share of the bodies in good quantitative status. However, even countries 
which  report  that  all  their  GWBs  have  sufficient  water  for  the  moment,  they  also  report  pressures  are 
increasing for some water bodies and that they are at risk of failing to achieve good status in the future.  

Table 3-3. Quantitative status of groundwater bodies in each Member State for both the second and third 
RBMPs. (Source: third RBMPs electronic reporting and PDF mining)  

Member 
State 

EU proportion 

AT 

BE 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

HR 

HU 

IT 

LT 

LU 

LV 

NL 

PL 

RO 

SE  

SK 

second RBMPs 

third RBMPs 

Good 

Poor 

Unknown  Good 

Poor 

Unknown 

Difference in 
good status in % 
points 

92.4% 

100.0% 

90.0% 

69.0% 

95.7% 

99.3% 

97.4% 

75.7% 

98.3% 

89.8% 

97.0% 

80.0% 

61.0% 

100.0% 

100.0% 

100.0% 

100.0% 

92.7% 

100.0% 

99.7% 

70.6% 

4.5% 

0.0% 

10.0% 

9.8% 

4.3% 

0.7% 

2.6% 

24.3% 

0.1% 

10.2% 

3.0% 

20.0% 

14.4% 

0.0% 

0.0% 

0.0% 

0.0% 

7.3% 

0.0% 

0.3% 

2.9% 

3.1% 

0.0% 

0.0% 

21.3% 

0.0% 

0.0% 

0.0% 

0.0% 

1.6% 

0.0% 

0.0% 

0.0% 

24.6% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

26.5% 

95.3% 

100.0% 

87.7% 

93.7% 

95.2% 

99.6% 

93.5% 

74.6% 

99.9% 

88.1% 

98.0% 

80.0% 

79.4% 

100.0% 

100.0% 

100.0% 

95.7% 

91.4% 

100.0% 

99.2% 

90.6% 

4.5% 

0.0% 

12.3% 

6.3% 

4.8% 

0.4% 

6.5% 

25.4% 

0.0% 

11.8% 

2.0% 

20.0% 

19.1% 

0.0% 

0.0% 

0.0% 

4.3% 

8.6% 

0.0% 

0.8% 

9.4% 

0.1% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.1% 

0.1% 

0.0% 

0.0% 

1.5% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

2.9% 

0.0% 

-2.3% 

24.7% 

-0.5% 

0.3% 

-3.9% 

-1.1% 

1.6% 

-1.7% 

1.1% 

0.0% 

18.4% 

0.0% 

0.0% 

0.0% 

-4.3% 

-1.3% 

0.0% 

-0.5% 

20.0% 

37 

 
 
 
 
 
There are different reasons which lead to failing to achieve good status and these are depicted in Figure 3-
10 below. 

Figure 3-10. Mains reasons for failing good quantitative status for groundwaters 

Water balance / Lowering water table

84%

Saline or other intrusion

25%

Associated surface waters

20%

Dependent terrestrial ecosystems

9%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

It must be noted, that at this point an assessment of the impacts of current and future climate change is not 
part of the tests for good quantitative status. 

Almost all MS undertook a water balance assessment39 for the third RBMPs, apart from Luxembourg which 
reports that this test will be completed by the end of the period.  

The assessment of long-term trends in groundwater levels was undertaken by the Netherlands, Austria, 
Luxembourg, Germany, Spain, Finland, France, Hungary, Italy, Poland, Slovakia, Belgium, Croatia and Romania.  
Czechia, Lithuania and Latvia did not carry out this part of the groundwater quantitative status assessment 
tests, and it was not mentioned by Denmark, Estonia and Sweden.  

However, contrary what the WFD requires, when assessing the quantitative status of groundwater bodies 
Member  States  do  not  always  consider  the  needs  of  the  groundwater  associated  aquatic  ecosystems 
(GWAAEs)  and  groundwater  dependent  terrestrial  ecosystems  (GWDTEs).  This  is  very  important  for 
ecosystem and species conservation and for stopping biodiversity loss. However, while some Member States 
did consider GWAAEs, GWDTEs and saline or other intrusions, others did so only partially or only in some 
RBDs, and many Member States have not taken all these factors into account when determining quantitative 
status. This represents a major gap that neglects the water needs of nature, since manmade alterations of 
groundwater  levels  may  have  major  impacts  on  the  status  of  surface  water  bodies  or  damage  precious 
ecosystems such as wetlands. 

It needs to be pointed out that throughout the past three implementation cycles Member States reported a 
high proportion of groundwaters , as being in good quantitative status. However, this sits in contrast with the 
increase in water scarcity across the EU and the observed increased reliance on groundwater bodies as source 
of  supply  for  public  services  and  irrigation  which  is  leading  to increased  abstractions40.  This  stresses the 

39 A water balance is the amount of water available for allocation, counted as inflows minus outflows in a given river (sub-)basin. 
40 According to the EEA, groundwater share of the total water abstraction has increased from 19% in 2000 to 23% in 2019. See 
section 3.6 for additional information. 

38 

 
 
 
importance  for  Member  States  to better  apply  agreed  methodologies  for  the  assessment  of  quantitative 
status to adequately consider seasonal variations and the impacts of climate change, while relying less on 
historical trends and fully considering the role of groundwater contribution to support rivers and ecosystems. 
An assessment solely relying on groundwater levels is not sufficient41. It also indicates, as also suggested by 
the EEA, the potential need to revise existing methodologies. 

Significantly, the number of groundwater bodies reported by Member States as at risk of not achieving good 
quantitative status by 2027 reflects an expected worsening of the situation by several Member States (see 
figure 3-11 below). 

Figure 3-11. Percentage of groundwater bodies that Member States report as at risk of not achieving good 
quantitative status by 2027 (only countries with e-reporting) 

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

The WFD requires Member States to establish a register or registers of all areas lying within each RBD which 
have been designated as requiring special protection under relevant EU legislation and where additional or 
more stringent objectives may be needed to achieve its objectives, as well as the objectives enshrined in 
other relevant EU legislation. 

All 20 Member States have reported the number of water bodies associated with protected areas according 
to a range of relevant Directives, as presented in the table 3-4 below. 

Overall, in this reporting cycle most Member States have reported a higher number of water bodies associated 
with protected areas designated under other EU legislation and have in place a register of protected areas 
which has been updated in the third RBMPs. Yet, most Member States provided only general information.  

However,  the  comparison  between  the  number  of  protected  areas  with  the  previous  cycle,  is  somewhat 
difficult. In the second RBMPs Member States reported the number of protected areas, whereas in the third 
RBMPs the focus has been on the number of water bodies associated with protected areas. 

41 See Common Implementation Strategy Guidance note n.18. 

39 

 
 
 
Table 3-4 Overview of the number of water bodies associated with protected areas per Member State  

Bathing 
waters 

Drinking 
water 
protection 
area 

Freshwater 
fish 
designated 
water 

Nationally 
designated 
Area (CDDA) 

Natura 
2000 

Nitrate 
vulnerable 
zones 

Nutrient 
sensitive 
areas 

Shellfish 
areas 

Austria 

50 

Belgium 

4 

Croatia 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Hungary 

Italy 

Latvia 

Lithuania 

Luxembourg 

Netherlands 

Poland 

Romania 

Slovakia 

Spain 

Sweden 

Monitoring 

82 

100 

0 

0 

206 

733 

429 

0 

260 

0 

58 

3 

86 

517 

4 

13 

439 

220 

96 

61 

70 

538 

1705 

0 

1107 

1277 

494 

0 

1412 

25 

173 

45 

26 

353 

351 

47 

2537 

1778 

0 

0 

0 

0 

154 

609 

1395 

85 

1336 

842 

269 

24 

1032 

3177 

4509 

7947 

2190 

142 

534 

66 

257 

3789 

whole 
country 
approach  
Whole region 
approach for 
Flanders and 
8 zones of 
Wallonia  
287 

0 

3 

0 

0 

1957 

21 

825 
 whole 
country 
approach 
0 
 whole 
country 
approach 
1955 
 whole 
country 
approach 
65048 

1465 

0 

0 

0 
 whole 
country 
approach 
4240 
whole 
country 
approach 
857 

1097 

4375 

0 

0 

0 

0 

0 

0 

0 

0 

7587 

107 

0 

0 

0 

0 

749 

172 

0 

0 

0 

0 

0 

0 

1327 

536 

23794 

0 

0 

0 

16 

180 

4 

0 

258 

232 

0 

0 

0 

0 

0 

0 

0 

655 

0 

0 

0 

0 

0 

402 

1877 

0 

0 

0 

749 

4239 

9191 

0 

0 

0 

0 

0 

0 

0 

434 

162 

0 

0 

0 

0 

0 

0 

0 

0 

All 20 Member States convey that protected areas are monitored. With some exceptions, there seems to be 
better monitoring of these areas, which in most cases is probably linked to the general improvement in 
monitoring under the WFD. 

In particular, Belgium, Czechia, Germany, Latvia, Spain, and Sweden have implemented a wide coverage of 
monitoring sites that appear to provide ample coverage to the number of protected areas within their country. 
No information has been identified for Denmark, Finland, or Slovakia regarding the number of monitoring 
sites. 

40 

 
  
Yet for most, it is unclear whether the monitoring network used for protected areas is the same than for WFD 
monitoring  or  it  is  additional.  Sweden,  Slovakia,  Netherlands,  and  Luxembourg  have  indicated  that  the 
monitoring of protected areas is additional to the monitoring networks used for the implementation of the 
WFD. 

Status assessment of protected areas 

The  status  of  protected  areas  could  be  assessed  only  for  13  Member  States  (out  of  20  covered  by  this 
assessment) due to the absence of electronic reporting for the other reporting Member States. As it can be 
seen in the Figure 3-12 below, data shows an increase in the number of water bodies associated with 
protected areas in bad status as compared to the previous cycle. 

This could partly be linked to the significant reduction of areas with unknown status since the share of water 
bodies with an unknown status has reduced considerably, especially for groundwater bodies. 

There has been a 10% increase in the bad ecological potential of surface water bodies, as well as a reduction 
of just under 5% in the number of water bodies rated as being in high status since 2015. There has also 
been a slight increase in the number of water bodies designated as poor or moderate status since 2015. 
Again, an increase of roughly 5% for both. 

For  chemical  status  of  surface  water  bodies  designated  as  protected  areas,  15%  are  in unknown  status, 
approximately 48% in good chemical status and around 36% in bad chemical status.  For chemical status of 
groundwater bodies unknown status has decreased by roughly 5% most likely due to increased monitoring 
within EU Member States since 2015. Good status has also decreased by nearly 20% which again could be 
due in part to an increase in monitoring.  For quantitative status of groundwater bodies, the unknown status 
of  water  bodies  has  been  significantly  reduced  and  poor  status  of  groundwater  bodies  has  increased by 
about 5% in protected areas. 

In the vast majority of Member States hence the designation of protected areas does not seem to bring about 
the expected improvements on the state. This suggests that, regrettably, the designation as “protected area” 
does not lead Member States to enhance efforts to protect the surface and ground waters which these areas 
need to flourish. This confirms limited progress in implementation of the Nature Directives compared to the 
2013-2018 period assessed in the 2020 ‘State of Nature’ report, according to which only 17% of protected 
river, lake, alluvial and riparian habitats were in good conservation status and a large majority of protected 
fish  and  amphibian  species  were  in  poor  or  bad  conservation  status  (respectively  80%  and  60%  of  the 
population)42. 

42 State of nature in the EU - Results from reporting under the nature directives 2013-2018; 
https://www.eea.europa.eu/publications/state-of-nature-in-the-eu-2020  

41 

 
 
Figure 3-12. Status of water bodies in protected areas in second and third RBMPs (Source: third RBMP electronic 
reporting) 

3rd Plan Ecological status/potential SWB

2nd Plan Ecological status/potential SWB

3rd Plan Chemical status SWB

2nd Plan Chemical status SWB

3rd Plan Quantitative status GWB

2nd Plan Quantitative status GWB

3rd Plan Chemical status GWB

2nd Plan Chemical status GWB

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

High

Good

Moderate

Poor

Bad

Unknown

Additional objectives 

Water  bodies  associated  with  protected  areas may  need  to  achieve  more  stringent  or  specific  objectives 
compared to the good status objectives set by WFD in order to achieve the level of protection required under 
the relevant legislation for protecting of specific ecosystem, species, drinking or bathing water. 

As  required  by  the  Nature  Directives,  Member  States  have  predominantly  set  up  specific  objectives  for 
habitats and  species  protected  areas  (Natura 2000  sites), although in some cases work is ongoing to 
establish the exact needs. In some cases, Member States have also set additional objectives and measures 
for sensitive areas under the urban wastewater treatment directive, bathing waters and drinking water 
safeguard  zones,  although  the  objectives  or  measures  are  often  reported in somewhat  general  terms43. 
Some Member States with a commercial interest in shellfish production (or less often in freshwater fish) 
have designated protected areas for economically significant aquatic species. These are Croatia, France, 
Italy, the Netherlands, Poland, Romania, Spain and Sweden for shellfish and Croatia, Finland, Italy, Latvia and 
Sweden for freshwater fish.  For the shellfish areas, some Member States (Croatia, the Netherlands Romania and Sweden) 
have set the same objectives that were in the Shellfish Directives, which has since been repealed44. One Member States 

43 For habitats and species protected areas some MS reported measures, while others clearly referred to management plans under 
the relevant directives (Birds and Habitats). In some cases, for these protected areas it is assumed that reaching WFD good status 
is sufficient to meet the additional objectives. 
44 Former Directive 2006/44/EC of the European Parliament and of the Council on the quality of fresh waters needing protection or 
improvement in order to support fish life, and Directive 2006/113/EC of the European Parliament and of the Council of 12 December 
2006 on the quality required of shellfish waters, whose validity ended in 2013. According to the WFD, the level of protection from these 
repealed Directives should be maintained through the inclusion of the areas, designated under the previous Fish and Shellfish directives, 
as protected areas under WFD. 

42 

 
 
 
(France) applies different microbiological standards as compared to the repealed directives for all these areas. While Italy 
and Spain apply the same standards in some areas and different standards in other areas. For Poland, the information on 
standards is unclear. 

Figure 3-13. Objective setting in protected areas per category of protected area 

Source: third RBMP electronic reporting 

Where  additional  objectives  have  been  set,  they  have  been  achieved  predominantly  for  drinking  water 
safeguard zones, shellfish designated areas and bathing waters, while only a minimal part of the objectives 
set for Natura 2000 sites have been achieved. See figure 3-14 below outlines the number of met objectives 
per type of protected area. 

For the Nitrates Vulnerable Zones, the additional measures are rather included in the Action Plans (which 
must be reviewed every 4 years) pursuant to the Nitrates Directive rather than in the RBMPs. About half of 
the Member States designate the whole country as a Nitrates Vulnerable Zones to make the provisions of 
the Nitrates Action Plans mandatory across the whole national territory. 

43 

 
 
 
 
Figure 3-14. Objectives met within different types of protected areas for surface waters 

Source: third RBMP electronic reporting 

3.1.5  What is being done to reduce hydromorphological pressures and restore nature?  

The WFD explicitly requires Member States to manage the effects on the ecological status of water which 
result  from  changes  to  physical  and  hydrological  characteristics  of  water  bodies.  Significant 
hydromorphological  pressures  have  been  identified  in  all  Member  States.  Physical  and  hydrological 
alterations (e.g. abstractions and impoundments) of water bodies as well as barriers are seen as a significant 
pressure in almost all RBDs. Half of surface water bodies (59% of river length and 56% of lake area) are 
affected by significant hydromorphological pressures. Similarly, hydromorpholocial pressure affect 50% of 
transitional water area and 14% of coastal water area. 

The most frequently reported alterations are “physical alteration of channel/bed/riparian area/shore” in 96% 
of RBDs that reported significant pressures, “dams, barriers and locks” (95%), “hydrological alteration” (84%) 
and “other hydromorphological alteration” (44%). 

Hydromorphological pressures should be clearly linked to the main sectors causing them. Figure 3-15 depicts 
that for the electronically reporting Member States these include in particular land drainage in agriculture 
sector, very closely followed by hydropower, flood protection, navigation, irrigation and drinking water, while 
other sectors are represented in less than a quarter of RBDs reporting. However, the pressures are not always 
apportioned to specific sectors. For a third of the  electronically  reporting Member States (Czech Republic, 
Estonia,  France,  Italy,  Latvia),  the  cause  of  the  majority  of  the  significant  hydromorphological  pressures 
remains “unknown” or unqualified (“other”). This shows that understanding such pressures remain a challenge 
in a considerable number of Member States. 

44 

 
 
Figure 3-15. Water sectors/uses causing hydromorphological pressures, percentage of RBDs 

Source: Electronic reporting 

Measures 

All  Member  States45  have  reported  a  variety  of  measures  aimed  at  reducing  the  negative  environmental 
impacts of significant hydromorphological pressures in all their RBDs by improving flow regime, restoring 
river continuity and/or ensure ecological flows. 

45 In six Member States, no key type measures (KTM) to tackle hydromorphological pressures were reported in WISE to date. It is 
noted though that in these Member States, information in the published RBMPs gives evidence that hydromorphological measures 
are planned for the next cycle. 

45 

 
 
 
Figure 3-16. Key Type Measures (KTMs) targeting hydromorphological pressures, percentage of RBDs 

Source: Electronic reporting 

Almost all assessed Member States also have registers of physical modifications in place in all their RBDs 
or at least in a few of their RBDs. In two Member States (Czech Republic, the Netherlands), such register is 
not reported. A register of physical barriers is under compilation in the Netherlands, while such a register 
exists in the Czech Republic, but is not referenced in the RBMPs nor reported. 

As foreseen by the WFD, there must be a periodic revision of permits for abstractions, impoundments and 
other  activities  causing  hydromorphological  alterations.  All  Member  States  assessed  have  a  permitting 
regime, but not always there is a mandatory regular review of permits. 

Measures  to  improve  longitudinal  continuity  (e.g.  establishing  fish  passes,  demolishing  old  dams  and 
removing  other  type  of  barriers)  and  other  hydromorphological  conditions  (e.g.  river  restoration, 
improvement  of  riparian  areas,  removal  of  hard  embankments,  reconnecting  rivers  to  floodplains)  are 
reported in virtually all the Member States. Improving longitudinal continuity is planned in 91% of RBDs and 
improving other hydromorphological conditions in 79% of the RBDs. According to Dam Removal Europe46 – 
a  coalition  of  non-governmental  organizations  –  487  barriers  were  removed  in  15  European  countries in 
2023, a 50% increase on last year’s record number. France appears to be the trailblazer, followed by Spain, 
Sweden, Denmark, and Estonia. While river fragmentation remains a big problem, these measures can also 
contribute to the 2030 target of 25 000 km free-flowing rivers set under the EU Biodiversity Strategy and 
the new Nature Restoration Law. 

While not all the barriers in rivers are related to hydropower production, hydropower plants (HPPs) continue 
to be a significant pressure on ecological status in several Member States, due to disruption of river continuity 
with major impacts on fish migration, fish mortality and changes in the hydrological flows and sediments 

46 New Report: Dam Removal Movement Breaks Barriers and Records - Dam Removal Europe. Data were provided by ministries, 
municipalities, water agencies, river trusts, NGOs, scientists, researchers, and river restoration practitioners. 

46 

 
 
 
movement.  If  the  removal  of  existing  HPP  is  not  possible,  because  of  no  other  technically  feasible  and 
proportionate alternative to achieve the benefits of the existing HPP to the society, refurbishing existing HPPs, 
including  win-win  solutions  for  hydropower  production  and  the  aquatic  environment,  should  be  generally 
prioritised over new HPPs. In the light of the climate change, the operations of such plants should also be 
made more sustainable and adapted to evolving hydrological conditions. This includes the periodic review of 
permits including all mitigation measures to tackle the adverse impacts of HPPs. 

Defining  and  implementing  minimum  ecological  flows  (e-flows)47  is  essential  for  safeguarding  the 
ecological status of surface water bodies. Measures to improve the flow regime, and/or establishment of 
ecological flows are reported by all Member States and cover 79% of the RBDs. However, it seems that the 
work  on  defining  and  implementing  minimum  ecological  flows  is  progressing  slowly  and  that 
notwithstanding  guidance  available  at  EU  level,  there  is  still  a  heterogenous  picture  in  how  e-flows  are 
defined (see Table 3-5 below). With some exceptions, in the majority of Member States, the definition of e-
flows is still being developed/studied . Regrettably, only in some cases, ensuring e-flows seems to be clearly 
linked to the granting and review of abstraction permits. 

Table 3-5. Overview of MS implementation of ecological flows 

Member State 

E-flows 
implemented 

E-flows defined 

Clarifying comment: 

Austria 

Belgium 

Croatia 

unclear 

yes  

E-flow  is  defined  in  Austrian  legislation  (Qualitätszielverordnung 
Ökologie – quality standards) and applies to all uses. 

no 

no 

yes (partly) 

E-flows have been defined partly and not implemented by 2021 

yes (partly) 

E-flows defined on a few rivers, relevant measures to define and 
implement e-flows, as well as to review permits to ensure e-flows, 
are planned in the third RBMP.  

Czechia 

under review 

yes (but under 
review) 

Defined in Art.36 of the Water Act (254/2001) as the minimal flow 
to maintain the ecological functions of flowing watercourses.    

Denmark 

unclear 

unclear 

No  explicit  information  found  in  the  RBMPs.  E-flows  had  been 
derived  in  the  second  RBMP,  but  no  indication  on  continuation 
within the third period has been provided. 

Estonia 

Finland 

yes (partly) 

yes 

Defined and partly implemented, but the work is ongoing and is 
planned to cover all relevant water bodies until 2027.  

no 

yes (partly) 

France 

yes (partly) 

yes (partly) 

Germany 

yes (partly) 

yes (partly) 

Partly  defined  but  not  implemented  by  2021,  relevant  work  to 
complete  definition  and  implementation  is  planned  for  the  next 
cycle.  

Defined and implemented only partly by 2021, relevant work is still 
on-going 

E-flows  were  defined  and  implemented  partly  by  2021,  and 
relevant work is still on-going. 

Hungary 

yes 

yes 

Established on water body level in the second RBMP. The e-flow 
values not changed for the third RBMP. 

47 For the purpose of the WFD, an ecological flow is ‘a hydrological regime consistent with the achievement of the environmental 
objectives in natural surface water bodies as mentioned in Article 4(1)’. In other words, it is the "amount of water required for the 
aquatic ecosystem to continue to thrive and provide the services we rely upon". 

47 

 
 
Italy 

yes (partly) 

yes (in progress) 

Currently  only  minimum  flow.  third  RBMPs  contain  binding 
documents  (“Direttive”)  within  RBMPs,  regarding  definition  and 
implementation of e-flows by 2027.  

yes (hydropower) 

E-flows are defined for all WBs with hydrological pressure due to 
operating HPP, implementation to take place by 2027. 

no 

There are plans to fully define and implement e-flows by 2027.  

Latvia 

Lithuania 

Luxembourg 

The Netherlands 

Poland 

no 

no 

no 

yes 

yes 

yes (simplified) 

yes 

yes 

Romania 

yes (partly) 

yes 

Slovakia 

no 

Spain 

yes (partly) 

no 

yes 

Sweden 

yes (partly) 

yes (partly) 

Further information on e-flow was announced in the second RBMP 
but not identified in the third RBMP. But there was a simplified e-
flow  assessment  as  part  of  the  water  balance  assessment, 
following the LAWA method and the work is ongoing 

not mentioned in the third RBMP, but already implemented in the 
second RBMP 

E-flows  were  defined  and  implemented  by  2021,  based  on  a 
hydrological method, and relevant work is still on-going to update 
this method and include biological aspects 

Defined  for  all  relevant  water  bodies,  being  implemented  in  a 
series  of  situations,  with  the  others  currently  undergoing 
implementation within the water management regulation process  

E-flows  not  defined  and  implemented  during  the  period  2015-
2021. 

Defined  in  all  24  RBDs,  fully  implemented  in  nine  and  partly 
implemented in the remaining 15 

E-flows  have  been  defined  and  implemented  by  the  measure 
“miljöanpassade flöden”, as a hydrological regime consistent with 
the  achievement  of  the  environmental  objectives  of  the  WFD  in 
natural surface water bodies as mentioned in Article 4(1).  

Natural  water  retention  measures  and  nature-based  solutions48  may  deliver  multiple  benefits, 
including  increasing  infiltration  and  reducing  run-off,  but  also  alleviate  pressures  from  hydrological 
alterations, abstractions and flow diversions, and provide natural storage of water for dry periods. Natural 
water  retention  measures  and  other  nature-based  solutions  specifically  addressing  hydromorphological 
pressures are reported in RBDs of about half of Member States that reported in WISE (Belgium, Spain, France, 
Italy, the Netherlands, Romania).  

Only few Member States (Austria, Belgium, France, Latvia, Luxembourg, Poland, Romania) report specifically 
a  national  policy  to  prioritise  nature-based  solutions  over  other  measures.  These  measures  are  also 
reported in the programmes of measures in all assessed Member States as win-win measures in terms of 
achieving the objectives of both the WFD and Floods Directive, as well as for drought management. 

3.1.6  What are Member States doing to reduce abstractions and tackle water scarcity? 

Introduction 

The Member States are required to report under the WFD, if water abstraction causes significant pressure on 
individual water bodies and at RBD level or in significant portions of an RBD. The assessment is based on the 

48 Examples of natural water retention measures, nature-based solutions and green infrastructure include: restoration of 
floodplains, restoration of wetlands, re-meandering of straightened channels, water retention measures, revegetation and buffer 
strips for soil erosion control, etc. 

48 

 
 
Water  Exploitation  Index  plus  (WEI+),  which  estimates  net  consumption49  as  a  percentage  of  renewable 
freshwater resources in an RBD. If water consumption exceeds 20% of renewable freshwater resources in a 
RBD over a long period of time, this may signify the occurrence of water scarcity conditions and, if it exceeds 
40%, water scarcity may be characterised as severe. 

It should be noted that water scarcity is a permanent or seasonally recurrent imbalance of water supply and 
demand that may arises irrespectively of droughts due to unsustainable use of water resources (e.g. over-
allocation  /  over-abstraction).  As  such,  water  scarcity  shall  be  distinguished  from  droughts,  which  are  a 
temporary natural phenomenon, occurring when precipitation, flow and/or soil moisture deviate significantly 
from their long-term average conditions in a region. 

There are significant differences  in water use  across different regions in the EU. EEA’s analysis of water 
abstractions over the period 2000-201950 shows that water abstraction declined overall51, reflecting policy 
measures implemented under  the WFD. However, while  abstraction declined in some sectors, such as for 
cooling in electricity generation (-27%), it increased in others. For instance, water abstraction for cooling in 
manufacturing almost tripled, while abstraction for public water supply increased by 4%, with a particularly 
sharp increase since 2010 (14%). Water abstraction for agriculture decreased overall between 2000 and 
2019. However, since 2010 it has increased by 8%, mainly because of the increasing demand for irrigation 
in southern Europe where water scarcity is exacerbated by climate change. 

In 2019, at EU level, abstraction for cooling in electricity generation w the largest contributor to total annual 
water  abstraction  (32%),  followed  by  abstraction  for  agriculture  (28%),  public  water  supply  (20%), 
manufacturing  (13%)  and  cooling  in  manufacturing  (5%),  with  mining  and  quarrying,  and  construction 
accounting for only 1% of total abstraction each. Looking at net consumption, however, the economic sector 
agriculture is the largest net consumer, as most water abstracted is either consumed by the crop and farm 
animals or evaporates (59% of EU water consumption in 201952), rather than being returned to the same 
source  it  was  abstracted  from.  Other  main  water  consuming  sectors  are  cooling  for  manufacturing  and 
electricity  generation  (17%),  households  and  services  (13%)  and  mining,  quarrying,  construction  and 
manufacturing (11 %). 

49 According to the EEA Report 12/2021 “Water resources across Europe —  confronting water stress: an updated assessment”, 
“water consumption” is the part of water used that is not returned to groundwater or surface water because it is incorporated into 
products (e.g. food and beverages) or consumed by households (e.g. drinking water) or livestock. 
50 https://www.eea.europa.eu/en/analysis/indicators/water-abstraction-by-source-and  
51 Total water abstraction per year in the EU-27 decreased by 17.6%, from 247,809 million m3 in 2000 to 204,112 million m3 in 
2019 
52 EEA Report 7/2024, Europe's state of water 2024. The need for improved water resilience 
(https://www.eea.europa.eu/en/analysis/publications/europes-state-of-water-2024). 

49 

 
 
Figure 3-17. Water abstraction by economic sector in the 27 EU Member States, 2000-2019 (EEA, 2022) 

It  should  also  be  noted  that  the  EEA  also  shows  that  the  relative  contributions  of  surface  water  and 
groundwater to the total volume of water abstracted have changed during this period: in 2000, surface water 
accounted for 81% of abstraction and groundwater for 19%, while, in 2019, surface water accounted for 
only 77% and groundwater for 23%. 

Figure 3-18. Share of total annual water abstraction by source in the 27 EU Member States, 2000-2019 (EEA) 

The increase in water abstraction from groundwater can largely be explained by increasing demand in the 
public  water  supply  and  agriculture  sectors,  with  groundwater  meeting  almost  65%  of total  public  water 
supply and 25% of agricultural water demands in the EU-27 in 2019. Climate change exacerbating seasonal 
variability in surface water availability is likely to have contributed to this, as demand for water has increased 
during  spring  and  summer  months  when  availability  of  surface  water  is  limited,  particularly  in  southern 

50 

 
 
 
Europe, causing competition between sectors and driving a shift in water abstraction from surface water to 
groundwater. 

Unsurprisingly, water scarcity is perceived as a growing issue in most Member States. Water abstraction and 
alteration  of  groundwater  level/volume  are  reported  as  significant  pressures  causing  failure  of  good 
quantitative status in 450 out of the 3 577 (12.6%) groundwater bodies and ecological status in 5 174 out 
of 52 718 (9.8%) of total surface water bodies for the thirteen Member States for which information was 
available through the e-reporting. However, as already outlined earlier, the pressure to the environment could 
be underestimated, as various Member States do not yet consider the needs of GWAAEs and GWDTEs in the 
assessment of good quantitative status. 

The proportion of groundwater bodies failing to achieve good quantitative status due to significant pressure 
from water abstraction and/or alteration of groundwater level/volume is the highest in Spain (25%), Hungary 
(20%), Italy (19%), France (11%)  and Belgium (11%).  In addition, the  proportion of surface water bodies 
failing to achieve good ecological status/potential due to significant pressure from water abstraction is higher 
in France (17%), Austria (12%), Spain (11%), Italy (9%) and Croatia (8%). While they failed to submit their 
third RBMPs, this is known to be a significant issue also in Cyprus, Greece, and Malta based on the previous 
RBMPs. 

It should be noted that the estimations on the volumes of water abstraction / use vary considerably depending 
on the source of the data. and that water abstraction is largely estimated based on indirect evidence, such 
as issued permits, conducted surveys, and assumptions / approximations (e.g. based on cropping  patterns 
and assumed need for irrigation). Direct monitoring and metering are more frequent in specific water uses 
(e.g. public water supply). This leads to significant degree of uncertainty on the actual pressures asserted on 
water  bodies.  The  degree  of  such  uncertainty  is  even  higher,  considering  that  unauthorised/illegal  water 
abstraction (i.e. abstraction either without a permit or in excess of the permit conditions) occurs in various 
sectors (e.g. more frequently in agriculture, but not limited to this sector) and is reported in the third RBMPs 
of certain Member States (see further below). 

Measures related to abstractions and water scarcity 

The WFD explicitly requires controls over the abstraction of surface water and groundwater and impoundment 
of fresh surface waters including a register or registers of water abstractions and a requirement for prior 
authorization of abstraction and impoundment. These permits have to be periodically reviewed and, where 
necessary, updated.  Measures to address abstraction and water scarcity have generally been planned in 
the PoMs in all RBDs where water abstraction has been identified as a significant pressure. These measures 
focus on control of abstractions, water efficiency and reuse, natural water retention, e-flows, research and 
knowledge building. 

However, implementation of these measures is uneven because Member States dedicate different resources 
to such task. As also found by the European Court of Auditors53, Member States have made progress in setting 
up  prior  authorisation  systems  for  water  abstraction,  systems  for  detecting  illegal  water  use  and  pricing 
mechanisms with the potential to incentivise water efficiency. However, the fact that most Member States 
exempt small abstractions from controls or registration is potentially problematic, as the accumulation of 
such small abstractions over the whole river basin can have negative impact on the status of surface and 
groundwater bodies. A lack of control and registration can be of concern particularly in Member States that 
already have water scarcity problems and in water bodies that face quantitative problems. In addition, it is 
noted that the frequency with which Member States review the abstraction permits, as required by the WFD54, 
is ranging from 6 years to several decades or even indefinite periods of time. This situation makes it very 

53 Special report 20/2021: Sustainable water use in EU agriculture. 
54 Article 11(3)(e) of the WFD requires Member States to undertake regular mandatory reviews. 

51 

 
 
difficult and sometimes impossible to properly factor in the evolving situation in water bodies, including from 
a climate change perspective. The Commission is currently involved in enforcing the obligation to review such 
permits to ensure its correct implementation across Member States55. 

The issue of over-allocation of water rights compared to available water resources, excluding e-flows, is 
not explicitly mentioned in the assessed third RBMPs documents. However, indirectly, this is acknowledged 
as an issue in Member States that report restrictions in the issue of new permits and/or include in their PoMs 
the purpose to review existing permits to support the achievement of environmental objectives (i.e. Belgium, 
France, Hungary, Italy, Spain). 

The issue of unauthorised/illegal water abstraction (i.e. abstraction either without a permit or in excess of 
the permit conditions) is explicitly mentioned only in some of the third RBMPs documents of 4 Member States 
(e.g. Flanders RBDs of Belgium, Mayotte and Guadeloupe RBDs of France, Hungary, South Apennines RBD of 
Italy). Nevertheless, the issue is also known to exist in other areas of Europe (e.g. Bulgaria, Cyprus, Greece, 
Spain), according to the special European Court of Auditors’ report on ‘Sustainable water use in agriculture’. 
However,  even  where mentioned,  these  references  usually  miss  a  quantification  of  the  current issue  and 
trends from the second RBMPs. In some of these countries, efforts are on-going to close the illegal wells to 
prevent such unlawful appropriation of this common good. In all MS, inspection mechanisms are in place to 
prevent cases of unauthorised / illegal abstractions or violation of permit conditions, including sample checks 
by national authorities after authorisation or targeted checks after submission of complaints. 

Eleven  Member  States  (i.e.  Belgium,  Croatia,  Czechia,  Finland,  France,  Hungary,  Italy,  Latvia,  Netherlands, 
Romania, Spain) also plan basic measures for water efficiency, including technical measures for irrigation, 
industry, energy and households, while 4 Member States (Belgium, Estonia, Netherlands and Italy) also plan 
basic  measures  for  groundwater  recharge  and  /  or  augmentation  of  groundwaters.  Other  types  of  basic 
measures  planned  for  the  2021-2027  period  include  measures  relevant  with  research,  improvement  of 
knowledge  base  and  reduction  of  uncertainty,  measures  for  drinking  water  protection,  climate  change 
adaptation measures and measures for cost recovery and incentive water pricing. 

As in the past, several Member States focus their measures to address water scarcity on increasing supply, 
such as drilling new wells, constructing new dams and reservoirs, expanding irrigation infrastructure for 
agriculture, constructing large-scale water transfer infrastructure and desalinisation plants. In the PoMs 
of the third RBMPs, such measures are planned in 8 Member States (i.e. Austria, Croatia, Czechia, France, 
Italy, the Netherlands, Poland, Spain) without providing a lot of information. In a context of increasingly felt 
impacts of climate change, it is important to ensure a robust assessment of the environmental impacts of 
such measures. 

In the PoMs of the third  RBMPs, 11 Member States plan  natural water retention measures (i.e. Croatia, 
Belgium, Czechia, Finland, France, Germany, Hungary, Italy, Poland, Romania, Spain) and 9 MS plan water 
reuse schemes (i.e. Croatia, Belgium, Czechia, France, Hungary, Italy, Poland, Romania, Spain). As noted by 
the ECA, natural water retention measures may deliver multiple benefits, including groundwater recharge, 
drought management and flood risk reduction, but their effectiveness is limited if they are used in a small 
area56. Overall, in tackling water abstraction and water scarcity issues and risks, all MS, including those that 
do not currently consider water abstraction as a significant pressure, need to adopt a more proactive and 
forward-looking approach that goes beyond the 6-year WFD cycles. Climate change scenarios and long-term 
water supply and demand forecasts should be explicitly integrated in WFD planning and permitting of all 
Member States. 

55 Letters of formal notice on this subject have been sent to Austria, Finland, the Netherlands and Slovenia,; for Ireland, the issue is 
dealt with in the context of the long-standing infringement procedure for lack of correct transposition of several provisions of the 
WFD, including Article 11.. 
56 ECA report on water and agriculture 

52 

 
 
3.1.7  Adaptation to climate change 

As outlined in the European Climate Risk Assessment (EUCRA)57 and as recognized by the Commission in its 
Communication on managing climate risks58, the EU and its Member States must become significantly better 
at  preparing  for  and  effectively  addressing  climate  risks59.  The  evidence  that  climate  change  is  having  a 
substantial impact on the occurrence and severity of water-related risks such as droughts and floods in much 
of Europe is mounting60. 

In the EU, according to the EEA61, water stress currently affects 20% of the European territory and 30% of 
the European population, with droughts causing damage of up to EUR 9 billion/year and unquantified damage 
to ecosystems and their services. Damages from drought alone could ramp up to EUR 40 billion/year, in the 
extreme scenario of a global warming of 3°C which, unfortunately, appears increasingly possible. The EUCRA 
highlights a growing risk of megadroughts that span large regions and last for several years, and that are 
even more severe than recent drought events in Europe. Prolonged droughts cause large economic damage 
across many sectors and can severely degrade the water resources that people, agriculture, industry, power 
plants, river transport and ecosystems depend on. 

On the other hand, the EUCRA shows also that extreme precipitation has increased in large parts of Europe, 
leading to growing flood risks and devastating floods in recent years. This trend is expected to rise further in 
a warming climate. In addition, rising sea levels increase the risk of coastal floods and storm surges, coastal 
erosion and saltwater intrusion into groundwater. This presents an important threat to many coastal cities, 
regions and ecosystems in Europe. 

Effective implementation of the WFD, as well as of the Floods Directive is essential to enhancing EU water 
resilience and ultimately a pre-requisite to achieve climate resilience objectives of the EU climate law62 and 
the EU adaptation strategy63. At the same, the objectives of the WFD and the FD can only be achieved by 
taking into full consideration the impacts of climate change in their implementation. 

Although the obligation to adapt the RBMPs to climate change is not explicitly included in the text of the WFD, 
the  stepwise  and  cyclical  approach  of  the  river  basin  management  planning  process  is  well  suited  to 
adaptively manage climate change impacts, building on climate adaptation plans in the member States. 

The Floods Directive on the other hand explicitly requires considering the impacts of climate change on the 
occurrence  of  floods,  and  therefore  in  the  preparation  of  Preliminary  Flood  Risk  Assessments,  which  are 
elaborated into Flood Hazard and Risk Maps (FHRMs), and Flood Risk Management Plans (FRMPs) which are 
assessed in the dedicated Section B of this document. However, considering the close relationship between 

57 EEA (2024), European climate risk assessment. No 1/2024, https://www.eea.europa.eu/publications/european-climate-risk-
assessment 
58 Communication from the Commission to the European Parliament, The Council, The European Economic and Social Committee and 
the  Committee  of  the  Regions  Managing  climate  risks  -  protecting  people  and  prosperity,  COM(2024)  91  final,  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52024DC0091 
59 Communication from the Commission to the European Parliament, The Council, The European Economic and Social Committee 
and the Committee of the Regions Managing climate risks - protecting people and prosperity, COM(2024) 91 final, https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52024DC0091 
60 Temperatures in Europe increase more than twice global average over the past 30 years – the highest of any continent in the 
world, November 2022 report, the World Meteorological Organization, https://wmo.int/publication-series/state-of-climate-europe-
2022 and Climate Change 2022: Impacts, Adaptation and Vulnerability, 
https://www.ipcc.ch/report/ar6/wg2/downloads/report/IPCC_AR6_WGII_FullReport.PDF  
61 EEA 2021 “Water resources across Europe —  confronting water stress: an updated assessment” 
(https://www.eea.europa.eu/publications/water-resources-across-europe-confronting)  
62 Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the framework for 
achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (‘European Climate Law’). 
63 COM(2021) 82 final - Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions “Forging a climate-resilient Europe - the new EU Strategy on Adaptation to 
Climate Change”. 

53 

 
 
overall water management and flood risk management and the importance of climate change  effects on 
both, climate change effects are jointly addressed in this section. 

Climate resilience and Drought risk management in the RBMPs  

An increasing number of Member States reported a systematic consideration of climate change impact and 
an effort to align their programme of measures with National Climate Adaptation Plans. For well over half 
of  the  Member  States,  National  Climate  Adaptation  Plans  provided  important  information  for  river  basin 
management plans; however, most RBMPs are not explicit in how climate change impacts were considered 
and integrated. 

Fourteen of the 20 Member States reported completing analysis of climate change on  main pressures to 
water  bodies.  For  some,  this  analysis  was  limited  to  only  a  few  sectors.  The majority  of  Member  States, 
however, do not provide details on the methodology used in this assessment. Climate-proofing of measures 
proposed in the PoMs was reported by 11 of the 20 Member States analysed. However, it is often unclear 
how the result of this study impact on their analysis of pressures and the definition of measures.  

Adaptation measures are integrated into RBMPs in 14 Member States, yet in some cases this is only done in 
a  very  general  manner.  Such  adaptation  measures  cover  areas  such  as  water  management,  habitat 
protection,  and  pollution  control.  Some  measures  pertain  to  land  conversions,  modifications  of  water 
allocations,  and  water  management  practices  to  rehabilitate  surface  and  groundwater  connectivity, 
maintaining ecological flow, and ensuring continuity for migratory species.  

Even if floods continued to remain a major concern, in the third RBMPs, effects of climate change were mostly 
linked  to  droughts  and  lower  water  availability  and  focused  often  on  their  effects  on  agriculture,  inland 
navigation and energy generation. Sixteen of the analysed 20 Member States reported droughts as significant 
occurrence in the planning period. This is a marked difference compared to the second RBMP, where excess 
water (i.e. floods) was highlighted as key impact of climate change.  

The analysis shows that progress was achieved in relation to drought management in several Member States. 
The  development  of  a  genuine  “drought  management  plan”  is  an  important  step  to  evolve  from  crisis 
management towards risk management.64 As recommended by the Commission65, 9 Member States (Belgium, 
France, Germany, Hungary, Italy, the Netherlands, Romania, Slovakia, Spain) reported in their third RBMPs the 
existence of distinct Drought Management Plans at national, river basin or regional levels. Such plans map 
areas  at  risk  and  determine  alert  levels,  foresee  warning  systems,  and  clarify  upfront  water  allocation 
priorities during a prolonged drought. Other Member States reported somewhat less comprehensive plans 
which mainly focus on mapping risks, and making broad recommendations, without however determining a 
response mechanism (e.g. water allocation priorities).  Two Member  States  have plans that come close to 
fully-fledged Drought Management Plans (Czechia, Poland) and two more (Finland, Luxembourg) declared 
that they are in the process of finalising such a plan. Overall, Nordic and Baltic Member States seem less 
prepared  for  droughts  than  Mediterranean  Member  States  with  Western  and  Central  European  Member 
States going through a transition.  

Drought management measures were integrated in the Programme of Measures for 10 Member States; when 
these Member States also have drought management plans, then these measures are aligned with those (i.e. 
they are in both plans). 

64 For a more detailed analysis see Schmidt et al (2023), Stock-taking analysis and outlook of drought policies, planning and 
management in EU Member States (https://op.europa.eu/en/publication-detail/-/publication/3bdf2849-9d57-11ee-b164-
01aa75ed71a1/language-en).  
65 COM (2009), Communication to the EP and the Council “Addressing the challenge of water scarcity and droughts in the European 
Union” https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52007DC0414 

54 

 
 
The effects of climate change are also felt on water quality in several Member States. Four Member States 
(Belgium, Hungary, Italy,  the Netherlands) invoked Article 4(6) exemption due to prolonged droughts 
that prevented the achievement of good ecological status in a total of 118 water bodies. This is an increase 
compared to the second RBMPs, potentially signalling a new trend in negative impacts of climate change on 
quality of water resources. 

Climate resilience and Floods Risk Management under the FD 

The assessment of the second Floods Hazards and Risk Maps (FHRMs) and second Flood Risk Management 
Plans (FRMPs) shows a significant improvement in the  integration of climate change consideration in the 
implementation of the Floods Directive. 

Although not explicitly required by the FD, 23 Member States considered climate change for the preparation 
of their second Floods Hazards and Risk Maps (FHRMs). This is an increase compared to the the first FHRMs 
where only 16 Member States did so. Of these 23 Member States, 15 Member States considered climate 
change for coastal flooding. Sixteen out of the 23 Member States considered climate change for the medium 
probability scenario66; for the other two scenarios this was done less often; 13 Member States for the low 
probability scenario67 and 11 for the high probability scenario68. 13 Member States obtained climate change 
trend  scenarios  from  the  IPCC  or  other  international  and  EU  sources69  and  15  from  national  research 
programmes70. Nine Member States used both sources71.  

As regards the FRMPs, all the assessed 21 Member States, compared to one third in the past, provide strong 
evidence  that  climate  change  was  addressed  in  their  Plans.  Almost  all  the  FRMPs  assessed  refer  to  the 
national adaptation strategies prepared by Member States under the EU Adaptation Strategy, though in some 
Member States this was not the case for all FRMPs. In all the Member States considered, the FRMPs present 
the  potential  climate  change  impacts  on  flooding.  These  Member  States  consider  a  potential  shift  in  the 
occurrence (or intensity) of extreme events and/or changes in the main source of flooding. The level of detail 
varies  significantly  though,  with  some  Member  States  providing  a  short,  general  discussion  of  potential 
impacts of climate change on flooding events, with others providing potential flood event detail, including 
quantitative information for the areas potentially affected. Most of the Member States assessed make an 
explicit reference to the scenarios provided by the Intergovernmental Panel on Climate Change (IPCC) within 
their FRMPs, indicating alignment with internationally recognised climate change projections. More than half 
of the Member States assessed present findings from national or regional studies, some of which are based 
on the IPPC scenarios, into their FRMPs. In a few Member States, an explicit reference to climate change 
scenarios and their impact on floods is also included in the Strategic Environmental  Assessments for the 
FRMPs. 

As regards the integration of climate adaptation measures included in FRMPs, over half of the Member 
States reporting72 prioritise measures that are adaptable to changing conditions, reflecting a consideration 
of climate change criteria in their FRMPs. The FRMPs in a few Member States73 described methods to assess 
the  effectiveness  of  measures  in  the  face  of  climate  change.  The  vast  majority  of  the  Member  States 

66 Austria, Belgium (partly), Bulgaria, Croatia, Cyprus, Denmark, Estonia, Finland, France, Hungary, Ireland, Lithuania, Malta, Poland, 
Portugal, Romania, and Sweden. 
67 Austria, Belgium, Croatia, Cyprus, Denmark, Estonia, Finland, Hungary, Ireland, Malta, Poland, Sweden, Slovenia. 
68 Austria, Belgium (partly), Croatia, Cyprus, Estonia, Finland, France, Hungary, Ireland, Lithuania, Malta. 
69 Bulgaria, Croatia, Cyprus, Denmark, Estonia, Finland, Italy (partly), Lithuania, Latvia, Portugal, Romania, Sweden, Slovenia. 
70 Belgium, Czechia, France, Hungary, Ireland, Malta, Poland. 
71 Croatia, Estonia, Finland, Italy, Lithuania, Portugal, Romania, Sweden, Slovenia. 
72 Austria, Belgium, Czechia, Germany, Estonia, Finland, Italy, Latvia, Netherlands, Poland, Romania and Sweden (12 out of 21). 
73 Belgium, Germany, Estonia, Finland and Romania. 

55 

 
 
assessed included in their FRMPs at least a few specific measures to address climate  change or refer to 
climate change in the context of some of their measures. 

Nearly  all  Member  States  include  nature-based  solutions  in  their  FRMPs,  and  many  plans  mention  their 
positive role for adaptation. While some FRMPs do not specifically refer to adaptation in the context of their 
nature-based solutions, these are likely to strengthen resilience, as highlighted in the EU’s 2021 Adaptation 
Strategy. 

Similarly, nearly all Member States include land use and spatial planning measures in their FRMPs. Some 
refer to their role in adaptation. On the other hand, while a few Member States refer to the role of insurance 
in flood risk management, references to its role in supporting climate resilience and adaptation were not 
found. 

3.2 

 POLICY ELEMENTS CONTRIBUTING TO ZERO POLLUTION 

3.2.1  Surface Water: what is their chemical status 

Good chemical status of surface waters is the chemical status achieved by a body of surface water in which 
concentrations of priority substances do not exceed the concentrations established in the law. 

The EQSD initially identified 33 priority substances, and eight other pollutants and set up related limits value. 
In 2013, twelve new priority substances and their limits were added to the list, and good status for these 
substances  must  only  be  achieved  by  2027.  In  addition  to  reaching  good  chemical  status  for  all  priority 
substances and the eight other pollutants, Member States are also required to assess long-term trends and 
to establish an inventory of emissions, discharges and losses of all substances identified in the Directive, for 
each national river basin district. 

Monitoring  

Overall, there has been further improvement in monitoring across the EU, but there continue to be a huge 
variation in the monitoring of Priority Substances74, both in terms of the percentage of water bodies and the 
number of substances. 

Most  Member  States  have  expanded  the  (geographic  coverage)  of  monitoring  networks  since  the  second 
RBMPs75. Figure 3-19 below provides a comparison per Member State to illustrate the proportion of water 
bodies  included  within  the  monitoring  network  to  determine  the  chemical  status.  For  a  small  number  of 
Member States, the information provided within the third RBMPwas insufficient to reach a conclusion. 

74 Substances presenting a significant risk to or via the aquatic environment, listed in the Environment Quality Standards Directive. 
75 11 out of 20 MS have expanded the scope of their monitoring network, a further 3 (out of 20) are unchanged, 2 (out of 20) have 
decreased the scale of monitoring and the remaining 4 either didn’t provide data or the data in the 3rd RBMP was insufficient to 
draw conclusions. 

56 

 
 
Figure 3-19. Evolution of geographic scale of monitoring networks between the second and third RBMPs 

In terms of frequency of monitoring, the majority of Member States76 comment that operational monitoring 
for surface water is undertaken on a monthly basis, and annually for sediment and biota. There are examples 
where mixed approaches are used. There is also a diversity of approaches to monitoring frequencies across 
locations, often based on the risks and probability of finding the pollutants given the available resources and 
perceived high risk/low risk locations across different water bodies. This means that the geographic scale of 
the monitoring network alone may not tell the full story for how complete the monitoring programme is in 
practice. 

Most Member States monitored all Priority Substances identified as discharged into their RBDs. While in some 
cases uncertainty remains as regards which substances are included in the monitoring programmes, it would 
appear that in half of the Member States covered (Austria, Belgium (Flanders and Brussels), Croatia, Finland, 
Germany,  Lithuania,  Luxembourg,  the  Netherlands,  Poland,  and  Sweden)  all  45  priority  substances  are 
included within the monitoring programme at national level, while the others (France, Latvia, Romania, and 
Slovakia)  indicated  that  they  monitored  between  40  and  44  priority.  Several  MS  (e.g.,  Belgium,  Croatia, 
Czechia, Finland, and Hungary) indicate that they have increased the number of priority substances included 
in their monitoring programmes to close gaps from the second RBMPs (these increases go beyond the 12 
new substances added to the EQSD in 2013). Denmark reported monitoring only 25 priority substances77, 
while  no  information  was  provided  by  Czechia  about  which  priority  substances  are  included  within  the 
monitoring programme. 

76 Belgium, Croatia, Denmark, Finland, France, Hungary, Italy, Luxembourg, The Netherlands, Poland, Romania, Slovakia, Spain, and 
Sweden.  
77 The justification provided by the authority was that it was only required to monitor priority substances where a known discharge 
to surface water was likely to occur. 

57 

 
 
 
Figure 3-20. Coverage of monitoring for priority substances across the Member States for the third RBMP* 

*Note that Wallonia monitors 44 out of 45 priority substances. The other parts of Belgium monitor all 45 priority substances. The 
graph above counts Belgium as a whole in the ‘all 45 priority substances’ category. 

Member States are required  to undertake monitoring in biota and sediment for 20 priority substances to 
complete long-term trend assessments. Unfortunately, as shown in Figure 3-21 below monitoring in sediment 
and biota for long-term trend assessment looks variable and largely incomplete. This aspect  of the WFD 
compliance  for  chemical  status  was the  weakest  in the  assessment  and  represents  the  biggest  gap.  The 
results of the trend analysis look significantly underdeveloped and are actually missing for most Member 
States. 

58 

 
 
 
Figure 3-21. Surveillance monitoring in sediment and biota – number of MS per substance that monitor each 
substance at 10 or more sites* 

Status Assessment 

It should be noted that the proportion of water bodies in unknown chemical status across all Member States 
has improved. Yet three countries really stand out with still very significant proportions of their surface water 
bodies  nationally  at  unknown  status,  Lithuania  (94.6%  of  surface  waters  in  unknown  status),  Denmark 
(92.5%), and Estonia (82.7%).  

The assessment shows a significant decrease in the number of surface waters bodies at EU level in good 
chemical status.  

Only 26,8% of surface waterbodies were in good chemical status in 2021 as compared to the second RBMPs 
in 2015 when the share of surface water bodies in good chemical status was 33,5%.  

The lack of progress is largely due to the presence of few individual compounds that are called “ubiquitous 
persistent, bioaccumulative and toxic” substances (uPBTs), for which there is also improved monitoring and 
better knowledge of the status of water bodies in  several countries leading to significant changes in the 
result of the chemical status assessment in a number of countries (see more information below). 

The most common of these compounds are mercury and polycyclic aromatic hydrocarbons (PAHs) such as 
benzo(a)pyrene, fluoranthene, and benzo(g,h,i)perylene, that mainly enter the aquatic environment following 
atmospheric emissions resulting from combustion processes of fossil or other fuels, and  polybrominated 
diphenyl ethers (PBDEs), which are heavily used in paints, plastics, foam furniture padding, textiles, building 
materials and industrial processes. These “usual suspects” have a very dominant effect in the chemical status. 
Without these very frequent and persistent compounds, we would observe that 81% of the surface water 
would have reached good ecological status. This represents largely the same proportion as in the last cycle.  

59 

 
 
It should be noted that uPBTs continue to be responsible also for failure to meet the good environmental 
status objective for contamination under the MSFD for 80% of the sea area78. 

Figure 3-22. Change in the chemical status assessment of EU surface water bodies from the first, second and 
third RBMPs (all substances including uPBTs) (source: WISE freshwater and PDF data mining) 

SWB chemical status for EU average

3rd

2nd

1st

0%

20%

40%

60%

80%

100%

Good

Failing to achieve good

Unknown

Figure 3-23. Change in chemical status assessment of EU surface water bodies from the second and third 
RBMPs (without uPBTs) (source: WISE freshwater and PDF data mining) 

SWB chemical status without uPBT for 
EU average

3rd

2nd

0%

20%

40%

60%

80%

100%

Good

Failing to achieve good

Unknown

78 Report from the Commission, First 'zero pollution' monitoring and outlook, 'Pathways towards cleaner air, water and soil for 
Europe', COM(2022) 674 final, Brussels, 8.12.2022. 

60 

 
 
 
 
 
As shown in the table 3-6 below, while the share of surface waters in good status has remained stable or 
slightly improved in some Member States compared to the 2016-2021 period, it has significantly decreased 
in others. In all these Member States the primary reason for such widespread chemical status failures relates 
to uPBT substances. As mentioned above, this deterioration may be largely due to improved monitoring and 
better  knowledge  of  the  status  of  water  bodies  in  these  countries,  particularly  in  relation  to  widespread 
uPBTs, major changes in the delineation of water bodies and more stringent standards for some substances. 

Furthermore,  it  should  be  noted  that  some  Member  States  have  assessed  the  original  list  of  priority 
substances from 2008 whilst others included already in the assessment the new priority substances added 
to the Directive in 2013 although legally the compliance deadline to meet the quality standards for these 
new substances is only 2027. 

Table 3-6. Overview of status assessment from third RBMPs (all substances including uPBT) 

second RBMPs 

third RBMPs 

Member State 

Good 

to 

Failing 
achieve 
good status 

Unknown 

Good 

Failing 
to 
achieve good 
status 

Unknown 

Difference 
in good 
status in % 
points 

EU proportion 

AT 

BE 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

HR 

HU 

IT 

LT 

LU 

LV 

NL 

PL 

RO 

SE  

SK 

33.5% 

0.0% 

2.2% 

68.5% 

0.0% 

0.8% 

9.7% 

87.5% 

49.5% 

62.9% 

91.8% 

45.7% 

71.7% 

99.0% 

0.0% 

10.6% 

39.2% 

59.0% 

97.7% 

0.0% 

97.5% 

50.9% 

100.0% 

97.7% 

31.1% 

100.0% 

0.7% 

2.0% 

6.4% 

50.5% 

15.9% 

8.2% 

7.8% 

8.5% 

0.9% 

100.0% 

4.7% 

51.8% 

26.4% 

2.3% 

100.0% 

2.5% 

15.6% 

0.0% 

0.2% 

0.4% 

0.0% 

98.5% 

88.3% 

6.1% 

0.0% 

21.2% 

0.0% 

46.5% 

19.8% 

0.1% 

0.0% 

84.7% 

9.0% 

14.7% 

0.0% 

0.0% 

0.0% 

26.8% 

0.0% 

0.0% 

38.6% 

0.0% 

1.8% 

9.7% 

89.8% 

0.0% 

67.9% 

80.4% 

46.0% 

75.1% 

0.3% 

0.0% 

0.0% 

9.4% 

24.8% 

97.7% 

0.0% 

71.2% 

60.8% 

12.4% 

98.8% 

100.0% 

42.9% 

100.0% 

5.7% 

7.6% 

7.1% 

100.0% 

23.0% 

19.4% 

54.0% 

15.8% 

5.1% 

100.0% 

100.0% 

90.3% 

53.5% 

2.3% 

100.0% 

28.8% 

1.2% 

0.0% 

18.4% 

0.0% 

92.5% 

82.7% 

3.1% 

0.0% 

9.1% 

0.2% 

0.0% 

9.1% 

94.6% 

0.0% 

0.0% 

0.3% 

21.7% 

0.0% 

0.0% 

0.0% 

-6.7% 

0.0% 

-2.2% 

-29.9% 

0.0% 

0.9% 

-0.1% 

2.4% 

-49.5% 

5.0% 

-11.4% 

0.3% 

3.4% 

-98.7% 

0.0% 

-10.6% 

-29.8% 

-34.2% 

-0.1% 

0.0% 

-26.3% 

Overall,  as  already  mentioned  above,  the  substance  responsible  for  the  greatest  number  of  failures  is 
mercury, followed by polybrominated diphenyl ethers (PBDEs) and polycyclic aromatic hydrocarbons (PAHs). 

61 

 
  
 
 
Nationally, the other substances that cause EQS exceedance and failure to achieve good chemical status 
vary,  but  metals  (e.g.  lead,  cadmium,  nickel  which  are  typically  linked  to  mining  waste,  municipal  and 
industrial wastewater, urban runoff), biocides and pesticides (tributyltin, chlorpyrifos), and some Persistent 
Organic Pollutants (e.g., hexachlorobenzene, , which still persist although banned for use in the EU since 
many years, continue to commonly feature in the top of the list of substances leading to failure (see Figure 
3-24 below).   

Figure 3-24. Top Priority substances (initial 33 priority substances) causing failure to achieve good chemical 
status (count of SWBs) – electronic reporting only. 

0

4000

Number of SWBs
8000
12000

16000

20000

Mercury and its compounds

Brominated diphenylethers (congener numbers 28, 47,…

Benzo(a)pyrene

Fluoranthene

Benzo(g,h,i)perylene

Benzo(b)fluoranthene

Nickel and its compounds

Benzo(k)fluoranthene

Tributyltin-cation

Lead and its compounds

When considering also the additional 12 priority substance added in 2013, PFOS (a type of PFAS) and its 
derivatives, heptachlor and heptachlor epoxide (an insecticide) have made their entry in the top ten. However, 
it must be noted that while monitoring of these new substances has become mandatory, the deadline for 
compliance as mentioned above is 2027. 

62 

 
 
 
Figure 3-25. Top Priority substances (revised list of 45 priority substances) causing failure to achieve good 
chemical status (count of SWBs) – electronic reporting only. 

0

4000

8000

12000

16000

20000

Mercury and its compounds

Brominated diphenylethers (congener numbers 28, 47,…

Benzo(a)pyrene

Fluoranthene

Benzo(g,h,i)perylene

Perfluorooctane sulfonic acid (PFOS) and its derivatives

Benzo(b)fluoranthene

Heptachlor and heptachlor epoxide

Nickel and its compounds

Benzo(k)fluoranthene

3.2.2  Groundwater Bodies: what is their chemical status 

The monitoring  and  assessment  of  the  chemical  status  of groundwater bodies  has improved,  although  a 
significant number are still not covered or are subject to  limited monitoring of some core parameters only. 

Status Assessment 

It is noted positively that the assessment shows an improvement in the overall chemical status with 86% of 
groundwater bodies in good status in 2021 as compared to the previous cycle when the share was 82.2%. 

Figure 3-26. Change in the chemical status assessment of EU groundwater bodies from the first, second and 
third RBMPs (source: WISE freshwater and PDF data mining) 

GWB chemical status for EU average

3rd

2nd

1st

0%

20%

40%

60%

80%

100%

Good

Poor

Unknown

63 

 
 
 
Lithuania is the only Member State that reported all groundwater bodies at good chemical status, with none 
at risk of poor status by 2027. Seven Member States (Austria, Croatia, Finland, Poland, Romania, and Sweden) 
report that at least 90% of their groundwater bodies are at good chemical status, whereas this amounts to 
70-90%  for  6  Member  States  (Denmark,  Estonia,  Hungary,  Italy,  Latvia  and  Slovakia),  to  60-70%  for  3 
Member  States (France, Germany  and  Spain)  and to  below  54%  for  4  Member  States  (Belgium, Czechia, 
Luxembourg and the Netherlands). However, only 2 Member States reported 100% high confidence in the 
status assessment, while for the rest there were mixed trends towards a decreased and an increase level 
ofconfidence. 

Table 3-7. Groundwater chemical status in EU Member States, comparison between second and third RBMPs. 

second RBMPs 

third RBMPs 

Member State 

EU proportion 

AT 

BE 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

HR 

HU 

IT 

LT 

LU 

LV 

NL 

PL 

RO 

SE  

SK 

Good 

Poor 

Unknown 

Good 

Poor 

Unknown 

Difference in good 
status in % points 

82.2% 

97.1% 

41.3% 

27.0% 

63.7% 

44.3% 

79.5% 

64.8% 

93.5% 

69.1% 

90.9% 

79.5% 

57.6% 

100.0% 

50.0% 

100.0% 

87.0% 

92.1% 

89.5% 

97.7% 

62.7% 

13.9% 

2.9% 

58.8% 

73.0% 

36.0% 

25.1% 

20.5% 

35.0% 

2.5% 

30.9% 

9.1% 

20.5% 

25.0% 

0.0% 

50.0% 

0.0% 

13.0% 

7.9% 

10.5% 

2.3% 

10.8% 

4.0% 

0.0% 

0.0% 

0.0% 

0.3% 

30.6% 

0.0% 

0.1% 

4.0% 

0.0% 

0.0% 

0.0% 

17.4% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

26.5% 

86.0% 

96.5% 

53.1% 

26.4% 

67.3% 

88.8% 

74.2% 

67.2% 

93.4% 

68.0% 

92.2% 

80.5% 

70.0% 

100.0% 

50.0% 

88.0% 

87.0% 

94.8% 

91.6% 

97.6% 

80.2% 

12.3% 

3.5% 

46.9% 

72.4% 

32.7% 

9.4% 

25.8% 

32.8% 

2.3% 

32.0% 

7.8% 

19.5% 

26.6% 

0.0% 

50.0% 

12.0% 

13.0% 

5.2% 

8.4% 

2.4% 

12.3% 

1.7% 

0.0% 

0.0% 

1.1% 

0.0% 

1.9% 

0.0% 

0.0% 

4.2% 

0.0% 

0.0% 

0.0% 

3.4% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

7.5% 

3.8% 

-0.6% 

11.8% 

-0.6% 

3.6% 

44.5% 

-5.3% 

2.4% 

0.0% 

-1.1% 

1.2% 

1.1% 

12.4% 

0.0% 

0.0% 

-12.0% 

0.0% 

2.7% 

2.1% 

-0.1% 

17.4% 

The most commonly reported pollutant leading to poor chemical status of groundwater bodies is Nitrates79 
coming mainly from intensive agriculture and livestock farming through the improper or excessive application 
of fertilizers and slurries/manures. This is the case for 17 out of the 20 Member States. Only Estonia, Latvia 
and Lithuania do not report nitrates as causing chemical status failure in their groundwaters. Pesticides and 

79 It should be noted that according to the EEA, average nitrate concentration in EU groundwaters did not change significantly since 
2021 (EEA, 2023). 

64 

 
  
  
 
 
their metabolites are responsible for the failure to achieve good chemical status by 9 Member States (Austria, 
Belgium,  Czechia,  Denmark,  Estonia,  France,  Luxembourg,  the  Netherlands,  and  Spain).  Phosphate  and 
ammonium, mainly stemming from intensive agriculture and livestock farming, also lead to poor chemical 
status with a particular impact in countries such as Slovakia and Czechia. Other substances mentioned as 
leading to a smaller proportion of groundwater bodies at poor chemical status (i.e. less than 10% by MS) 
including naturally occurring pollutants such as chloride, sulphate, potassium, iron and total organic carbon. 
Industrial  solvents,  PAHs,  methyl  tert-butyl  ether  (MTBE  -  primarily  used  as  a  fuel  additive)  and  anionic 
surfactants (frequently present in soaps and detergents) are less commonly pointed as the cause of poor 
status. 

Substances featuring a sustained and significant upward trend include nitrate, pesticides, chloride, sulphate, 
arsenic, nickel, cadmium, potassium phosphates, nitrite and ammonium. 

3.2.3  What is being done to combat pollution from agriculture 

Pollution  from  agriculture  is  the  top  pressure  identified  by  all  Member  States  in  almost  all  RBDs  and  is 
relevant for both surface and groundwater bodies. This is essentially due to unsustainable land management 
practices  and  excessive  and  improper  use  on  one  hand  of  fertilisers  and  slurries/manures  which  contain 
nitrogen leading to nitrates in water, on the other hand of pesticides and other hazardous substances.  

It  was  a  key  recommendation  from  the  assessment  of  the  second  RBMPs  to  perform  a  quantitative 
assessment of the reduction in the nutrient load that would be necessary to achieve good ecological status. 
This would form the basis for defining and selecting the measures that are necessary in order to achieve the 
necessary load reduction. 

Regrettably, limited progress has been made by most Member States carrying out this estimations. Only 8 
Member States (Belgium, Denmark, Finland, Germany, Latvia, Lithuania, the Netherlands, Sweden) have made 
a detailed assessment of the need for reduction of nutrient loads which covers both nitrogen and phosphorus 
and at least all surface water bodies. Romania has made estimation only as regards nitrogen. There is a large 
number of Member States that do not report on the load reductions. It is noted with concern that the majority 
of  Member  States  have  only  estimated  the  number  of  water  bodies  where  the  nutrient  load  should  be 
reduced.  

Table 3-8. Overview of gap assessment for nutrients (from agriculture and other sources) 

Member State 

Approach to gap assessment 

Comments 

Austria 

Number of water bodies 

Number of water bodies where diffuse nutrient pollution from agriculture 
requires measures to be applied. (Pesticide number of water bodies 2) 

Belgium 

Load reductions by water body  

Assessment of the RBD in Flanders  

Croatia 

Number of water bodies 

There is additional gap information in the WISE reporting on area 

Czechia 

No gap assessment  

There are measures listed by water bodies, but it is not clear how many 
water bodies required measures to reduce diffuse agricultural pollution 

65 

 
Member State 

Approach to gap assessment 

Comments 

Denmark 

Load reduction by water body 

Need for nitrogen reduction estimated at water body level with focus on 
what  is  required  for  coastal  water  bodies.  Need  for  reduction  of 
phosphorous load for lakes.  

Estonia 

Number of water bodies 

The  RBMPs  indicate  that  a  more  detailed  load  assessment  will  be 
developed 

Finland 

Load reduction by water body 

Need  for  load  reduction  based  on  modelling,  but  the  modelling  tools 
cannot yet fully assess the impacts of measures 

France 

Number of water bodies 

There is different level of information across the RBDs, but none of the 
RBMPs include quantification of the needed nutrient load reductions 

Germany 

Load reduction by water body 

For the assessed RBD there are estimates of need for nutrient reductions.  

Hungary 

No gap assessment 

There is some information about how many water bodies will be affected 
by each measure, but it is not clear if that is addressing the gap 

Italy 

Gap  assessment 
pressures 

including  all 

A scoring approach is used which combines all pressures  

Latvia 

Load reduction by water body 

Lithuania 

Load reduction by water body 

There  is  estimate  of  how  much  the  nutrient  load  needs  to  be  reduced. 
There  is  also  data  on  the  area  (ha)  where  agricultural  measures  are 
planned. 

There  is  estimate  of  how  much  the  nutrient  load  needs  to  be  reduced. 
There  is  also  data  on  the  area  (ha)  where  agricultural  measures  are 
planned. 

Luxembourg 

No gap assessment  

There some information about the area covered by specific measures, but 
no gap assessment 

The Netherlands 

Load reduction by water body 

Need for nutrient reduction estimated at water body level 

Poland 

No gap assessment 

Romania 

Load of nitrogen 

Based  on  the  e-reporting.  No  details  in  the  RBMPs  that  explains  the 
estimation 

Slovakia 

Number of water bodies 

Number of water bodies where diffuse nutrient pollution from agriculture 
requires measures to be applied 

Spain 

Number of water bodies 

Different assessments across RBD. Reference to modelling tools but do 
details presented. 

66 

 
 
Member State 

Approach to gap assessment 

Comments 

Sweden 

Load reductions by water body  

The aggregated need for nutrient load reductions is presented 

Source: third RBMPs PDF and electronic reporting 

Only 4 Member States (Denmark, Germany, the Netherlands and Sweden) have conducted an assessment on 
the  expected  effectiveness  of  the  measures  to  reduce  the  nutrient  loads  which  shows  that  the  planned 
measures have not been sufficient to remove all the nutrients required for achieving good ecological status.  

For none of the EU transitional and coastal water bodies, there appear to be clearly set upstream thresholds 
for  nutrients  load  reductions  or  closely  related  biological  quality  elements  to  ensure  a  good  status.  No 
Member State is using nutrient related thresholds in the classification of ecological good status of transitional 
and  coastal  waters  either.  This  has  also  an  impact  on  achieving  the  objectives  of  the  Marine  Strategy 
Framework Directive.   

For pesticides, there are very few examples of estimations of pesticides load reduction needed to achieve 
the objectives.  Member States report on challenges with assessing pesticides due to long retention time of 
pollutants in the soil and in the groundwater bodies. This relates to the fact that it takes some time for the 
pesticides to  reach the groundwater  and,  even  when  the  releases  have  stopped, it  takes time  before  the 
groundwater status improves. This explains why some of the pesticides that have been banned for several 
or  many  years  are  still  being  detected  in  groundwaters.  Restrictions  on  the current  use  of  pesticides  will 
therefore only show progress over a long time.  

No evaluation is reported of the effectiveness of the agricultural measures taken in the 1st and in the second 
RBMPs. This would have been essential to ascertain the progress to target for 2027. In addition, similarly to 
planned measures in other areas, also  not all the agricultural measures  announced in the second RBMPs 
have been implemented as planned. As in other areas, the reported challenges include funding, the low uptake 
by farmers of many of the voluntary measures incentivised through subsidies and the time it takes to deploy 
at large scale changes in farming practices. 

The  assessment  of  the  RBMPs  shows  that  basic  measures  are  usually  in  place  as  foreseen  by  the  WFD. 
Mandatory measures are nevertheless limited to those provided under the Nitrates Directive, the Sustainable 
Use Directive (2009/128/EC) and the cross-compliance and greening requirements under the CAP. All Member 
States have implemented the basic measures though there are some compliance deficiencies. 

As  regards  supplementary  measures,  all  Member  States  have  reported  on  them,  but  the  level  of  details 
provided in the RBMPs is generally limited. Several voluntary measures have been in place often supported 
through  the  CAP,  notably  through  agri-environment  climate  commitments80  (AECC)  and  other  relevant 
measures  included  in  the  Rural  Development  Programmes  developed  by  Member  States.  However,  these 
measures, together with the basic measures implemented, have not been sufficient to reduce pressures from 
nitrates and pesticides. This might have been due to a variety of factors including intrinsic limitations in the 
design of the voluntary measures in questions, the fact that measures were not sufficiently programmed by 
Member States, limited uptake by farmers, or limited uptake in the most affected areas. 

80 Payments for multi-annual commitments for environment and climate friendly agricultural practices which go beyond the baseline 
of mandatory requirements. 

67 

 
 
With  respect  to  the  CAP  2023-2027,  an  increased  contribution  to  tackling  pollution  from  nitrates  and 
pesticides  can  be  expected81.  It  includes  enhanced  conditionality82  standards,  such  as  strengthened  soil 
management requirements (e.g. crop rotation/ diversification, buffer strips) and a new requirement linked to 
controls on diffuse sources of pollution from phosphates. The instruments available under rural development 
funding83  (AECCs  including  organic  farming,  support  for  investments,  WFD  payments,  training  /  advice, 
innovation and cooperation) continue to be available and have been complemented with eco-schemes which 
support  environment/climate  friendly  practices;  Member  States  have  to  dedicate  at  least  25%  of  EAGF 
funding  to  these  schemes84.  Support  from  eco-schemes  and  AECC  covers  inter  alia  improved  nutrient 
management85 and the sustainable use of pesticides86. 

3.2.4  What is being done to combat pollution from other sectors? 

Pollution from sectors such as urban settlements, industry or energy also poses a threat to the aquatic 
environment and to human health via the environment.  

Basic measures to deal with pollution from these sectors are generally in place. These include measures such 
as an authorisation and/or permitting regime to control wastewater point source discharges, the operation 
of  registers  of  wastewater  discharges,  and  the  prohibition  or  limitation  of  all  direct  discharges  to 
groundwater, and/or other measures to eliminate / reduce pollution from priority and other substances. 

These are, in most cases, specific measures to deal with  specific pollutants which are causing failures of 
chemical or ecological status such as, for example, measures to reduce or stop the release into water of 
certain  pollutants  or  remediation  of  contaminated  sites,  addressing  historical  pollution  in  sediments, 
groundwater and soil. However, not all Member States and RBMPs provide the same level of detail when it 
comes to linking individual substances explicitly to specific measures to combat pollution. More progress is 
needed on this front, as well as on developing a gap analysis to inform the design of the measures.  

All Member States reported inventories of emissions, discharges, and losses of harmful substances, but 
there are large variations both in terms of coverage of the relevant pollutant and their completeness. The 
top  ten  substances  for  which  emissions  inventories  have  been  most  commonly  established  are  mercury, 
benzo(a)pyrene,  fluoranthene,  and  benzo(g,h,i)perylene  (PAHs),  nickel,  lead,  and  cadmium  (heavy  metals) 
nonylphenol  (non-ionic  surfactants),  perfluorooctanesulfonic  acid  (PFOS,  a  type  of  PFAS),  and  tributyltin-
cation (a highly toxic biocide). 

Most  of  the  Member  States  have  reported  basic  measures  “construction  or  upgrades  of  wastewater 
treatments plants” as it is being recognized that additional efforts are needed to comply with the UWWTD. 
Currently,  82%  of  Europe’s  urban  wastewaters  are  collected  and  treated  in  line  with  EU  standards.  The 
implementation of the revised UWWTD, for which the co-legislators recently reached a political agreement , 
will further reduce pollution from urban wastewaters. It includes new rules on storm overflows and urban 

81 See “Mapping and analysis of CAP strategic plans” (2023-2027) 
(file:///C:/Users/faltech/Downloads/mapping%20and%20analysis%20of%20cap%20strategic%20plans-KF0323354ENN%20(3).pdf). 
82  Conditionality links the full receipt of CAP support to the compliance of farmers and other beneficiaries with basic standards 
concerning the environment, climate change, public health, plant health and animal welfare. The basic standards encompass statutory 
management requirements (SMRs) and standards of good agricultural and environmental conditions of land (GAEC standards). 
83 European Agricultural Fund for Rural Development (EAFRD), c.f. Regulation 1305/2013 
84  See article 97(1) and (2) of Regulation 2021/2115. 
85 Support for farming practices to improve nutrient management are planned to be carried out on 15,2% of the EU’s agricultural area. 
86 27% of EU’s agricultural area is planned to be covered with commitments which lead to a sustainable use of pesticides in order to 
reduce risks and impacts of pesticides such as pesticides leakage. 

68 

 
 
 
 
run-off that will help Member States to more effectively address these pressures that had not been covered 
by EU legislation. 

It is worth noting that, while the WFD does not cover pollution from litter, this is a key area where synergies 
with the MSFD must be built since a very large part of the plastics in the sea come from the rivers.  The 
assessment of the Programmes of Measures under the MSFD shows that Member States have taken many 
measures to address the main sources of litter. This has led to an estimated 33% reduction of beach litter 
between 2016-2021 across all EU sea basins. These measures are likely to have had also a positive impact 
on rivers, lakes and coastal waters. 

4.  Exemptions and economics 

4.1  Exemptions 

Where the environmental objectives of the WFD cannot or have not yet been achieved and where there is a 
need to derogate to the principle of preventing any further deterioration of status, the WFD foresees that 
exemptions can be applied pursuant to Article 4 (4), (5), (6) and (7)87. 

All Member States apply one or more of these types of exemptions for those surface and groundwater bodies 
still failing to achieve good status, and in some cases to justify a deterioration. The type of exemption used, 
the underlying reasons (e.g. disproportionate cost, technical feasibility, natural conditions) and the level of 
detail used to justify the exemptions varies considerably per Member State. 

Given the limited progress in reaching good status, a large majority of the water bodies in the EU are covered 
by the various exemptions foreseen in Article 4 of the WFD.  

Overall, compared to the previous cycle, the number of exemptions, particularly those related to Articles 4(4) 
on time exemption for achieving the objectives  and 4(5)  exemptions setting less stringent environmental 
objectives of the WFD has increased. 

The number of exemptions applied under Article 4(4) has increased in six Member States88. For the remaining 
Member States, there is no change in the number of exemptions under Article 4(4) or it is not possible to 
compare directly due to changes in number of water bodies. 

The number of exemptions applied under Article 4(5) has increased in six Member States89 and decreased in 
two90. For the remaining Member States, there is no change in the number of exemptions under Article 4(5) 
or it is not possible to directly compare. 

The number of exemptions allowing for a temporary deterioration in status applied under Article 4(6) has 
increased in four Member States91. For the remaining Member States, there is no change in the number of 
exemptions under Article 4(6) or it is not possible to compare. 

87 The WFD distinguishes between the following types of exemptions for a water body:  
Article 4(4) –Time exemptions for achieving the objectives. 
Article 4(5) – Exemptions by setting less stringent environmental objectives. 
Article 4(6) – Exemptions from the obligation not to deteriorate status, allowing for a temporary deterioration in status if resulting 
from unforeseen circumstances. 
Article 4(7) – Exemptions from the obligation not to deteriorate status or not to prevent the achievement of good status, due to 
new modifications of the physical characteristics of a water body, alterations to levels of groundwater and sustainable human 
development activities. 
88 Finland, Luxembourg, the Netherlands, Romania, Slovakia and Sweden. 
89 Finland, France, Germany, Latvia, Romania, Sweden. 
90 Austria and Czechia. 
91 Belgium, Germany, Italy, the Netherlands. 

69 

 
 
The number of exemptions from the obligation not to deteriorate status or not to prevent the achievement 
of good status applied under Article 4(7) has increased in four Member States92 and decreased in two93. For 
the remaining Member States, there is no change in the number of exemptions under Article 4(7) or it is not 
possible to compare. This could point to the fact that Member States are not always applying this exeption 
when implementing new projects. 

Application of exemptions in Surface Waters 

Exemptions  according  to  WFD  Article  4(4)  are  applied  for    surface  water  bodies  in  all  Member  States 
assessed. For the countries with complete and partially complete electronic reporting, the share of surface 
water bodies that has been exempted under Article 4(4) is around 44% for ecological status and 39% for 
chemical  status  (see  figure  4-1  below).    Consequently,  this  type  of  exemptions  is  the  one  that  is  most 
frequently used. As shown in Figure 4-2, for surface water bodies, technical feasibility , natural conditions  
and disproportionate costs  are the most used justifications for applying this type of exemption.94 The main 
pressures causing the application of exemptions under Article 4(4) in surface water bodies are atmospheric 
deposition, agriculture, urban wastewater, diffuse urban run-off, and plants included under the scope of the 
Industrial Emissions Directive. 

Exemptions under Article 4(5) are applied in the surface water bodies of most Member States assessed 
(1495 out of 20). For the countries with complete and partially complete electronic reporting, the share of 
surface water bodies that has been exempted under Article 4(5) is around 9.3% for ecological status and 
0.3% for chemical status (Figure 4-1 below). As shown in Figure 4-2, for surface water bodies, infeasibility  , 
and  disproportionate  costs    are  used  as  justifications  for  applying  this  type  of  exemption.96  The  main 
pressures reported causing the application of exemptions under Article 4(5) in surface water bodies are urban 
wastewater, diffuse urban run-off, agriculture, forestry and transport. 

92 Hungary, Italy, Slovakia and Sweden. 
93 The Netherlands and Spain. 
94 Percentages refer to Member States with complete electronic reporting.  
95 Austria, Denmark, Estonia, Finland, France, Germany, Hungary, Italy, Latvia, Poland, Romania, Slovakia, Spain, Sweden. 
96 Percentages refer to Member States with complete electronic reporting. 

70 

 
 
Figure 4-1. Share of exemptions applied per Article of the total number of delineated surface water bodies in 
the third RBMPs (countries with complete and partially complete electronic reporting) 

Exemptions under Article 4(6) have been much less applied and only four97 out of the 20 Member States 
assessed. as illustrated in Figure 4-1 above. As shown in Figure 4-2, for surface water bodies, accidents , 
natural causes , and force majeure (0.01% of all reporting surface water bodies for ecological status) are 
used as justifications for applying this type of exemption.98 

Exemptions according to WFD Article 4(7) are applied to projects in the surface water bodies of eight99 
out of the 20 Member States assessed. For the countries with complete and partially complete electronic 
reporting, the share of surface water bodies that has been exempted under Article 4(7) is around 0.1% for 
ecological status. As shown in Figure 4-2, for surface water bodies, sustainable human development  and 
new modifications, are used as justifications for applying this type of exemption to surface water ecological 
status.100 

97 Hungary, Italy, the Netherlands, Spain. 
98 Percentages refer to Member States with complete electronic reporting.  
99 Austria, Denmark, Germany, Italy, Poland, Slovakia, Spain, Sweden. 
100 Percentages refer to Member States with complete electronic reporting. 

71 

 
 
 
Figure 4-2. Share of exemptions type of the total number of surface water bodies in the third RBMPs (countries 
with complete and partially complete electronic reporting, more than one exemption may apply to a water body) 

Source: WISE electronic reporting  

Application of exemptions in Groundwaters 

Exemptions according to WFD Article 4(4) are applied by all Member States assessed, except for Latvia 
and Lithuania. As shown in figure 4-3 above, for the countries with complete and partially complete electronic 
reporting, the share of groundwater bodies that has been exempted under Article 4(4) is around 9.9% for 
quantitative status and 23% for chemical status. As shown in Figure 4-4, for groundwater bodies, technical 
feasibility , natural conditions  and disproportionate costs  are used as justifications for applying this type of 
exemption.  101  The  main  pressures  reported  causing  the  application  of  exemptions  under  Article  4(4)  in 
groundwater bodies are agriculture and contaminated sites or derelict industrial sites. 

Exemptions according to WFD Article 4(5) are applied in the groundwater bodies of eight102, out of the 20, 
Member States assessed. For the countries with complete and partially complete electronic reporting, the 
share of groundwater bodies that has been exempted under Article 4(5) is around 1% for quantitative status 
and 3.4% for chemical status (Figure 4-3). As shown in Figure 4-4, for groundwater bodies, infeasibility , and 
disproportionate costs are used as justifications for applying this type of exemption. 103 The main pressures 

101 Percentages refer to Member States with complete electronic reporting.  
102 Czechia, Estonia, France, Germany, Italy, Latvia, Poland, Spain. 
103 Percentages refer to Member States with complete electronic reporting.  

72 

 
 
 
reported causing the application of exemptions under Article 4(5) in groundwater bodies are agriculture and 
contaminated sites or derelict industrial sites. 

Figure 4-3. Share of exemptions applied per Article of the total number of delineated groundwater bodies in the 
third RBMPs (countries with complete and partially complete electronic reporting) 

73 

 
 
Figure 4-4. Share of exemptions type applied per Article of the total number of groundwater bodies in the third 
RBMPs (countries with complete and partially complete electronic reporting, more than one exemption may 
apply to a groundwater body) 

Source: WISE electronic reporting  

Exemptions according to WFD Article 4(6) are applied in the groundwater bodies of six104 out of the 20 
Member States assessed. For the countries with complete and partially complete electronic reporting, the 
share  of  groundwater  bodies  that  has been  exempted  under  Article  4(6) is  around  0.2%  for  quantitative 
status and none for chemical status (Figure 4-3).  As shown in Figure 4-4 for groundwater bodies, natural 
causes , and force majeure  are used as justifications for applying this type of exemption.105 

Exemptions according to WFD Article 4(7) are applied in the groundwater bodies of six106 out of the 20 
Member States assessed. For the countries with complete and partially complete electronic reporting, the 
share of surface water bodies that has been exempted under Article 4(7) is around 0.4% for quantitative 
status and none for chemical status (Figure 4-3).  As shown in Figure 4-4, for groundwater bodies, sustainable 
human development  and new modification  are used as justifications for applying this type of exemption.107 

Only Latvia applied exemptions according to Article 6(3) of the Groundwater Directive on the grounds of 
artificial  recharge  /  augmentation  (0.02%  of  all  reporting  groundwater  bodies  for  chemical  status).  The 

104 Belgium, Denmark, Finland, Germany, Poland, Slovakia. 
105 Percentages refer to Member States with complete electronic reporting.  
106 Germany, Hungary, Poland, Romania, Spain, Sweden. 
107 Percentages refer to Member States with complete electronic reporting. 

74 

 
 
 
pressures reported causing the application of exemptions under Article 6(3) are recharges and public water 
supply. 

Justification of exemptions 

As  required  by  WFD,  the  reasons  for  applying  exemptions  under  Article  4,  paragraphs  (4)  to  (7)  shall  be 
specifically  set  out  and  explained  in  the  RBMPs.  This  implies  that  the  exemptions  should  be  based  on 
appropriate, evident and transparent criteria or methodologies and shall be justified in detail in the RBMPs. 
This  is  particularly  the  case  for  the  application  of  Article  4(5)  which  allows  to    lower  the  environmental 
objectives, for which the WFD implies a thorough and well documented demonstration of disproportionate 
cost and unfeasibility criteria, and evidence that all possible measures not disproportionately expensive or 
infeasible have been implemented. This also applies to the use of exemptions under Article 4(7) WFD for 
new  projects,  which  must  include  detailed  justifications,  detailing  cumulative  effects,  the  assessment  of 
better environmental options, and the measures taken to mitigate the adverse impacts of new developments. 
In addition, the WFD requires that any exemption applied is  regularly reviewed and does not permanently 
exclude  or  compromise  the  achievement  of  the  environmental  objectives  in  other  water  bodies,  and 
guarantee at least the level of protection provided for in other EU environmental law. 

Compared to the second RBMPs, there have been some improvements in the  methodologies used for the 
application of exemptions for surface and groundwater bodies. Specifically, following previous Commission 
recommendations,  out  of  the  20  Member  States  analysed  in  this  report,  18  provide  justifications  on 
exemption at water body level108 and 11 of these  have provided more detailed justifications109. However, 
some Member States do not provide sufficient details on the justification in any of the RBMPs assessed and 
some provide sufficient information in some instances and insufficient details in others.  

4.2  Economics 

The WFD addresses the economic aspects mainly  through two main articles: Articles 5 and 9, addressing 
respectively the economic analysis of water use and the recovery of water services’ costs, although, as further 
detailed below, this division is not clear-cut.  

Article 5 requires Member States to undertake an economic analysis of water use. The law also establishes 
that the reports must contain enough information in sufficient detail to support the assessment of the cost 
recovery for water services and related obligations  as well as the judgements on the most cost-effective 
combination of measures in respect of water uses to be included in the Programme of Measures, PoMs.  

WFD article 9(1) establishes that MS “must take account of the principle of recovery of the costs of water 
services, including environmental and resource costs, […] and in accordance with the polluter-pays principle” 
(PPP). In addition, it establishes that: 

•  Water pricing policies must provide adequate incentives for users to use water resources efficiently; 

and 

•  Different  water  uses  –  disaggregated  into  at  least  industry,  households  and  agriculture,  must 

adequately contribute to the recovery of the costs of water services.  

The progress on the economic issues was limited in the set of 1st RBMPs. In its overall assessment of the 
programming period of the set of second RBMPs110, the Commission noted across-the-board improvements 

108 Lithuania and Latvia do not provide justifications at water body level. 
109 Austria, Belgium, Estonia, France, Germany, Italy, Luxembourg, the Netherlands, Poland, Romania, Slovakia. 
110 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2019%3A095%3AFIN  

75 

 
 
 
in the economic aspects of the WFD, but also significant gaps in translating these improvements in economic 
analysis  into  concrete  measures.  It  concluded  that  further  progress  in  the  economic  underpinning  of  the 
RBMPs, specifically the PoMs, would  greatly facilitate water-related  decisions and investments needed to 
achieve the WFD objectives. 

Water services and water uses 

A  sound  definition  of  water  services  and  water  uses  is  the  basis  for  a  solid,  transparent  and  correct 
implementation of Article 5 and Article 9 requirements, although the implications may go further than that 
(e.g. a good identification of water uses should be based on the outcomes of the required assessment of 
pressures and impacts of activities on water bodies). 

Water supply and sanitation services were recognized as (broad) water services in all 20 Member States. 
As  a  result,  these  services  were  included  (either  separately  or  jointly) in  the  cost  recovery  analysis  in  all 
Member States, but Latvia (which did not report its cost  recovery analysis). In addition, 4 Member  States 
(Belgium, Czechia, France and Italy) also reported a sectoral disaggregation at least into industry, households 
and agriculture. In 3 Member States (Hungary, Lithuania and Spain) there was no real sectoral disaggregation, 
but supply for irrigation  was recognized as a separate water service. 

In contrast, fewer MS have reported specific “individual” water services, be it self-supply, or storage and 
impoundment, or other services which are also water uses. While for a part this may reflect their (lack of) 
relevance for the RBD(s) in question, it may also reflect a lack of transparency on the economic aspects of 
these  services,  including  their  pricing,  and  consequently  their  efficiency  of  provision,  their  impact  on  the 
efforts to meet the environmental objectives and some untapped financing potential: if these services are 
actually in place in the country, but are not reported or identified in water policy as such, there may be some 
provision  costs (e.g.  storage  infrastructure)  that  could  be  covered  by  the  users  of  the  service through  an 
appropriate economic instruments, which is not the case today (see also section on financial cost recovery). 

The water services identified are depicted in Figure 4-1 below. 

Table 4-5. Water services identified in RBMPs, and included in cost recovery analysis 

Water services identified by the WFD 

The  “broad  water  services:”  Overall  water  supply  services  and  overall 
wastewater services (jointly or both separately) 

As  regards  water  supply  services:  Impoundment  and  storage  reported  as 
distinct water services 

“Self-service”  (“self-abstraction”  and  on-site  water  treatment  for  re-use 
purposes) recognised as separate water services 

A water service is reported other than the above ones, while that use does 
not directly correspond  to the  list of water services mentioned in WFD art 
2(38) 

Identified in 
RBMPs? 

Included in cost 
recovery assessment? 

No. of MS 

No. of MS 

20 (all) 

19 

7 

8 

7 

1 

2 

4 

In relation to the identification of water uses (see Figure 4-5), these were not reported, or not specifically 
referred to, in Belgium, Denmark and Finland. As it can be seen in the graphs below, there is no common 

76 

 
practice across MS as regards the identification and reporting of water uses, as a variety of different water 
uses is reported in different Member  States. The water uses that were most reported are manufacturing 
industry, agriculture (excluding irrigation), hydropower, wastewater treatment (excluding self-services) and 
drinking water supply. As a general rule, it is unclear whether RBMPs actually made a distinction between 
“water  uses”  and  “water  use  sectors”;  the  overall  impression  is  that  these  two  terms  are  often  used  as 
synonyms.  

It  should  be  noted  that  an  incomplete  identification  of  water  uses  might  result  in  the  following 
implementation issues for Member States: 

• 
• 
• 

Incomplete understanding of water uses in the country, including their economic significance; 
Incomplete understanding of the pressures on water ecosystems; 
Incomplete understanding of the  contribution of each water use  sector to pollution and water 
resource use, resulting in turn in an incomplete understanding of environmental and resource costs 
and in an incomplete application of the polluter-pays principle; 

•  potentially higher bills for paying for the pollution costs or that this part of water services’ cost is not 

recovered at all. 

77 

 
 
Figure 4-6. Water uses reported in RBMPs

Source: third RBMPs electronic reporting and data mining of PDF reporting

78 

 
 
Economic Analysis 

The assessment shows some progress with the reporting on the economic analysis, particularly 
in 9 Member States in all RBDs, and in some RBDs in 3 Member States (see Figure 4-6 below). 

Figure 4-7. Reporting of progress in the economic analysis 

Source: third RBMPs electronic reporting 

In contrast the assessment of the compliance with the requirements included in the WFD (annex 
III) reveals a less positive picture. Overall, no Member State covers all items listed in the law with the 
actual  coverage  varying  across  Member  States  (fulfilled  different  combinations  of  requirements. 
Within a Member State, the coverage tends to be addressed in a (near) homogenous way in all RBDs. 

The items that are most commonly assessed are as follows: 

•  Volume  estimates  associated  with  the  various  water  services  (13  Member  States),  also 

differentiated over user types/ sectors (12 Member States);  

•  Cost  estimates  associated  with  the  various  water  services  (12  Member  States), 

differentiated over user types or sectors in 8 Member States; 

•  Estimates of the potential costs of relevant measures (12 Member States); however, these 

estimates are differentiated only in 4 Member States; 

•  Price estimates associated with the various water services (11  Member States); however, 
these estimates were differentiated over user types or sectors in 5 Member States only; 
•  Estimates  of  relevant  investment  including  forecasts  of  such  investments  (10  Member 
States); differentiated over water services in 6 Member States, and differentiated over supply 
sources  and  distribution/user  types  in  2  Member  States  and  3  Member  States  only, 
respectively.  However,  reporting  on  investments  needs  and  forecasts  often  appears  to  be 
rudimentary, as only total figures are often provided. 

Overall, long-term forecasts of water supply were found in 7 Member States, differentiated over 
source type in 5 Member States and long-term forecasts of water demand were found in 8 Member 
States, differentiated over user types or sectors in 6 Member States. 

Judgments  about  the  most  effective  combination  of  measures  are  only  reported  in  6  Member 
States. 

79 

 
 
No information at all on Annex III requirements was found in 2 Member States. 

Overall, the assessment confirms that thanks to the WFD, the economic analysis has become a well-
established practice in all assessed MS and that continued progress has been made in this respect. 
Nevertheless, in many Member States economic analyses are still incomplete and underused. The link 
with key challenges and developments in the RBD appear mostly implicit or absent.   

Overall, MS seem to be more familiar with volume estimates, cost estimated associated with water 
services, estimates of potential costs of measures, price estimates of water services and estimates 
of  relevant  investments.  In  contrast,  long  term  forecasts,  be  it  of  water  supply  or  demand,  are 
reported by a minority  of  Member  States, suggesting that European RBMPs are still  struggling  in 
developing a long-term perspective of water management – which would be crucial, in particular 
in view of climate change. 

Water pricing and incentive function 

In the assessed Member States, tariffs for water and sanitation services111 can take either the form 
of  one  tariff  covering  both  services  (Austria112,  Czechia,  Denmark,  France,  Hungary,  Lithuania, 
Luxembourg, the Netherlands, Poland, Slovakia) or two distinct tariffs for water supply on the one 
hand,  and  sanitation  on  the  other  (Austria,  Belgium,  Croatia,  Germany,  Italy,  Sweden);  this  is  also 
shown in the graph below. In the case of Romania, it is not clear whether one tariff only is in place 
for the two services or two separate prices are applied. Four Member States (Estonia, Finland, Latvia 
and Spain) do not report about the basis for charging for water and sanitation services. 

RBMPs often make references to a national pricing framework in place, which applies to all RBDs (e.g. 
Spain); the entity in charge of setting prices may vary depending on the Member States – for example, 
prices can be set by municipalities or by a specific authority  – and this might create a tension between 
the need to have a uniform pricing framework at the national level and the need to adapt to local 
circumstances. 

111 To be noted that the reporting is usually focussed on "broad" services only and not on "individual" services - this holds 
even more so for info on pricing. 
112 In Austria, prices for Water and Sanitation Services are set at the local level, which results in a high variability of tariff 
structures and rates. As a result, both categories are present (one integrated bill for WSS, or distinct prices for water 
supply and sanitation) 

80 

 
 
Figure 4-8. Basis for charging Water and Sanitation Services (WSS) in EU MS 

In  terms  of  tariff  structure,  in most  assessed  Member  States (Austria,  Belgium, Czechia,  Croatia, 
Denmark, France, Germany, Hungary, Italy, Lithuania, Luxembourg, the Netherlands, Slovakia), tariffs 
for WSS take the form of integrated tariffs made of a fixed component (independent of volume) and 
a  volumetric  component  (unit  price  per  m3).  In  most  of  these  Member  States,  the  latter  is  not 
differentiated based on consumption tiers (i.e. the same rate applies to all consumption levels); in 
France and Italy, the volumetric component increases with increasing consumption tiers, whereas in 
Belgium  this is  the  case  for  the  household  sector  only.  In  Austria  and  Czechia,  in  some  locations, 
integrated tariffs are not in place, and volumetric tariffs (unit price per m3) are applied. In Romania, 
Sweden and Poland,  volumetric tariffs are applied. In 4 Member States (Estonia, Finland, Latvia and 
Spain) the tariff structure was not reported. This is also shown in the graph below. 

Figure 4-9. Tariff structure in EU Member States 

81 

 
 
 
Different tariff levels are applied to the different  use sectors in Austria, Belgium, Hungary, Italy, 
Luxembourg, Poland113 and Sweden; no information on such differentiation was found in the other 
assessed Member States.  

In France, RBMPs also provide average rates  for irrigation water tariffs (unit prices per m3) in all 
assessed RBDs; in Italy, some RBMPs provide a qualitative description of irrigation water tariffs (either 
volumetric or flat rates, depending on location and managing entity). 

With  the  exception  of  Germany,  where  such  information  is  not  reported,  environmental  charges 
(including water abstraction, pollution and other charges) are in place in all assessed Member States.  

Detailed  information  on  structure  and  rates  is  provided  in  10  Member  States  (Belgium,  Czechia, 
Denmark,  France,  Hungary,  Italy,  Lithuania,  Luxembourg,  Latvia,  Slovakia),  whereas  a  qualitative 
description  is  provided  in  6  Member  States  (Austria,  Croatia,  Estonia,  the  Netherlands,  Romania, 
Sweden). No information was provided by the remaining Member States. 

Based on the information outlined above, the assessment of whether pricing arrangements at the 
Member States provide an incentive for a more efficient water use reveals that in general existing 
pricing arrangements appear underdeveloped in  as regards the policy objectives of the WFD as shown 
in Figure 4-9 below.  

Figure 4-10. Do pricing arrangements in place in EU Member States provide an incentive for a more 
efficient water use? 

Overall, the results of the assessment clearly indicate that the role of water pricing as an instrument 
to provide an incentive for a more efficient water use is not systematically considered in EU Member 
States, and this is likely to imply that these instruments are still underused in the policy mix to improve 
the  overall  efficiency  of  water  use.  In  most  Member  States,  the  RBMPs  only  provide  a  general/ 
qualitative  assurance that  existing pricing  arrangements  provide  an  incentive for  a  more  efficient 
water  use.  In  some  cases,  it  is  assumed  that  pricing  arrangements  able  to  achieve  cost  recovery 
automatically provide also adequate incentives, as it was already observed in the second cycle – and 
while pricing levels able to achieve full cost recovery are indeed an incentive, some pricing structures 
(e.g.  increasing  block  rates)  are  more  effective  than  others  in  providing  an  incentive  for  a  more 
efficient  water  use  (e.g.  volumetric  rates  irrespective  of  consumption  levels),  although  full  cost 
recovery can be achieved in both cases. 

The fact that most Member States do not have pricing arrangements taking water scarcity conditions 
into account  can be seen as a symptom of this. The application of a “scarcity premium” to water 
tariffs (i.e. water tariffs can vary with scarcity conditions) were only reported in Croatia. In addition, 
water prices allow for the differentiation of prices over regions in 9 Member States, and this might 

113 PL: different tariff levels for industry and households; agriculture is not mentioned. 

82 

 
 
 
include  regions  with  different  water  scarcity  conditions;  at  the  same  time,  with  the  available 
information  it  is  not  possible  to  infer  whether  price  variations  over  regions  take  water  scarcity 
explicitly into account, or whether price variations are solely based on differences in financial costs. 
Similarly, water abstraction charges vary with the level of water scarcity only in one Member State. 

Financial cost recovery 

Financial  cost  recovery  of  water  and  sanitation  services  was  generally  well  documented  in  the 
assessed Member States, with  17 out  of the 20  Member States assessed providing financial  cost 
recovery rates for water and sanitation services. Nevertheless, some gaps or inconsistencies remain. 

As shown in Table 4-1 below, only in some Member States this information is also split by main water 
use  sector  (households,  industry  and  agriculture),  and  as  separate  rates  for  water  supply  and 
sanitation services (as opposed to overall cost recovery for water and sanitation services as a whole). 
Only  for  a  small  number  of  Member  States  a  “broader  cost  recovery  rate”  is  provided  which  is 
calculated  including  both  financial  and  environmental  and  resource  costs.  Not  all  Member  States 
reporting financial cost recovery rates also provide corroboration for such rates. Cost recovery rates 
are  very  rarely  reported  for  impoundment  (Spain),  self-service  abstraction  (Spain),  and  other 
individual water services (the Netherlands). A minority of Member States (Croatia, Italy, Latvia) did 
not report any financial cost recovery rates. 

Table 4-1 Financial and broader cost recovery rates provided by EU Member States 

Water 
service 

Financial cost recovery rates provided 

Broader cost recovery rates 
provided 

Overall rate 

Sectoral split 

Overall rate 

Sectoral split 

WSS as a 
whole 

DK, EE3, FR, HU, LT, 
PL, SE, SK 

FR, HU, PL 

EE, HU 

FR, HU 

HU 

HU 

With 
corroboration 

Drinking 
water supply 

AT, BE, CZ, DK, DE, ES, 
FI, FR, LT, LU, NL, RO, 
SE, SK 

BE, FR, RO 

ES, FR, RO 

FR1 

FR 

ES, FR 

BE, FR, RO 

ES, FR, RO 

FR 

ES, FR 

ES2 

ES2 

FR1 

FR1 

FR1 

With 
corroboration 

AT, CZ, DK, DE, ES, FR, 
LT, NL, SE, SK 

Sanitation 

AT, BE, CZ, DK, DE, ES, 
FR, LT, LU, NL, RO, SE, 
SK 

With 
corroboration 

AT, CZ, DK, DE, ES, FR, 
LT, NL, SE, SK 

Irrigation 

With 
corroboration 

Other 
individual 
water 
services 

With 
corroboration 

ES2 

ES2 

NL 

NL 

83 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Impoundment 

With 
corroboration 

Self-service 
abstraction 

With 
corroboration 

No rates 
provided 

ES 

ES 

ES 

ES 

HR, IT, LV 

ES 

ES 

ES 

ES 

Notes: 1FR: in most RBMPs; 2ES: in at least 1 RBMP; 3EE: rates are provided but, as observed in the MS report, 
the methodology applied raises doubts on its adherence to WFD prescriptions for the assessment of cost 
recovery. 

Both operational and capital costs of water and sanitation services were reported in 16 out of the 20 
Member States assessed, although the quality and completeness of financial cost figures are rather 
variable across countries. 

The  reporting  on  the  revenues  of  water  and  sanitation  services  is  much  less  developed  and 
complete,  with  8  Member  States  (Denmark,  Finland,  Germany114,  Luxembourg,  Latvia,  Poland, 
Romania, Sweden) not reporting any figure. This seems to indicate a more limited understanding on 
this key component of the implementation of cost recovery. 

Similarly, reporting of information on subsidies to water services was still not homogenous across 
the assessed EU MS as shown in Figure 4-10. 

Figure 4-11. Reporting on subsidies to water services in EU MS 

Source: third RBMPs electronic reporting and PDF reporting 

According  to  Article  9.4  of  the  WFD,  Member  States  can  choose  not  to  apply  the  "cost  recovery 
principle" for some water services, in cases where this does not compromise the purposes and the 
achievement  of  the  objectives  of  the  WFD.  Regrettably,  Article  9(4)  exemptions  on  “established 
practices” were not reported in most of the assessed Member States. In 3 Member States, some these 
exemptions are mentioned, although details are not provided. 

Based  on  the  above,  it  has  to  be  noted  that  in most  Member  States  the  financial  cost  recovery 
assessment was conducted only for water supply and sanitation services115, even in those Member 

114 For Germany, some information on revenues is provided in the Weser and Elbe RBMPs. 
115 With the only noteworthy exception of the Netherlands, which conducted the cost recovery assessment for all water 
services identified in the RBMPs. 

84 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
States which identified other water services such as for example self-supply, storage/ impoundment 
or other water use activities.  

It is clear that some of the requirements pose challenges to Member States. These notably include 
the i) provision of adequate incentives to use water efficiently through pricing mechanisms;  ii) the 
inclusion  of  water  services  other  than  water  and  sanitation  and  iii)  the  explanation  of  the  use  of 
mitigation factors and “established practices” into cost recovery assessments. In addition, different 
levels of progress are also observed for:  i)  the assessment of environmental and resource costs and 
the application of the polluter-pays principle, ii)  the assessment of “adequate contribution” of water 
uses and water user sectors. The collected information does not allow for formulating explanations 
on why these requirements are particularly arduous for Member States – especially considering that, 
on some topics, guidance has been provided over the years through the CIS process.  

Investments needs and funding of the Programmes of Measures 

For  Member  States  that  reported  electronically,  some  information  on  the  funding  needs  for  the 
implementation WFD – based on the estimation of the funding needs to implement the third PoMs - 
is available  and shows that an increase in funding to implement their measures  compared to the 
second RBMPs. This would also include the EU financial contribution. However, it should be noted that 
the information is either incomplete, contradictory, or even missing for some Member States. For the 
10 Member States for which information is available, the cumulative funding needs over the period 
2022-2027  is  reported  to  be  EUR  89.4  billion  (approximately  EUR  15  billion/year)  but  given  the 
limitations in data this is likely to be an underestimation.  

For  all  Member  States,  it is  unclear  from the  reports  whether the  countries  have  already  secured 
these  funds  but  given  that  funding  has  been  systematically  highlighted  as  major  barrier  in  the 
implementation of the previous Programmes of Measures, it can be assumed that this is not the case. 

This is also consistent with OECD data and European Commission analysis that shows – for the EU 
as a whole – a failure to meet the annual investment needs that are estimated to EUR 77 billion per 
year, with a financing gap currently estimated at around EUR 25 billion per year116. It should be noted 
that this amount is largely  based on needs for water supply  and sanitation, while  costs for other 
measures  related  to  the  implementation  of  the  WFD  and  the  FD  may  not  be  fully  reflected. 
Regrettably, for most Member States, the RBMPs do not contain a clear investment planning that 
considers long-term water supply and demand forecasts based on the latest climate scenarios and 
climate adaptation strategies. More generally, the reported economic analyses do not clearly show 
how cost-effectiveness assessments have informed the selection of measures in the PoMs (which 
should  otherwise  entail  many  more  investment  measures).  Further  progress  in  the  economic 
underpinning of the PoMs would greatly facilitate water-related decisions and investments. 

5.  Transboundary cooperation under the WFD  

Effective international cooperation is key to the cost-effective achievement of the objectives of the 
WFD.  Such  cooperation  is  heterogeneous  within  Europe  ranging  from  the  sole  recognition  of  the 
international character of a river basin to more developed formal international commissions with a 
dedicated secretariat, human and financial resources, and their own projects and activities. 

116 DG ENV, Environmental investment needs, financing and gaps in the EU-27 – update 2024 (internal analysis). Note 
that the next Environmental Implementation Report planned for Spring 2025 (EIR 2025) will include further information 
and updates publicly available on the topic. 

85 

 
 
There  are  75  iRBDs  and  30  sub-basins  in  the  EU.  Based  on  their  level  of  cooperation,  four  main 
categories  were  identified.  An  overview  of  different  types  of  international  cooperation  is  given  in 
Table 5-1.  

Table 5-1. Different types of international coordination in relation to the WFD 

Category 

1 
2 
3 
4 

Formal international 
agreement 
Yes 
Yes 
Yes 
No 

International coordinating 
body 
Yes 
Yes 
No 
No 

iRBMP produced 

Yes 
No 
No 
No 

The  analysis  of  the  third  RBMPs  shows  a  certain  stability  in  the  dense  institutional  network  of 
transboundary  coordination  mechanisms  for  different  iRBMPs,  with  few  example  of  existing 
arrangements  that  were  “upgraded”.  In  certain  cases,  however  Member  States  reported  that  the 
agreements in place were considered to be insufficient, while cooperation with non-EU countries tends 
to  be in  some  cases  focused  on  specific  issues  rather  than  being  framed  broadly in  line  with the 
integrated water resoruces management approach of the WFD.  

Noticeably, international coordination has been expanded in 2 iRBD through the ratification of new 
agreements: 

•  Romania and Serbia signed an agreement regarding cooperation in the field of sustainable 
management of transboundary waters in 2019. Both countries belong to the Danube iRBD 
and Romania had bilateral agreements with all its neighbouring countries with the exception 
of  Serbia.  The  agreement  established  the  Romanian-Serbian  Commission  for  sustainable 
cross-border  water  management  and  hosts  two  sub-committees  (Sub-committee  for 
Hydrometeorology  and  Quantitative  Water  Management;  and  Sub-committee  for  Water 
Quality Protection).  

•  Hungary and Serbia signed an agreement in 2019 and established a bilateral commission. It 
hosts a Water Management Sub-committee, and a Water Quality Protection Sub-committee. 
The two countries are part of the Danube iRBD. 

•  Poland  and  Belarus  signed  an  agreement  which  covers  many  aspects  of integrated  water 
resources management in the Vistula iRBD. This agreement is the achievement of 20 years 
of negotiations between the 2 countries.  

•  Poland and Ukraine signed 2 agreements to complement the State-level agreement in place 
since 1996: on 14th August 2019 between the Regional Water Resources Authority of the Bug 
and  San  rivers  in  Lviv  and  the  Regional  Water  Management  Board  in  Lublin  and  on  19th 
February 2021 between the Regional Water Management Board in Rzeszów and the Regional 
Water  Resources  Authority  of  the  Bug  and  San  River  of  the  Republic  of  Ukraine.  Both 
agreements apply on tributaries within the Vistula iRBD. 

Among the 20  iRBD assessed, 3 have an agreement which has been identified by local authorities 
as insufficient: 

•  France and Spain signed an administrative agreement on water management, on February 
15, 2006, for the Garonne iRBD (waterbodies of the Bidasoa, Nive, Nivelle, Garonne, Ariège 
and Segro) though it is limited to consultation between authorities, public participation and 
sharing of experiences.  

86 

 
 
•  France and Switzerland signed an agreement in 1963 to protect Lake Geneva, which is part 
of  the  Rhone  iRBD:  cooperation  is  undertaken  via  the  CIPEL8.  However,  the  cooperation 
between the Rhone-Mediterranean RBD and Switzerland is hampered by the fragmentation 
caused  by  multiple  administrative  agreements  for  several  small,  shared  sub-catchments 
Discussions  are  ongoing  on  the  framework  to  be  established  to  support  an  effective 
governance. 

•  According  to  the  Polish  Vistula  RBMP,  cooperation  with  the  Russian  side  in  the  field  of 
transboundary waters requires re-formalisation, the establishment of a new legal framework 
and  cooperation  bodies,  but  unfortunately  the  negotiations  failed  and  as  a  result  were 
suspended.  

International coordination is higher for surface water bodies (rivers, lakes, transitional waters) while 
it remains very limited when it comes to transboundary groundwaters. Many iRBD have not identified 
cross-border groundwaters. Where transboundary aquifers are identified (e.g., Scheldt, Vistula, Elbe, 
Danube),  characterisation  is  left  to  bilateral  discussions.  There  is  also  limited  cooperation  on 
monitoring of qualitative and quantitative indicators for groundwaters and status assessment.  

The analysis also shows that international RBMPs have been developed for the most important iRBDs 
and provide the umbrella for the coordination of cooperation among Member States with notiable 
improvements in several key areas. 

Data sharing117, coordinated monitoring and joint research projects among neighbouring countries 
have continued to expand. The intensity of bilateral or multilateral coordination varies depending on 
the  existence  and  leadership  of  international  basin  commissions,  thereby  ranging  from  the  mere 
acknowledgement of the national/regional monitoring networks, to coordinated sampling protocols 
as  on  the  Danube  iRBD.  Geographic  Information  System  (GIS)-based  databases  to  collect  and 
compare information from Member States sharing the same iRBD, as well as web interfaces open to 
the public are also being developed and improved. Cooperation continues also as regards the joint 
characterisation and status assessments for the iRBDs, including through discussions on priority 
indicators and threshold values relevant at the iRBD level. The latter however does not implies full 
convergence on the assessment among the different riparian countries. The cooperation mechanisms 
help to identify the discrepancies and compare methodologies, but reaching a consensus is not always 
possible  as  the  priority  indicators  and  threshold  values  are  first  and  foremost  driven  by  national 
guidance,  decrees  or  regulations,  to  ensure  comparability  and  homogeneity  of  reporting  within  a 
Member State rather than interest in international harmonisation. Coordination is also reported by 
the Member States as regards the joint management of extreme or rare situations such as pollution 
accidents, floods or low flows. On the latter, it should be noted that with some exceptions, such as 
the Albufeira Convention between Portugal and Spain, cooperation in the relevant iRBDs on tackling 
water scarcity and drought is so far limited and should be further encouraged. 

There has been less progress in international coordination on the Programmes of Measures. With 
the  exception  of  the  Danube  iRBMP  which  defines  measures  of  international  relevance,  the  other 
iRBMPs just compile the measures establisheds autonomously by each Member State and it is hence 
unclear  the  extent  to  which  coherence  is  guaranteed  between  measures  taken  by  upstream  and 
downstream countries. For instance, when it comes to nutrients load reduction – which is commonly 
recognized as a joint significant water management issue - most transboundary cooperation is still 
lacking a minimum of needed homogeneity in monitoring, indicators, agreed objectives and/or agreed 
measures to establish clear quantified contributions to needed load reductions across the borders. 
Upstream  Member  states  are  not  reporting  on  the  possibly  needed  contributions  in  nutrient  load 

117 The data exchange relates to climate, hydrology, water quality parameters, groundwater levels and, sometimes, biota. 

87 

 
 
reduction  for  downstream  objectives  in  their  national  RBMPs  but  focus  completely  on  their  own 
waterbodies. There are nevertheless positive examples to set up joint targets and commitments such 
as  in  the  Baltic  Sea118  or  the  joint  2018  strategy  of  Czechia  and  Germany  for  Elbe  (iRBD)  which 
includes agreed quantified annual goals, exemplary measures and a 10-points action plan. 

118 In the Ministerial Declaration of the 2024 Ministerial Meeting on the Baltic Sea Marine Environment, the Parties to the 
HELCOM Convention committed to “fully implementing, by 2027 at the latest, all nutrient input reduction measures 
necessary to achieve the net input ceilings (NICs)”. 

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SECTION B: 
FLOODS DIRECTIVE 

89 

 
 
 
6.  Flood risk management under floods directive (FD) - 
findings from second FRMPs 

6.1  Main elements of the Floods Directive 

The Floods Directive requires each Member State to take three steps: (a) scan its territory for flood 
risks, assess the potential adverse consequences of future floods for human health, the environment, 
cultural heritage, and economic activity, thereby identifying the Areas of Potentially Significant Flood 
Risk (APSFRs); then (b) map the flood extent and the potential adverse consequences; and finally (c) 
take measures to reduce the flood risk. 

These steps are reflected, respectively, in (a) the preliminary flood risk assessments (or PFRAs), which 
include the identification of areas of potential significant flood risk (or APSFRs119), (b) the preparation 
of flood hazard and risk maps, or FHRMs, and (c) the establishment of flood risk management plans, 
or FRMPs. These three steps are carried out over a six-year cycle. Once a cycle is finished, a new cycle 
begins owing to the changing nature of flood risk. 

This document provides an overview of the second Flood Risk Management Plans (FRMPs), as well as 
of the second Floods Risk and Hazards Maps (FHRMs), reported to the European Commission.  

Twenty-six Member States submitted on time their maps (FHRMs)120, while only 21 Member States 
submitted  their  second  plans  (FRMPs)  which  cover  the  period  2022-2027.  Similarly  to  the  WFD, 
implementation  of  the  FD  has  been  supported  by  informal  co-operation  under  the  Common 
Implementation Strategy (CIS)121. 

6.2  Assessment of the Flood Hazard and Risk Maps 

To recall, twenty-six Member States122 prepared and reported in time their  risk maps (FHRMs) and 
were subsequently assessed by the Commission. 

Flood hazard maps 

According to the law, Floods Hazard maps shall cover the geographical areas which could be flooded 
according to the following scenarios: (a) floods with a low probability, or extreme event scenarios; (b) 
floods with a medium probability (likely return period ≥ 100 years); (c) floods with a high probability, 
where appropriate. For each scenario, the elements to be shown on the hazard maps are (a) the flood 
extent; (b) water depths or water level, as appropriate; (c) where appropriate, the flow velocity or the 
relevant water flow. 

Most  Member  States  are  using  a  combination  of  historical  data,  hydraulic  modelling,  hydrological 
modelling, observed data and rainfall data to define the probabilities of flooding. All Member states 
have  developed  maps  for  floods  of  low,  medium,  and  high  probability.  The  return  periods  for  the 
respective scenarios vary depending on the source of flooding. 

119 On the basis of the identified APSFRs, since October 2023 the “Flood Risk Areas Viewer” provides a single gateway to 
the work done by the Member States under the Floods Directive, https://discomap.eea.europa.eu/floodsviewer/  
120 Greece did not report in time to be included in the Commission’s assessment of second FHRMs. In the meantime 
though, Greece reported its second FHRMs. 
121 https://circabc.europa.eu/ui/group/9ab5926d-bed4-4322-9aa7-9964bbe8312d/library/dd9b4484-2935-4ee8-b3ce-
72f844f3644c  
122 Greece did not report in time to be included in the Commission’s assessment of second FHRMs. In the meantime 
though, Greece reported its second FHRMs. 

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One important change since the first FHRMs is the switch in all countries assessed but one123 from 
PDF maps to exclusively GIS-based online map viewers, or to a mix of online GIS map viewers and 
downloadable  PDF  maps.  The  GIS-based  approach  has  increased  accessibility,  even  if  the  user 
friendliness of the map viewers varies. These differences in user friendliness can partly be explained 
by the intended use of the maps, i.e. if the map is intended for public use, expert use, or both. 

Most  Member  States  used  a  100-year  return  period  (or  1%  probability)  for  mapping  medium 
probability river floods. Only in Denmark (50 years), Italy (varies from 30 to 200 years), Finland (50 
to 100 years) and Malta (50 years) differ from the 100 years mentioned in the FD. 22 Member States 
have taken into account existing flood defences in preparing their flood maps124. There was no clear 
information  for  two  Member  States125.  A  range  of  probabilities  from  0.01%  to  0.5%  (10  Member 
States use 0.1% or 1 000 year return period) were used for extreme sea water flooding events, and 
a range between 5 to 50 year return periods for the high probability, i.e. the relatively frequent events.  

With regards to the hazard elements shown in the maps: flood extent is shown in all countries and 
water  depths in  all  except  two126,  though  this  information  is  provided  only  partly  by  five  Member 
States127. There has been progress in the mapping of fluvial floods and flood extent since in this cycle 
all Member States did it. Flow velocity, or relevant water flow – a useful feature for rescue services 
– although not strictly required by law was shown on the hazard maps of 8 Member States. 

Dedicated hazard maps for pluvial floods were prepared by six Member States at the time of the 
first  FHRMs,  now  12  Member  States  mapped  pluvial  floods128.  This  reveals  the  growing  attention 
Member States are assigning to flash floods of pluvial origin in urban areas. 19 of the 22 Member 
States129 with coastlines have produced specific sea water flood maps. Seven Member States130 
have combined the mapping of sea water floods with other relevant sources including Belgium and 
the  Netherlands  who  prepared  combined  fluvial  and  sea  water  flood  maps.  Based  on  documents 
reported by the Member States to EIONET131 as well as other sources reviewed, 16 Member States132 
have  taken  into  account  existing  flood  defences  in  preparing  their  sea  water  flood  hazard  maps. 
Regarding other sources of flooding, groundwater has been mapped by three Member States133 and 
artificial  water-bearing  infrastructure  (i.e.  dams  and  reservoirs)  failure  by  seven  Member 
States134. This is only a marginal improvement as compared to the first FHRMs where groundwater 

123 Hungary. 
124 Austria, Bulgaria, Czechia, Cyprus, Finland, France, Germany, Ireland, Lithuania, Luxembourg, Latvia, the Netherlands, 
Poland, Portugal, Romania, Slovenia, Slovakia, Spain and Sweden. The information was only found partly in Belgium, 
Denmark and Italy. 
125 Croatia and Hungary. 
126 Estonia and Lithuania. 
127 Italy, Malta, Portugal, Slovenia and Spain. 
128 Austria, Belgium, Bulgaria, Cyprus, France, Hungary, Ireland, Italy, Lithuania, Malta, Romania and Spain. 
129 These are Belgium, Bulgaria, Croatia, Denmark, Estonia, Finland, France, Germany, Ireland, Italy, Lithuania, Latvia, the 
Netherlands, Poland, Portugal, Romania, Slovenia, Spain and Sweden. In addition, Cyprus and Malta also have a coastline 
Greece’s FHRMs have not been assessed yet due to late reporting. 
130 Belgium, Bulgaria, Denmark, Estonia, Germany, the Netherlands and Slovenia. 
131 The European Environment Information and Observation Network (EIONET) is a partnership network of the European 
Environment Agency (EEA) and its 38 member and cooperating countries. Reportnet is EIONET’s infrastructure for 
supporting and improving data and information flows. The Central Data Repository (CDR), where Member States report, is 
part of the Reportnet. 
132 Belgium, Bulgaria, Cyprus, Denmark (partly), France, Germany, Ireland, Lithuania, Latvia, the Netherlands, Poland, 
Portugal, Romania, Slovenia, Spain and Sweden. 
133 Croatia, Hungary and Spain (only in the case of ES010). 
134 Belgium (only BEESCAUT_SCHELDE_BR), Bulgaria, Croatia, Italy (only ITI012, ITI024, ITI024, ITR171), NL, PL (only 
PL200 and PL6000) and Romania. 

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floods  and  floods  from  artificial  water-bearing  infrastructure  were  mapped  only  by  two  and  six 
countries, respectively135. 

Flood risk maps 

Article  6(5)  of  the  FD  says  that  flood  risk  maps  shall  show  the  potential  adverse  consequences 
associated  with  flood  scenarios  expressed  in  terms  of  (a)  the  indicative  number  of  inhabitants 
potentially affected; (b) type of economic activity of the area potentially affected; (c) IED installations 
and protected areas identified in Annex IV(1)(i), (iii) and (v) to Directive 2000/60/EC; and (d) other 
information which the Member State considers useful.  

Indicative numbers of inhabitants potentially affected have been identified by all Member States 
except Czechia and Malta (which will do so in the future). Some Member States136 only provided this 
information for medium probability flooding. Just below a third of the Member States excluded high 
probability  events  (i.e.  more  frequent  and  therefore  less  severe  flooding)  from  the  calculation  of 
inhabitants  potentially  at  risk  and  a  comparable  number  of  Member  States  did  the  same  for  low 
probability  flooding.  The  number  of  inhabitants  potentially  affected  by  medium  probability  fluvial 
floods across the European Union as a total has increased compared to the first FHRMs by about a 
million and a half to roughly 17 million inhabitants137. 

The type of economic activity of the area potentially affected is presented by all Member States; 
the  situation  largely  remains  similar  to  the  first  FHRMs  in  the  sense  that  information  is  mainly 
provided by showing land use on the maps. An example is the Netherlands, which used six clearly 
defined  categories:  agricultural  area,  forest  and  nature  area,  work  area,  recreational  area, 
infrastructure, and living area. Also, Sweden clearly categorized the economic activities: the risk for 
damage  has  been  considered  for  properties  (divided  into  industrial  and  other),  for  buildings,  for 
transport infrastructure (roads, railroads, and water supply), for forest and for agricultural land. Only 
four Member States138 quantified the economic damages. For example, Denmark’s national web-
GIS  portal  is  showing  the  economic  damage  (based  on  five  ranges  of  damage)  to  buildings, 
businesses,  infrastructure,  crops  and  livestock  for  each  of  the  three  scenarios  in  each  Area  of 
Potentially Significant Flood Risk (APSFR).  

Twenty-five Member States139 mapped the risk to industrial installations falling under the scope of 
the Industrial Emissions Directive (IED). Sixteen Member States reported the numbers potentially at 
risk, which is less than the number of countries that did so in the previous cycle. The total number of 
IED installations potentially affected under a medium probability scenario currently stands at 3 250, 
which is nevertheless slightly above the roughly 3 100 installations reported by 23 Member States 
for the first maps. 

Concerning risk to protected areas, all Member States140 except two141 show relevant information on 
their maps. 

135 However, additional security considerations may be at play with regards to floods from artificial water-bearing 
infrastructure. 
136 Czechia, France, the Netherlands and Slovakia. 
137 Excluding from the calculations the UK, which in the meantime left the EU, and HU, which did not provide population 
affected for the medium probability scenario at the time of the first FHRMs. 
138 Belgium (Flanders), Denmark, Netherlands and Romania. 
139 Except Czechia. 
140 It should be noted however that in Hungary, protected areas are not shown consistently in the FHRMs for bathing sites 
and abstraction for drinking water, however there are some PDF maps for specific locations. 
141 In Czechia, this is due to technical reasons to be lifted. Malta stated in a technical report that WFD protected areas are 
not located within the identified APSFRs and are therefore not considered to be at risk from flooding.  

92 

 
 
The largest change perhaps can be found in relation to cultural heritage. While in the first FHRMs, 
cultural heritage was considered by about half the Member States, under the second 25 of the 26 
Member States assessed142 included cultural heritage in their FHRMs. Several Member States show 
UNESCO’s world heritage sites. Some Member States go further and mapped much broader categories 
of patrimony. 

Although  not  explicitly  required  by  the  FD,  23  Member  States  considered  climate  change  for  the 
second  FHRMs  (of  which  15  considered  climate  change  for  coastal  flooding).  This  is  an  increase 
compared to the the first FHRMs where only 16 Member States did so. Sixteen out of the 23 Member 
States considered climate change for the medium probability scenario143; for the other two scenarios 
this was done less often; 13 Member States for the low probability scenario144 and 11 for the high 
probability scenario145. 13 Member States obtained climate change trend scenarios from the IPCC or 
other international and EU sources146 and 15 from national research programmes147. Nine Member 
States used both sources148. 

6.3  Assessment of the Flood Risk Management Plans 

Twenty-one  Member  States149  prepared  and  reported  in  time  their  FRMPs  to  be  included  in  the 
European Commission’s assessment of second FRMPs. 

The FD requires Member States to “establish appropriate objectives for the management of flood 
risks” and that FRMPs ‘…shall include measures for achieving the objectives established…’. Moreover, 
the Annex of the Directive requires Member States to include a summary of the measures.  

Seven Member States have kept the same objectives they had in their previous plans. For 14 Member 
States, objectives have just been slightly changed. Only in few cases, more substantial changes are 
seen.  

Compared  to  the  first  FRMPs,  there  has  been  little  change  in  the  administrative  level  at  which 
objectives have been set. Most Member States have developed objectives at national level, while a 
smaller number have adopted  an approach that sees national-level objectives adapted at UoM or 
FRMP level (see the figure 6-1 below).  

142 Except France, possibly owing to an error in compiling the databases. 
143 Austria, Belgium (partly), Bulgaria, Croatia, Cyprus, Denmark, Estonia, Finland, France, Hungary, Ireland, Lithuania, 
Malta, Poland, Portugal, Romania, and Sweden. 
144 Austria, Belgium, Croatia, Cyprus, Denmark, Estonia, Finland, Hungary, Ireland, Malta, Poland, Slovenia and Sweden. 
145 Austria, Belgium (partly), Croatia, Cyprus, Estonia, Finland, France, Hungary, Ireland, Lithuania, Malta. 
146 Bulgaria, Croatia, Cyprus, Denmark, Estonia, Finland, Italy (partly), Lithuania, Latvia, Portugal, Romania, Slovenia and 
Sweden. 
147 Belgium, Czechia, France, Hungary, Ireland, Malta, Poland. 
148 Croatia, Denmark, Estonia, Finland, Italy, Lithuania, Portugal, Romania, Slovenia and Sweden. 
149 The following Member States did not report in time to be included in the Commission’s assessment of second FRMPs: 
Bulgaria, Cyprus, Greece, Malta, Portugal and Slovakia. In the meantime, Bulgaria, Cyprus, Malta, and Portugal finalised 
their second FRMPs, however not in time to be included in this document. At the time of writing, Greece and Slovakia are 
yet to finalise their second FRMPs. 

93 

 
 
Figure 6-1. Level at which FRMP objectives are set  

Source: Member State reporting and FRMPs 

As regards the areas covered by the objectives150, there are few changes in comparison to the first 
FRMPs. Further, all Member States address the adverse consequences of floods in their objectives: 
almost  all  plans  provide  strong  evidence  of  this,  with  the  remaining  providing  some  evidence. 
Relatively few Member States directly address the reduction in the likelihood of flooding. Nearly all 
Member States refer to non-structural initiatives – that is, measures not involving civil engineering 
structures  such  as  raising  awareness,  ensuring  early  warning  systems  or  disaster  prevention  and 
response plans or spatial planning – in their objectives (see the figure 6-2 below). 

150 Broadly these are health, economy, the environment and cultural heritage. 

94 

 
 
 
Figure 6-2. Evidence of the focus of objectives 

When setting their objectives to reduce the  potential  adverse consequences  of floods, half of the 
Member States explicitly consider potential impacts on human health, cultural heritage, environment, 
and economic activity.  

Figure 6-3. Evidence that FRMP objectives address potential adverse consequences of floods  

Source: Member State reporting and FRMPs 

As regards quantitative targets, just few Member States set them: one example is Latvia, where 
there is a target to reduce the number of inhabitants affected and the area of public infrastructure 
facilities at risk of low probability floods by at least 40%. The Netherlands has a target to reduce, the 
risk of death to no more than 1 fatality per 100 000 citizens per year by 2050, for areas along main 
water  bodies  protected  by  flood  defences.  In  Lithuania,  indicators  linked  to  the  objectives  specify 
reductions in the number of inhabitants at risk, increasing areas protected from flooding, and reducing 
the number of hazardous facilities that may cause pollution in case of flooding: these imply reducing 
adverse consequences on human health, economic activity and the environment. 

95 

 
 
 
 
As shown in a figure above, in 15 Member States, there is strong evidence of objectives that refer 
to  non-structural  initiatives.  Several  common  trends  emerge,  the  most  common  of  which  is  the 
prioritisation of raising public awareness, which appears in nine Member States. In addition, improving 
knowledge is a recurring focus in six Member States, while land-use planning is highlighted in five 
Member States. Member States also emphasise the importance of developing flood forecasting and 
early warning systems. Furthermore, there is a widespread recognition of the need for improved crisis 
management, as seen in three Member States and emergency planning.  

Several Member States have objectives that address climate change, calling for enhanced resilience 
and adaptation. 

Are the FRMPs objectives specific and measurable? 

When  it  comes  to  assessing  whether  the  identified  objectives  are  specific  and  measurable,  the 
analysis shows limited progress as compared to the first FRMPs. 

Several Member States have objectives that refer to quantitative targets; in other cases, objectives 
are at least partially measurable. Some Member States identify indicators for their objectives, as in 
Czechia and Lithuania – both using the indicator Number of inhabitants at significant risk of flooding. 
In Poland, the FRMPs describe a chain linking objectives, sub-objectives, measure types and actions, 
and then indicators. Spain’s FRMPs link the objectives to groups of measures and provide indicators 
to track both objectives and measures. 

Nonetheless, the objectives for most Member States are only partly specific and measurable, and for 
a few, the objectives remain too general to be measurable. Positively, more than half of the Member 
States link their objectives to their measures. 

Achievement of flood risk management objectives 

Most of the assessed Member States provide, in their second FRMPs, at least some evidence of the 
progress towards the achievement of the objectives set in their first FRMPs. In many cases, the second 
FRMPs  refer  to  the  progress  of  the  measures  under  the  FRMPs,  rather  than  discussing  the 
achievement of objectives themselves. 

Figure 6-4. Evidence in the FRMP of the progress towards the achievement of objectives 

Source: MS assessments 

A few of the second FRMPs assessed provide data on reductions in flood risks from the measures 
implemented to achieve the objectives: this includes, for example, Czechia and Hungary.  

96 

 
 
Since  the  objectives  were  largely  not  quantified  in  the  first  FRMPs  and  as  several  measures  are 
ongoing and those finished are replaced with new ones, none of the Member States declared that 
their objectives have been reached. 

6.3.1  Measures for flood risk management 

While many Member States reported broadly the same numbers of measures as in the previous FRMP, 
a  few  reported  considerably  more  measures.  Only  Austria  reported  significantly  fewer  measures, 
decreasing by two thirds between the two reporting periods.  

As  required  by  the  FD,  Member  States  categorised  the  measures  as  either  prevention,  protection, 
preparedness, or recovery and review151. The distribution of measures reflects the different flood risk 
management strategies and priorities of the Member States (see Figure 6-5 below).  

Figure 6-5. Share of measures by measure aspect152 

Source: MS reporting to EIONET 

A general overview of all Member States indicates that protection measures are the most common, 
representing  on  average  34%  of  all  reported  measures,  closely  followed  by  prevention  measures 
(29%) and preparedness measures (27%). Less common are recovery and review measures, which 
represent 8% of all measures (2% of measures reported under the category 'other'). Comparing to 
the measures reported in the first FRMPs, the distribution of measure between categories appears to 
be changing. For example, while protection measures are still the most frequently reported in 2022, 
at  34%,  they  have  decreased  from  (41%)  in  2016.  Prevention  and  preparedness  measures  now 
account for a slightly larger share of the EU total at 29% and 27% respectively (increasing from 26% 
and 24%). The increased share of prevention and preparedness measures is not driven by a significant 
increase in one Member State in particular, but rather small increases in most Member States at the 
expense of few protection measures.  

151 An example of a prevention measure is to not allow new housing in flood prone areas via land use planning policies. An 
example of a protection measure is to build an embankment. An example of a preparedness measure is to improve the 
flood forecasting or warning system. An example of a recovery measure is clean up and restoration activities or health 
support actions after a flood. 
152 Owing to the distinction between individual and aggregated measures – and due to the inherent difficulty in averaging 
across measures of a varied nature, charts such as this one are of an illustrative value. 

97 

 
 
 
While many Member States have included clear and explicit descriptions of their measures, others 
have provided only general or limited information. Overall, only a few Member States provide clear 
information  on  what  their  measures  are  trying  to  achieve  (intended  effects)  or  how  (the  steps 
involved). This includes in particular Belgium, Estonia, Spain, Finland, Croatia, Hungary, Poland, and 
Sweden. On the other hand, some Member States, such as Austria and Germany, have not provided 
clear and explicit descriptions of their measures in terms of where, how, and by when they will be 
achieved. Generally, it was noted that structural measures were more specific than non-structural 
measures in Member States’ FRMPs.  

As regards the geographical scale or coverage of the measures, the assessment shows that overall, 
measures implemented at the level of the APSFR appear to be the most prevalent, with nine Member 
States reporting that more than 60% of their measures will have this geographical coverage. This is 
shown in Figure 6-6 below. 

Figure 6-6. Geographical location of implementation of the measures 

Source: Member State reporting to EIONET 

Although  less  common,  five  Member  States  report  that  at  least  50  %  of  their  measures  are 
implemented at national level. The reported data also indicates a trend in the geographical coverage 
of structural and non-structural measures. The former are typically more localised, conversely, non-
structural measures appear to have a wider geographical coverage.  

As required by the law, 19 Member States reported the priority of their measures (the options were 
critical,  very  high priority,  high, moderate  and  low  priority).  Overall, the  results  indicate  that most 
measures were classified in the three highest priority categories (high, very high and critical), with 13 
out of 19 Member States reporting 50% or more of their measures in one of these categories. Far 
fewer Member States reported that their measures fell into the moderate priority category, with the 
share of measures falling below 30% in most cases. 

Looking  at  the  priority  of  measures  across  all  aspects  of  flood  risk  management  (prevention, 
protection, preparedness, or recovery and review), it seems preparedness measures tend to have a 
higher priority (67% of all preparedness measures have critical or very high priority), especially when 
compared to protection measures (50 % of protection measures have critical or very high priority). 

98 

 
In the transition from the first to the second FRMPs, there has been, with few exceptions, a slight 
downward shift in the urgency of actions across Member States, from critical to very high priority and 
from very high to high priority. 

When it comes to methods for this prioritization, in the majority of Member States assessed (18 out 
of 21), the FRMPs or other relevant documents provided information on the methods used to prioritise 
measures. In most cases (13 of 18 Member States), some variant of multi-criteria assessment (MCA) 
was used. These multi-criteria assessments included factors such as cost-effectiveness, risk reduction 
potential  and  compliance  with  the  Water  Framework  Directive  (e.g.  Lithuania  and  Germany).  The 
comparison between Member States’ first and second FRMPs does not indicate any significant trends 
in terms of the methods of prioritisation that were used. Most Member States assessed, i.e. 15 out of 
the  21  that  reported,  have  made  some  analysis  of  costs  and  benefits  of  their  measures.  Little 
progress on the use of Cost Benefit Analysis (CBA) and similar methods is noted between the two 
first and second FRMPs. The ratio of Member States using these methods is more or less the same, 
that is 71% compared to 75% in the previous cycle. In six Member States, CBA or similar methods 
are used for prioritisation of measures or for the assessment of scenarios of measures153, while in 
the  remaining  nine  Member  States  which  use  these  methods,  it  is  used  for  the  assessment  of 
individual  measures/actions.  In  all  the  Member  States  which  use  CBA  for  prioritisation  of  their 
measures, and which provide a detailed description of the methodology154, the benefits are defined 
in terms of avoided damages, but the scope of the damages included in calculations varies. In all 
these Member States, a similar approach was already used in the first FRMPs, but the methodology 
has been revised and improved.  

Progress in implementation of the measures 

All 21 Member States assessed indicated the progress of implementation of their measures. As shown 
in Figure 6-7, the reported levels of progress in implementation of the measure show considerable 
variation across Member States, with no clear overarching trend.  It should be noted  however that 
Member States appear to have followed different approaches in terms of reporting the measures in 
the first and second FRMPs, and this influences their conclusions on the progress of measures. 

153 These are: Czechia, Poland, Estonia, Romania, Hungary, and Germany. 
154 Hungary, Poland and Romania. 

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Figure 6-7. Progress of implementation of measures 

Source: MS reporting to EIONET 

Monitoring of progress in implementation of the FRMPs 

For the first FRMPs, while many Member States provided some information on monitoring processes, 
the descriptions were often not detailed, with some using the results of the Preliminary Flood Risk 
Assessment  (PFRA)  and  Flood  Hazard  and  Risk  Maps  (FHRMs)  as  baselines.  This  time  around,  the 
majority  of  Member  States  provided  information  on  approaches  for  monitoring  the  progress  in 
implementing measures. However, the level of detail varied across Member States.  

A common approach taken by nearly  half of Member States assessed  – Czechia, Croatia, Estonia, 
France, Ireland, Luxembourg, Latvia, Poland, Romania, Slovenia, and Sweden – was the identification 
of indicators to track the progress of measure implementation. These indicators were often linked to 
objectives or measures outlined in the FRMPs. 

Additionally, more Member States have now outlined institutional arrangements and responsibilities 
for  monitoring  progress.  Common  approaches  included  designated  authorities  or  inter-agency 
coordination groups responsible for collecting data, compiling reports, and overseeing the monitoring 
process. A few Member States indicated timeframes for progress monitoring reports, ranging from 
annual to biennial reporting. Overall, while there was progress in monitoring the implementation of 
measures  between  the  first  and  second  FRMPs,  aspects  such  as  establishing  baselines  or  linking 
measures and objectives remain a challenge for several Member States. 

Funding of measures  

While only a small share of the Member States voluntarily reports the costs of their measures, two 
thirds have provided at least some information on the total costs of their measures in their FRMP. 
The extent of the information provided varies, however. 

The information on costs by type of measure, as reported to EIONET, is very limited, and it is therefore 
not possible to identify broad trends, except that it is mostly structural measures whose costs are 
quantified. From the Member States that provided this information by measures aspect, prevention 
and preparedness measures generally account for a smaller proportion of total costs. 

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All 21 Member States that reported have provided information in their FRMPs on the source of funding 
for their measures (see figure 6-8). However, the level of detail varies considerably, with the FRMPs 
of some Member States only making general references to possible sources of funding, while others 
are more concrete and specific. 

Figure 6-8. Funding sources for measures 

Sources: Based on information available from the assessment of FRMPs in 20 Member States. 

Notes: In this figure, ‘groups affected by flooding’ refers to: ‘Distribution of costs among those groups affected by flooding 
(including businesses and households)’. ‘International funds’ refers mainly to resources from international financial 
institutions, such as the European Investment Bank.  

As it can be seen, EU funding instruments, including through Cohesion Policy, played a significant role 
in supporting the implementation of FRMP measures across Member States.  

In addition to public and EU funding sources, ten Member States refer to the use of resources from 
the private sector and households. Also included in this category are Member States that specifically 
indicate insurance as a funding source. In addition, some Member States, the FRMPs identify specific 
taxes  and  charges  that  finance  FRM  measures.  Generally,  as  was  the  case  for  the  first  FRMPs, 
government funding emerged as the primary source of financing for measures across the Member 
States. EU funding instruments played a significant role in supporting the implementation of FRMP 
measures across Member States. In addition to public and EU funding sources, ten Member States 
refer to the use of resources from the private sector and households and eight Member States  – 
indicate in their FRMPs that property owners should contribute to finance actions to protect against 
flooding; these are often general statements. 

There was also a notable shift in the emphasis on EU level funding instruments. While the European 
Structural and Investment Funds (ESIF) were cited by 14 Member States in the first FRMPs, they are 
referenced by far fewer Member States in the second FRMPs. Furthermore, only a few Member States 
– Hungary, Romania, and Slovenia – explicitly mentioned the use of EU Cohesion Policy funds in the 
second  FRMPs.  Instead,  there  was  an  increased  focus  on  other  EU  funding  instruments  like  the 
sectoral funds (LIFE, Horizon Europe), and Interreg Programmes and also the arrival of the Recovery 
and Resilience Fund. Finally, the involvement of private investments and other funding sources, such 
as water charges and insurance, was recognised by a small number of Member States in both first 
and second Plans, holding relatively stable.  

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Linking objectives and measures 

The  table  below  assesses  Member  States  in  terms  of  the  specificity  of  their  objectives  and  their 
measures: Whether objectives or measures are general, specific or partially specific. It also indicates 
if there are clear links reported between the measures and objectives.  

Table 6-1. Objectives, measures and their links 

Member State 

Objectives 

Measures 

Links between  
objectives and measures 

Sweden 

Ireland 

Finland 

Poland 

Belgium 

Denmark 

Estonia 

France 

Latvia 

the Netherlands 

Spain 

Specific 

Specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Specific  

Specific  

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Link exists 

Partial link 

Link exists 

Link exists 

Link exists 

Link exists 

Link exists 

Link exists 

Link exists 

Link exists 

Link exists 

Romania 

Partly specific 

Partly specific 

Partial link (to general 
categories of measures) 

Croatia 

Czechia 

Lithuania 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

Partly specific 

No clear link 

No clear link 

No clear link 

Germany 

Partly specific 

General 

Link exists 

Austria 

Luxembourg 

Slovenia 

General 

General 

General 

Partly specific 

Partly specific 

Partly specific 

Link exists 

Link exists 

Link exists 

Italy 

General 

Partly specific 

Partial link (some FRMPs) 

Hungary 

General 

Partly specific  

No clear link 

Sources: FRMPs  

For the great majority of Member States, 18 out  of the 21, the measures were considered partly 
specific. This was assessed in terms of the extent of information on  what each measure aimed to 
achieved – the expected effect – as well where and by when it would be achieved, and how, the latter 
referring to a brief description of the steps of actions involved.  

102 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
FRMPs and specific groups of measures in related policy areas 

As regards spatial planning, the FD states that FRMPs should take into account spatial planning and 
land use and include “the promotion of sustainable land use practices”. Evidence of spatial planning  
was  found  in  all  Member  States’  FRMPs  assessed155.  All  Member  States  except  Lithuania,  the 
Netherlands, and Slovenia reported measures related to protection and water flow regulation156. On 
the  other  hand,  only  12  Member  States  reported  measures  focused  on  prevention,  removal  and 
relocation of receptors157. Many of the spatial planning measures set out in the second FRMPs call for 
further integration of flood risk management into local spatial plans. References to legal or policy 
frameworks  that  link  spatial  planning  and  flood  risk  management  were  seen  in  eight  of  the  21 
Member States assessed. Several Member States, have legal restrictions on new development in flood 
risk areas. Some plans include measures to retrofit existing buildings that are vulnerable to flooding.  

As regards nature-based solutions and natural water retention measures advocated for under the 
FD, just as in the first FRMPs, all Member States included nature-based solutions (including natural 
water retention measures), at least to some extent. A few Member States have a high share of these 
measures:  they  account  for  41  %  in  Luxembourg,  31 %  of  the  measures  in Austria,  and  20  %  in 
Romania. The FRMPs include a range of measures, such as afforestation and stream renaturalisation 
measures, dune restoration to address coastal flooding, renaturalisation of polders in the estuary, 
creating wetlands that can absorb and attenuate storm surges Nearly all Member States reported 
that they had considered controlled flooding.  

In relation to links with nature conservation, a clear majority of the Member States had measures 
that considered nature conservation in their plans. 17 out of the 21 Member States158 indicated that 
nature conservation was addressed to some degree in the development and implementation of their 
FRMP measures. Regarding the specific considerations for nature conservation, the most common 
approach  cited  was  the  assessment  of  potential  impacts  of  flood  risk  management  measures  on 
protected  natural  areas,  particularly  Natura  2000  sites  designated  under  the  Habitats  and  Birds 
Directives.  A  few  Member  States  integrated  nature  conservation  more  directly  into  their  FRMP 
objectives  and  measures.  Overall,  it  is  noted  positively  that  Member  States'  integration  of  nature 
conservation  into  their  measures  showed  a  marked  improvement  between  the  first  and  second 
FRMPs,  with  more  Member  States  now  providing  information  on  specific  measures,  objectives  or 
impact assessments in this respect. However, despite the increased attention to nature conservation, 
the consideration of ecosystem services remained largely absent from the reported information in 
both FRMPs. 

When it comes to cultural heritage, as noted above, 16 out of the 21 Member States159 provide either 
strong or some evidence that their objectives address adverse consequences on cultural  heritage. 
Roughly  half  of  the  Member  States  –  11  out  of  the  21160  –  reported  that  measures  specifically 
addressing cultural heritage protection were included in their FRMPs. At the same time, some Member 

155 A total of 7  009 measures, 9 % of all measures reported to EIONET. 
156 M32: Protection, Water flow regulation, Measures involving physical interventions to regulate flows, such as the 
construction, modification or removal of water retaining structures (e.g., dams or other on-line storage areas or 
development of existing flow regulation rules), and which have a significant impact on the hydrological regime. 
157 M22: Prevention, Removal or relocation, Measure to remove receptors from flood prone areas, or to relocate receptors 
to areas of lower probability of flooding and/or of lower hazard. 
158 These Member States include Austria, Belgium, Czechia, Germany, Denmark, Estonia, Spain, Finland, France, Croatia, 
Ireland, Italy, Luxembourg, Latvia, Poland, Romania, and Sweden. 
159 The 16 Member States include Austria, Belgium, Czechia, Estonia, Spain, Finland, Croatia, Hungary, Ireland, Italy, 
Lithuania, Luxembourg, Latvia, Poland, Romania, and Sweden. 
160 The 11 Member States include Czechia, Estonia, Spain, Finland, Croatia, Italy, Lithuania, Luxembourg, Latvia, Poland, 
and Sweden. 

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States  that  refer  to  cultural  heritage  in  their  objectives  did  not  report  specific  measures  for  the 
protection of cultural heritage in their FRMPs. 

As regards navigation and port infrastructure, out of the 21 Member States assessed, 11 provided 
information on this aspect161, as required by the law, indicating that their FRMPs included measures 
that specifically address or at least consider ports and inland navigation. This is significantly more 
than in the first FRMPs. Among these Member States, some countries, such as Denmark and Finland, 
included specific measures for port areas in their FRMPs, while  several other Member States only 
made general references or mentioned the importance of navigation and ports without elaborating 
further on specific measures. Specifically, the use of dredging as a measure to increase the capacity 
of river channels and improve the ability to convey water for flood alleviation and/or inland navigation 
purposes was reported with varying levels of detail by 12 of the 21 Member States162 assessed, all 
of which indicated that their FRMPs included measures or considerations related to dredging activities. 
Compared to the reporting of the first FRMPs, there was no clear change in Member States' reporting 
on dredging activities. It should be recalled that dredging may alter the hydromorphological conditions 
of water bodies, potentially reducing their status under the WFD: for this reason, an assessment under 
Article 4(7) of the WFD may be necessary for such measures. 

Nearly all Member States reported on measures related to emergency planning and response to 
flooding situations in their second FRMPs, with the exception of Lithuania and Hungary163. Out of the 
21 Member States assessed, nearly all provided either specific measures or objectives related to the 
development of emergency planning, with the exception of Lithuania. A common approach taken by 
nine  of  these  Member  States  included  training  exercises,  and  capacity  building  for  emergency 
responders being included as measures. The role of early warning systems and flood forecasting in 
emergency planning was noted by six Member States. 

The  role  of  insurance  policies  and  other  economic  instruments  in  flood  risk  management  was 
addressed inconsistently and with varying degrees of detail by Member States in their second FRMPs. 
More  than  half  of  the  Member  States  assessed  provided  little  to  no  information  on  the  role  of 
insurance policies in flood recovery, preparedness, or resilience, while several Member States164 did 
not mention the role of insurance at all. Among those Member States that do provide information on 
the  issue,  Belgium,  France,  Germany,  and  Sweden  included  information  on  the  availability  and 
conditions of flood insurance for properties in flood-prone areas. Few Member States discussed the 
role  of  public  authorities  and  compensation  schemes  in  flood  recovery.  Moreover,  three  Member 
States note that insurance for flood damages should be covered by private insurance. Notably, no 
Member States explicitly addressed whether environmental liability insurance covers the restoration 
costs arising from flooding of potentially polluting sites and installations. 

As regards the consideration of climate change in the preparation of flood risk management plans, 
reference is made to section 3.1.7 on ‘Adaptation to climate change’. 

161 These 11 Member States include: Belgium, Germany, Denmark, Spain, Finland, France, Hungary, Ireland, Italy, Latvia, 
and Poland.  
162 These 12 Member States include Belgium, Czechia, Germany, Estonia, Spain, Finland, Hungary, Italy, Latvia, 
Netherlands, Poland, and Sweden. 
163 Hungary subsequently explained that Flood Localisation Plans (that are referred to in the second FRMP and are 
separate to the FRMP) are flood emergency response plans. Specifically, these plans define measures in case of a flood 
protection failure or an emergency event (e.g. a dike failure). The plans are used by the Defence Committees, the national 
Directorate General of Disaster Management and the General and Terrestrial Water Directorates. 
164 These Member States include Czechia, Croatia, Lithuania, Latvia, the Netherlands, and Poland. 

104