COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Germany 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: Germany, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

EN 

  EN 

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

Germany 

ENVIRONMENT 

 
 
 
 
 
 
 
 
Content 

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

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

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

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

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

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

3. Policy elements contributing to biodiversity and climate change adaptation ...................................... 13 

3.1 Surface Water: what is their ecological status or potential .................................................................... 13 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) .......................................... 15 

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 16 

3.4 Protected Areas (identification, monitoring, objectives and measures) ........................................... 18 

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 19 

3.6 What Germany is doing for abstractions and water scarcity ................................................................. 19 

3.7 Adaptation to climate change .................................................................................................................................. 22 

4. Policy elements contributing to zero pollution ........................................................................................................ 23 

4.1 Surface Water: what is their chemical status ................................................................................................. 23 

4.2 Groundwater Bodies: what is their chemical status .................................................................................... 26 

4.3 What Germany is doing to combat pollution from agriculture ............................................................. 28 

4.4 What Germany is doing to combat pollution from other sectors ........................................................ 29 

4.5  What  Germany  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 30 

5. Exemptions and economics ............................................................................................................................................... 31 

5.1 To what extent are exemptions applied in Germany .................................................................................. 31 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 33 

6. WFD recommendations ........................................................................................................................................................ 36 

SECTION B: FLOODS DIRECTIVE .................................................................................................................................................. 39 

7. Flood risk management under floods directive (FD) ............................................................................................ 40 

7.1 Flood hazard and risk maps ...................................................................................................................................... 40 

7.2 Flood risk management plans .................................................................................................................................. 41 

8. FD recommendations ............................................................................................................................................................ 43 

2 

 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, member state characterisation

Germany has a population of 84 million inhabitants1 (with a population density 236 persons per km2 
more than twice the EU average) and a surface area of 357,582 km2 and a marine area close to 
56,000km²  split  between  the  North  Sea  North  Sea  and  the  Baltic  and  is  bordered  by  nine  other 
countries. The northern part of the country consists of lowlands with the southern part of the country 
consisting of the Alps, in-between are forested upland regions. 

Germany  has  designated  ten  River  Basin  Districts.  Most  German  rivers  follow  the  general  north-
northwest ward inclination of the land, eventually entering the North Sea. This does not hold Danube, 
which flows eastward, to the Black Sea. Germany shares six RBDs with other countries and for several 
of them, it holds the estuary position. This entails that the quality and quantity of its waters also 
depends on decisions taken in other countries. 

Water availability has traditionally been high with 791 millimetres precipitation (30-year average)  

Figure 1. Map  of the  River  Basin Districts  of Germany  with low  risks for  droughts but high flood risks 

However, some regions in central and eastern Germany already had water shortages in the past and 
recently dry seasons have become more frequent and longer lasting. Agriculture occupies 47% of 
the land and the country is the world’s 4th largest exporter of agricultural products. The country also 
hosts the third largest harbour in Europe in Hamburg. 

1 Statistics | Eurostat (europa.eu) 

4 

 
 
Reporting  

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

By September 2023 Germany have not submitted full electronic reporting, but data for majority of 
RBDs were available. Therefore, the assessment is based on the dataset available at that time and 
the missing RBDs are based on the data mining of the pdf RBMPs. 

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

5 

 
 
 
Table 1. Changes in Status, Pressures, Exemptions & Measures 

Surface 
Water 
Bodies 
(9744) 

Trend (% good 
status/potential) 

100%

50%

ECOLOGICAL 
STATUS 

8,1% 9,3%

0%

2015 2021

Main Pressures & Changes & Exemptions 

Germany achieved good ecological status/potential in only 9.3% of SWBs, which is a slight improvement compared to the 2nd RBMPs. DE 
expects around 10% to be in good status by 2027 but does not explicitly explain this high proportion of status failure. In general, diffuse 
nutrient pollution from agriculture and physical alterations to the SWBs for agriculture and flood protection are identified as significant 
pressures in all RBDs. The largest gap in status is quantified for agricultural pollution for all surface waters including coastal waters. 
Although water abstraction is not identified as a significant pressure in all RBDs, several studies point to emerging water scarcity issues 
e.g. in )Eastern Germany. It remains partly unclear which measures are taken to prevent nutrient pollution and how these relate to legal 
requirements e.g., from the EU Nitrates Directive. 
Clear improvements in relation to monitoring were made, with all biological quality elements now being monitored and reported compared 
to 2015. Germany has made clear improvements in implementing e-flows. This is important for safeguarding the ecologic status of 
surface water bodies and the quantitative status of groundwater bodies especially in the light of an expected aggravation of water 
scarcity and drought issues due to climate change. 

Exemptions were applied under Article 4(4) for technical feasibility to 24%, for disproportionate cost to 24.2%, and for natural conditions 
to 51.2% of SWBs for ecological status. Article 4(5) exemptions were applied to 0.2% of SWBs each for technical feasibility and 
disproportionate cost. Article 4(7) exemptions have been applied to 0.2% of SWBs for new modifications. 

6 

 
 
CHEMICAL 
STATUS 

100% of SWBs are in poor chemical status/potential, mainly due the ubiquitous Persistent, Bio-accumulative and Toxic substances (uPBTs) 
mercury and PBDEs. These substances are mainly emitted during combustion of fossil fuels and industrial use, and enter surface waters 
through atmospheric deposition, which is the main pressure on SWBs in DE. Under exclusion of uPBTs, chemical status improves, ranging 
from 59% in good status in the Rhine RBD to 95% in good status in the Ems RBD. Substances that are of further importance depend on 
the region. Among them are e.g. pesticides, PFOS from industrial emissions, and fluoranthene from fossil combustion. In the NRW Rhine 
catchment for example PFOS form industrial use put pressure on SWBs. DE expects 0% of SWBs to achieve good chemical status/potential 
by 2027. 

DE monitors all SWBs for chemical status/potential and classifies with high confidence, with remaining gaps in trend analysis and 
insufficient detail in reporting.  

Exemptions are applied under Article 4(4) for technical feasibility to 0.4%, for disproportionate cost to 0.7%, and for natural conditions to 
63.1% of SWBs for chemical status. Article 4(5) exemptions were applied to 0.1% of SWBs each for technical feasibility and 
disproportionate cost. 

7 

 
 
 
 
 
 
Ground 
Water 
Bodies 
(1291) 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

QUANTITATIVE 
STATUS 

Since the 2nd RBMPs, DE's number of GWBs has increased by 10% due to aggregation and splitting. This affects the observed trend in 
quantitative status, which shows a slight deterioration with 11 additional GWBs failing to achieve good status since 2015. 
Germany achieved good quantitative status in 95.2% of GWBs, which is a slight decrease compared to the 2nd RBMPs. DE expects 98% of 
GWBs to achieve good quantitative status by 2027. 

Most of the GWBs fail good status because their levels are lowering due to over abstraction, followed by damages to dependent terrestrial 
ecosystems and associated surface waters. Overall, cooling water in electricity generation is the most common use of water (although 
mostly surface waters are used for this purpose) before households and industry with 25% and 19% respectively. Total water abstraction 
has decreased by 15% since 2016, through a less water-intensive energy sector. Agriculture only constitutes 1.7% of the total 
abstractions in DE with an increasing trend. Recent studies show that DE is experiencing climate change induced water loss from soils and 
vegetation and record-low levels of GWBs throughout different regions. 
Exemptions are applied under Article 4(4) for technical feasibility to 0.7% and for natural conditions to 0.9% of GWBs for quantitative 
status. Article 4(5) exemptions have been applied to 1.5% of GWBs for technical feasibility, and 0.1% for disproportionate cost. Article 4(6) 
exemptions have been applied to 0.4% of GWBs on the grounds of natural conditions. Article 4(7) exemptions have been applied to 1.1% 
of GWBs for new sustainable human development. 

8 

 
 
 
CHEMICAL 
STATUS 

The chemical status of GWBs in DE has improved slightly. Germany achieved good chemical status in 67.3% of GWBs, which is a slight 
increase compared to the 2nd RBMPs. 

GWBs mainly fail because of their water quality, followed by deterioration of drinking water quality, as well as damage to associated 
surface waters. 

pH, electrical conductivity, and dissolved oxygen seem not to be monitored in all RBDs. 

For groundwater, ‘diffuse – agricultural’ is the pressure reported to affect the highest percentage of water bodies. The 242 GWBs that are 
reported in poor chemical status, fail to achieve good chemical status, mainly due to the general water quality assessment. 

GWBs at risk of failing good status by 2027 are incomplete due to the delayed electronic reporting in Rhine and Weser (which contain 
almost half of all GWBs). Based on the incomplete data from the 3rd RBMPs e-reporting, at least 23.2% of the GWBs are at risk of failing 
to achieve good chemical status by 2027. 17% of the GWBs are expected to fail to achieve good chemical status by 2027. Nitrate is the 
pollutant responsible for the greatest risk. Examples of other relevant groundwater pollutants are pesticides, pharmaceuticals, and 
industrial pollutants like PFAS. 

Exemptions are applied under Article 4(4) for technical feasibility to 4.6%, for disproportionate cost to 0.2%, and for natural conditions to 
16.8% of GWBs for chemical status. Article 4(5) exemptions have been applied to 1.3% for technical feasibility, and 0.3% for 
disproportionate cost. 

9 

 
 
 
 
 
 
2. Horizontal aspects 

2.1 Governance 

Germany has streamlined its governance with the river basin approach by reducing the number of 
competent authorities to one for each of the ten (instead of 16 before) river basin district (RBDs) 
thereby  improving  coordination  arrangements  between  the  German  federal  states  (‘Länder’).  This 
may be one reason why all ten RBDs have been finalised and published on time. In this process, the 
LAWA (the German Working Group on water issues of the Federal States and the Federal Government 
represented by the Environment Ministers Conference (UMK)) continues to play an essential role in 
ensuring  coherent  and  coordinated  approaches  for  the  implementation  of  the  Water  Framework 
Directive  (WFD) in  Germany  and  is  encouraged  to  facilitate  further internal  harmonisation.  It  has 
issued several guidance documents or set minimum standards for all Länder and RBDs which has 
led  to  a  further  convergence  of  implementation  approaches  across  the  RBDs.  Still  there  are 
shortcomings in terms of a streamlined, let alone, harmonised application of the Directive across 
RBDs and Länder. 

International coordination in the six international RBDs is still strong. Moreover, Germany has invested 
significantly in the work of the international river conventions. However, there is limited evidence that 
more harmonised approaches have been developed (see recommendation 2019) which still leads to 
different approaches taken for the different major river basins, and differences in progress as well 
with  the  international  Oder  RBD  having  made  the  least  progress.  The  analysis  underscores  the 
persistent  challenges  in  meeting  water  quality  objectives  by  2027,  particularly  in  basins  with 
international cooperation, due to persistent issues with nutrient pollution, fluctuating concentrations, 
and limitations in achieving the targets. To achieve the objectives of the WFD more effectively and 
enhance water resilience, Member States including Germany should further enhance transboundary 
cooperation, in particular as regards e.g.: 

a)  Delineation  and  characterisation  of  water  bodies,  as  well  as  joint  or  coordinated  monitoring 
programmes and status assessment methodologies (e.g. commonly agreed reference conditions 
for biological quality elements and EQSs for pollutants); 

b)  Quantitative  aspects  of  water  management  through  relevant  international  cooperation 

mechanisms and bodies. 

Significant  public  participation  efforts  are  still  taking  place  in  all  RBDs  in  line  with  the  minimum 
requirements.  In  addition, most  RBDs  undertook  additional  public  information and  communication 
activities  as  well  as  a  broad  range  of  stakeholder  engagement  activities  to  involve  them  in  the 
preparation of all RBMPs. The coordination between the preparation of the River Basim Management 
Plans  (RBMPs)  and  the  Flood  Risk  Management  Plans  (FRMPs)  continues  to  be  strong  with 
consultations  done  in  parallel,  joint  implementation  taking  place  and  synergies  at  the  level  of 
measures  identified.  This  is  not  always  the  case  for  the  coordination  with  the  Marine  Strategy 
Framework Directive (MSFD). Some RBMPs include the MSFD objectives but except for the Weser RBD, 
the references are superficial. A more joined up approach happens on the identification of measures 
but there is no evidence that competent authorities are coordinating effectively, e.g. through  joint 
consultation processes or coordinated reporting when it comes to land-based pollution sources for 
the marine. Similar deficiencies in joint implementation seems to exist with other related pieces of 
legislation of relevance, as it appears from the information provided on protected areas. 

10 

 
In terms of obstacles in the implementation of measures planned under the 2nd RBMPs, Germany 
identified including lack of finance, of mechanism, acceptance, and staff resources. Moreover, further 
digitalisation  in  administrations  and  more  effective  and  open  data  management,  e.g.  by  better 
connecting information systems between the different authorities involved in the implementation of 
the WFD, also outside the environment domain, is another avenue to explore to improve governance. 

2.2 Characterization of River Basin District 

Germany designated a total of 9744 surface waterbodies and 1291 groundwater bodies in its 3rd 
RBMPs. There has been an increase of 9.6% in the total number of delineated groundwater bodies, 
because of splitting, aggregation and/or creation of new GWBs, compared to the previous cycle. As 
regards  surface  water  bodies, the  numbers  have  only  changed  slightly  compared  to  the previous 
cycle. For rivers the number were largely the same (-1%), 738 lakes (+1%), 5 transitional waters (no 
change),  71  coastal  waters  (-5%)  and  7  territorial  waters  (not  reported  in  2015).  Although  this 
appears to be a rather stable situation, there have been significant changes in the delineation of river 
water bodies (16%) and lake water bodies (14%), pointing to a refinement of the characterisation. 
Around 66 surface water bodies (125 in the 2nd RBMPs) and 428 groundwater bodies (2833 in the 
2nd RBMPs) are designated as protected areas for drinking water and therefore subject to additional 
protection. 

Table 2. Overview of Germany‘s River Basin Districts (RBDs)  

RBD 

Name 

Size (km2) 

% share of total 
basin in DE 

Countries sharing RBD 

DE1000 

Danube 

56265 

DE2000 

DE3000 

Rhine 

Ems 

DE4000 

Weser 

DE5000 

DE6000 

Elbe 

Oder 

105925 

17391 

49061 

99539   

9686 

DE7000 

Maas /Meuse 

3976 

DE9500 

Eider 

DE9610 

Schlei/Trave 

9344 

9222 

DE9650 

Warnow/Peene 

21094 

Source: 3rd RBMPs electronic reporting 

7.0 

54 

84 

100 

65.5 

7.7 

11.6 

- 

99.9 

100 

AT, BA, BG, CH, CZ, HR, HU, IT, MD, 
ME, MK, PL, RO, RS, SI, SK, UA, AL 

AT, BE, CH, FR, IT, LI, LU, NL 

NL 

- 

AT, CZ, PL 

CZ, PL 

BE, FR, LU, NL 

DK 

DK 

Overall,  Germany  has  refined  the  well-established  characterisation  process  and  improved  the 
establishment of reference conditions. It is noted positively that for all water bodies (except 1% of 
the river water bodies) there are at least some reference conditions with most improvements made 
for the coastal waters. Overall, approaches have improved but are still not fully harmonised or, at 

11 

 
 
least, comparable, across RBDs. Consequently, some work remains to fully implement the previous 
shortcomings (see recommendation 2019). 

Germany have assigned numerous Key Type Measures (KTMs) for many pressures. The most relevant 
significant pressures affecting the highest percentage of surface water bodies in Germany are 
chemical  pollution  (including  pollution  from  atmospheric  deposition)  affecting  99%  of  surface 
water bodies, nutrient pollution from agriculture affecting at least 71% of surface water bodies, 
and  physical  alteration  of  habitats  channel/bed/riparian  area/shore  affecting  at  least  83%  of 
surface  water  bodies2.  It  is  noted  that  the  numbers  from  the  report  of  the  German  Environment 
Agency (UBA) are slightly different. Those report that 77% of the surface waters and 29% of the 
groundwaters in Germany are affected by agricultural pressures resulting in too high emissions of 
nutrient-  and  pesticides3.  These  impacts  are  the  same  as  in  the  previous  cycle,  indicating  that 
Germany needs to significantly step up its efforts to reduce those pressures and impacts. 

Figure 1. Trophic status of surface water as reported under the Nitrates Directive 

Source: Joint Research Center (n.d.). JRC NITRATES DIRECTIVE - Reporting Period 7 (2016-2019) Trophic Status. [online] 

water.jrc.ec.europa.eu. Available at:  

https://water.jrc.ec.europa.eu/portal/apps/dashboards/cb6034c2a75e4df282f8a62f90c16caa  

For groundwater, the pressures with the most significant impacts on groundwater bodies are 
chemical pollution (40%) and nutrient pollution from agriculture (10%). The electronic reporting 
was severely delayed, this may point to existing challenges in implementing existing legal obligations 
on  data  management  and  reporting.  Consequently,  Germany  is  advised  to  further  improve  data 

2. Workbook: WFD_SWB_Impacts (europa.eu) 
3 UBA Report – Water Framework Directive – Waters in Germany 2021 – Progress and Challenges 
https://www.umweltbundesamt.de/publikationen/die-wasserrahmenrichtlinie-gewaesser-in-deutschland 

12 

 
 
 
 
quality  and  data  comparability  by  harmonising  methods  and  electronically  collected  data  across 
RBDs, on monitoring, assessments, projections, economic assessment, etc. and make all data openly 
available  through timely publication in line with the requirements of the INSPIRE, Open Data and 
Public  Sector  Information  Directive  (PSI)  Directives  and  the  public  sector  High  Value  Datasets 
(Commission  Implementing  Regulation  (EU)  2023/138)  to  help  eliminate  the  need  for  reporting. 
Germany  is  also,  advised  to  better  connect  data  and  information  systems  of  all  administrations 
involved in the implementation (also others than the water competent authorities) and make better 
use of the opportunities from digitalisation and earth observation systems. 

Around 30 invasive alien species of EU concern4 create pressures for freshwaters in Germany. From 
those the following invasive aquatic plants are specifically mentioned: Canadian waterweed (Elodea 
nuttallii),  curly  waterweed  (Lagarosiphon  major),  parrot  feather  watermilfoil  (Myriophyllum 
aquaticum), water primrose (Ludwigia grandiflora) and water hyacinth (Pontederia crassipes)5 6. Also, 
water fern (Azolla filiculoides) and New Zealand pigmyweed (Crassula helmsii) create local problems. 
Particularly  vulnerable  are  eutrophic  ecosystems  and  modified  water  bodies  already  affected  by 
human  activities.  Invasive water  plants,  reduce  aquatic  biodiversity  and  ecosystem  functions.  The 
combination  of  reduced  penetration  of  light  combined  and  anaerobic  conditions  from  detritus 
decomposition can result in fish kills. Furthermore, the plants clog canals and irrigation ducts. Invasive 
alien animal species creating pressures are gobies (Neogobius melanostomus, Neogobius fluviatilis, 
Ponticola kessleri, Proterorhinus marmoratus and Babka gymnotrachelus), calico crayfish (Orconectes 
limosus) and the bullfrog (Lithobates catesbeianus). Invasive species have spread to varying degrees 
among water bodies in Germany7, but gobies have spread to the Baltic Sea, the North Sea basin, the 
Danube, and Rhine basins, including tributary rivers (Main, Neckar, and Moselle). Although, all invasive 
species are on the rise, their impact on species composition in water bodies and the achievement of 
good ecological  status can net be  reliably estimated for all  RBMPs. The  international  Rhine RBMP 
does describe measures against the further spread of certain invasive alien species. 

Also  as  regards  the  preparation  of  inventories  of  emissions,  discharges  and  losses  of  chemical 
substances, Germany has made progress, and they are now developed for all RBMPs. The electronic 
reporting of emissions inventories of chemicals is available for eight out of ten RBDs (exceptions are 
Rhine  and  Weser).  This  largely  overcomes  some  of  the  previous  shortcomings  (recommendation 
2019)  but  Germany  still  needs  to  address  some  gaps  and  differences  in  methodologies.  The 
substances for which the most inventories have been established are mercury and its compounds, 
nickel, and its compounds, perfluorooctane sulfonic acid (PFOS) and its derivatives, terbutryn, total 
Polycyclic Aromatic Hydrocarbons (PAHs), brominated diphenylethers, isoproturon, and lead and its 
compounds. 

4 EASIN - European Alien Species Information Network (europa.eu)  
5 German federal research centre for cultivated plants (Julius Kühn Institute) https://www.julius-
kuehn.de/media/Veroeffentlichungen/Flyer/Wasserpflanzen.pdf 
6 Hessisches Landesamt für Naturschutz, Umwelt & Geologie Invasive_Wasserpflanzen_gesamt_web.pdf (hlnug.de) 
7 https://www.bfn.de/gebietsfremde-und-invasive-arten#anchor-8237 

13 

 
 
3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

Overall, Germany has made progress in the monitoring, assessment, and classification of ecological 
status/potential in surface water bodies and the identification of river basin specific pollutants. All 
water  bodies  were  classified.  Progress  has  also  been  made  in  other  areas,  such  as  the  further 
inclusion of river basin specific pollutants. 

As regards monitoring, the number of monitoring points has increased compared to the 2nd RBMPs 
and  most  stations  monitor  biological  quality  elements,  physico-chemical  quality  elements  and 
several hundred of river basin specific pollutants (RBSPs). Although data were incomplete at the time 
of assessment, the number of operational and surveillance monitoring stations amounted to at least 
15542. 

The surveillance monitoring covers all biological  quality elements and Germany monitors most of 
them. For rivers, lakes, and transitional water bodies, these are: phytoplankton, macrophytes, benthic 
invertebrates,  and  fish  (not  phytobenthos8).  Whereas  for  coastal  water  bodies  phytoplankton  and 
benthic invertebrates. However, in two out of four coastal waters other aquatic flora is also monitored. 
All general physico-chemical quality elements are now monitored in most water body types, except 
for coastal water bodies where only nutrient and oxygenation conditions are monitored. According to 
the  available  information,  hydromorphological  quality  elements  are  not  monitored  under  any 
monitoring  programme.  Nevertheless,  in  the  ‘ex  ante  analysis’,  the  current  hydromorphological 
conditions and the expected conditions are considered in the models to assess biological status (for 
quality elements sensitive to hydromorphological changes). 

Figure 2. Chemical status or potential of surface water bodies, as reported in 2010, 2015 & 2021 

Source: e-reporting from WISE. 

8 Justification accepted in the context of the intercalibration exercise 

14 

 
 
 
As  regards  assessment  and  classification,  based  on the  electronically  reported  data,  the  share  of 
rivers in good or high ecological status/potential has slightly increased from 8% in the 2nd to 9.3% in 
the 3rd RBMPs. 

By 2027, the share of water bodies reported in good or better ecological status/potential is expected 
to be 7%. This is at odds with the analysis of the German Environment Agency (UBA) which projected 
an achievement of 18% of, at least, good ecological status/potential by 2027. The UBA also estimated 
it will take until 2045 to achieve 82% of compliance of surface water bodies in relation to ecological 
status. 

Still, this small but steady progress in improving ecological status is at very low levels and insufficient 
to achieve the objectives of the Directive. Rivers in good status are mainly found upstream often in 
the  south  whereas  the  rivers  in  highly  industrialised  regions  or  transitional  and  coastal  waters 
downstream have the worst ecological quality. The situation of lakes is more promising with 20% in 
good ecological status (which include the Lake Constance, the Müritz or the Chiemsee) and 36% in 
good  ecological  potential.  The  main  reason  for  this  low  level  of  compliance  are  high  levels  of 
pressures from pollution and altered ecosystems. 

Also,  of  around  37%  of  all  reported  water  bodies  are  significantly  affected  by  pressures  from 
hydropower  with  impacts  on  ecological  status  such  as  the  interruption  of  the  biological  and 
hydromorphological continuity of watercourses (preventing migratory fish of reaching their spawning 
grounds), direct damage to organisms by hydropower turbines (around 22 % of the fish of all ages 
passing through a turbine die and an even larger percentage is injured), and habitat changes affecting 
water  levels  downstream. The  sum  of  all  effects  of  chains  of  dams  with  successive  turbines  can 
jeopardise  entire  populations.  Fish  species  such  as  eel,  barbel,  salmon  and  ‘common  nase’  are 
particularly affected. 

No information on the establishment of nutrient limits was available suggesting that Germany is not 
using such limits for the purpose of the assessment, as recommended by the Commission previously. 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

In Germany, there is a very significant human intervention on the water system. Most surface water 
bodies are altered of pressures created by human activities (35% of the WBs are heavily modified 
and 17% are artificial). This entails that for around 52% of all WBs lower environmental objectives 
would be applicable and they will aspire to ‘good ecological potential’. For the designation of heavily 
modified water bodies (HMWBs), the shares between rivers, lakes, transitional and coastal  waters 
have  remained  largely  the  same  as  in  the  2nd  RBMP.  However,  more  changes  are  observed  for 
artificial water bodies (AWBs) where more than 600 AWBs have been designated mainly because of 
‘new uses’. Based on reported data, the reasons for this increase are not sufficiently justified. 

The  share  of  electricity  from  hydropower  is  3.1%  of  total  electricity  production.  The  country  has 
however around 7000 hydropower plants, many are very small, and most electricity comes from less 
than 500 plants of which a large proportion is in southern Germany. Hydropower accounts for 14% 
of the electricity production in Bavaria9 and 9% in Baden-Württemberg10. The ecological status of 

9 https://www.stmwi.bayern.de/energie/erneuerbare-energien/wasserkraft/ 
10 https://www.statistik-bw.de/Presse/Pressemitteilungen/2021331 

15 

 
 
around 37% of all reported water bodies –i.e. over 51 000 km of rivers – are significantly affected 
by pressures from hydropower. 

Overall,  the  designation  of  HMWBs  is  largely  the  result  of  land  drainage  for  agriculture  (66%), 
urbanisation (28%) and flood protection (19 %). Germany seems to have very extensively designated 
water  bodies  because  of  drainage  for  agriculture  compared  to  other  countries11.  In  some  cases, 
several  reasons  apply  simultaneously.  For  larger  rivers  (e.g.  the  Rhine)  and  transitional  waters, 
navigation is the main reason for designation. Areas in the North of Germany (mainly the lowlands) 
where agricultural activities are intense have a particularly high percentage of HMWBs this may be 
due to drainage of agricultural land. In the South of Germany (mainly in the Alpine regions), HMBWs 
are  often  associated  with  hydropower  use.  In  many  rivers,  a  combination  of  reasons  for  their 
designation applies. Artificial water bodies are mostly the result of agriculture needs (e.g. drainage 
channels  and  ditches  as well  as  reservoirs)  or inland  navigation  (canals).  Moreover,  in the mining 
regions some open cast mining lakes exist. 

The methodologies for the designation and definition of good ecological potential have not changed 
since the 2nd RBMPs. Information on the outcome of the assessment of significant adverse effects 
of restoration measures and better environmental options at water body level has not been found. 

Overall, regrettably, the German HMWBs and AWBs are doing worse than the natural water bodies 
and experience more difficulties to achieve their corresponding environmental objectives even if those 
are of a lower level of ambition. Indeed, only 5% of HMWB and AWB achieve good or high ecological 
potential in comparison to 14% for natural water bodies12. It is noted with concern that there has 
been largely a negative trend since the 2nd RBMP. Whereas ecological status classes improved by 
2.8% in natural waters, they got worse in 0.3% of HMWBs and AWBs, in lakes (-12.8%) with the most 
negative  trend  for  the  parameter  phytoplankton13  (which  is  a  possible  indicator  for  increased 
eutrophication  in  heavily  modified  and  artificial  lakes  but  might  partly  also  be  explained  using  a 
revised  and  stricter  assessment  method).  Addressing  this  legacy  of  altered  water  ecosystems  by 
human activities is one of the biggest challenges for Germany to reach the objectives of the WFD. 
Consequently, Germany is advised to develop and implement methodologies for definition of Good 
Ecological Potential and to rapidly improve the status of HMWB and AWBs. 

Hydromorphological pressures may result from the gradual closure of open pit coal mines. The re-
filling of pits with rainwater and groundwater may accelerate groundwater recovery in these regions 
and bring environmental benefits14. At the same time, coal mines also contain pollutants that will be 
released when pits are re-filled, thereby potentially deteriorating the chemical status of ground and 
surface water bodies. Also, new hydromorphological pressures may emerge where groundwater from 
coal pits has been feeding rivers. For instance, the Spree River (an essential source of water supply 
for Berlin and the Brandenburg region) in summer months carries up to 40% of the river’s discharge 
from dewatering of lignite mining areas. Due to mine closures, and the end of groundwater pumping, 
the mines could turn from a water source for the Spree into a water sink. Due to lower flows, the 

11  By  preparing  of  this  report,  Germany  has  designated  2  213  water  bodies  as  heavily  modified  due  to  drainage  for 
agriculture, while for all other electronically reported Member States it is in total 694 water bodies. 
12  Workbook: WFD_SWB_SurfaceWaterBody (europa.eu) 
13 Report: Die Wasserrahmenrichtlinie - Gewässer in Deutschland 2021 | Umweltbundesamt 
14 Bozan, C., Wallis, I., Cook, P.G. et al. Groundwater-level recovery following closure of open-pit mines. Hydrogeol J 30, 
1819–1832 (2022). https://doi.org/10.1007/s10040-022-02508-2 

16 

 
 
concentration of pollutants (sulphate, iron, heavy metals, nutrients etc) in this river could increase 
and ecological flows could be at stake.15  

3.3 Groundwater bodies - have they sufficient water – quantitative status 

Germany has delineated 1291 groundwater bodies in the 3rd RBMPs which is an increase of 9.6 %. 
Yet the total GWB area has remained almost the same. Hence this is the result of aggregation and/or 
splitting,  or  creation  of  new  GWBs.  So,  this  can  entail  some  constraint  of  comparability  between 
cycles. The assessment of the groundwater quantitative status is done according to the harmonised 
recommendations for action on "Consideration of groundwater-dependent terrestrial ecosystems in 
the  risk  analysis  and  status  assessment  of  groundwater  bodies16.  This  includes  the  impacts  on 
Groundwater  Associated  Aquatic  Ecosystems  (GWAAEs)  and  Groundwater  Associated  Terrestrial 
Ecosystems (GWDTEs) which primarily include habitat types along watercourses, both alluvial forests 
and/or,  wet  meadows  and  the  watercourses  themselves.  All  RBMPs  confirm  that  the  needs  of 
groundwater dependent ecosystems (both terrestrial and aquatic) have been assessed (as required 
by WFD Annex II), and often the corresponding number of areas is indicated, but the outcomes of the 
assessments themselves are less consistently described. Overall, groundwater levels are increasingly 
affected by climate change. The dry years between 2015 and 2022 (2018, 2019 and 2020 and 2022 
were amongst the hottest ever recorded with precipitation shortages of 25%, 7%, 10% and 15% 
compared to the long-term averages)17. This resulted in lower groundwater levels particularly in areas 
in Eastern Germany prone to the negative effects of prolonged droughts. However, despite the low 
soil  moisture  levels  recorded  during  those  years,  this  did  not  affect  the  achievement  of  good 
quantitative status yet, according to data reported by Germany. Locally, the situation is different as 
deeper groundwater layers, particularly in Eastern parts of Germany, are likely still affected by the 
past  series  of  dry  years.  The  risks  of  increasing  water  scarcity  are  illustrated  by  a  recent  study 
analysing groundwater level monitoring data from around 6700 monitoring stations in Germany. The 
results show that at almost half of all the locations evaluated, groundwater levels have fallen in the 
drought years between 2018 and 2021 to the lowest level  since 199018. These trends should be 
considered when applying, as it is currently done, quite some intensive drainage of agricultural land. 
Increasing the water retention capacity of the land should be considered. 

The quantitative status of GWBs is slowly decreasing. According to the electronic data reported by 
Germany in WISE, around 95% of the groundwater bodies is in good quantitative status, slightly less 
than in the 2nd reporting cycle. 

15 The Spree River on a drip | IGB (igb-berlin.de) 
16 Handlungsempfehlungen der LAWA zur „Berücksichtigung grundwasserabhängiger Landökosysteme bei der 
Risikoanalyse und Zustandsbewertung der Grundwasserkörper“: 
https://www.lawa.de/documents/arbeitshilfe_umsetzung_wrrl_kap_grundwasser_1575970330.pdf 
17 https://www.umweltbundesamt.de/themen/wasser/extremereignisseklimawandel/trockenheit-in-deutschland-fragen-
antworten#trockenheit-aktuelle-situation 
18 https://correctiv.org/aktuelles/kampf-um-wasser/2022/10/25/klimawandel-grundwasser-in-deutschland-sinkt/ 

17 

 
 
Figure 3. Quantitative status or potential of groundwater bodies, as reported in 2010, 2015 & 2021. 

Source: e-reporting from WISE  

The  affected  groundwater  bodies  are  situated  in  the  Danube,  Elbe,  Meuse,  Oder,  Rhine  and 
Warnow/Peene RBDs. There are multiple reasons for failure, and they vary per region. In the Elbe, 
Meuse, Oder and Rhine RBDs, the poor quantitative status is largely a result of the past or current 
open pit mining activities, but also agricultural irrigation and the production of drinking water are 
important causes. Against a context of increasing droughts, the number of affected water bodies may 
increase  in  the  future  especially  because  the  status  assessments  must  include  the  needs  of  the 
groundwater dependent ecosystems (both terrestrial and aquatic) as required by WFD Annex II. 

According  to the German  Federal  Statistical  Office most  of the  water  extracted  was  groundwater 
(61%). The proportion of groundwater has remained stable for 18 years: it was 65% in 1998 and 
2004 and stood at 61% in 2013. Despite the gradual closure of these mining activities, it will take 
decades until a natural groundwater situation can be established again. Finally, it is unclear if climate 
scenarios have been included in the prediction of future achievements of good quantitative status 
for groundwaters in Germany. The UBA predicts a level of compliance of 98% by 2027 and of 100% 
by 2045 which may appear overly optimistic in the light of climate change. 

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

It is positive to note that on protected areas the RBMPs assessed show in detail that surface water 
bodies, that are in water dependant Natura 2000 areas, have been included in operational monitoring 
programmes.  It  is  welcome  that  since  the  2nd  RBMPs  the  number  of  monitoring  sites  for  several 
protected areas have increased significantly. This is particularly remarkable for Natura 2000 areas 
that  have  increased  by  7,644  monitoring  sites  resulting  in  a  total  of  8267  sites.  Also  6695 
groundwater monitoring sites for Drinking Water Protection are designated.  

18 

 
 
 
 
Table 3. Number of Water Bodies Associated with protected areas  

Protected area type 

Bathing waters 

Drinking water protection 
area 

Natura 2000  

Total 

441 

101 

7673 

8215 

Number of Water Bodies Associated with protected areas in 

Rivers 

Lakes 

Groundwater 

707 

27 

1049 

1783 

0 

6695 

8267 

14962 

Strikingly the number of protected areas for the abstraction of water for human consumption from 
rivers and groundwater bodies, as well as the number of bathing water sites decreased from the 2nd 
to  the  3rd  RBMPs.  As  regards  the  Nitrates  Vulnerable  Zones,  Germany  has  designated  the  whole 
territory. The same goes for  sensitive  areas under the Urban Wastewater Treatment Directive. No 
areas have been designated for the protection of economically important aquatic species including 
shellfish in the 3rd RBMPs, although some were identified in the 2nd RBMPs. 

Although  the  data  are  incomplete,  there  seems  to  be  a  low  level  of  inclusion  of  such  areas  in 
comparison to the numbers reported under the respective directives. For instance, Germany reported 
2291 bathing water sites for the season 2021 yet only several hundred are mentioned in the RBMPs. 

Additional objectives have been set for surface and groundwater bodies associated with Natura 2000 
areas  only  in  the  Ems  and  Meuse  River  basin  districts  but  not  in  the  others.  For  drinking  water 
protected areas, Germany has set out specific objectives in its water law and specific ordinances at 
Länder level. 

While it is welcome that the knowledge of the status of protected area is enhanced and that there 
are no unknowns, unfortunately this status does not appear to have changed significantly between 
the 2nd and 3rd RBMPs except for some slight deterioration in groundwater chemical and quantitative 
status. The data are not always clear and suggest that there is no strong integration between the 
efforts  to  implement  the  Water  Framework  Directive  and  the  implementation  of  related  EU 
environment  laws  designating  protected  areas  across  all  RBDs.  There  seems  to  be  significant 
potential for creating further synergies and effectiveness gains by better administrative cooperation, 
e.g. by sharing basic data for water management between different competent authorities such as 
those responsible for health (bathing and drinking water), nature (Natura 2000), agriculture (nitrates, 
pesticides) or fisheries (shellfish). 

3.5 What is being done to prevent/reduce hydromorphological pressures 

In the 3rd RBMP, Germany included the largest number of measures in relation to hydromorphological 
alterations. It noted positively that approximately 56% of surface water bodies will benefit from such 
measures until 2027. Moreover, Germany indicates that in 83% of all surface waters, measures are 
planned to reduce pollution from flow regulation and morphological changes. At the same time, the 
reports  also  recognise  that  regrettably  not  all  measures  planned  in  the  2nd  RBMP  have  been 

19 

 
implemented  (e.g.  in  the  Elbe  RBD,  only  about  half  of  the  measures  planned  in  2015  had  been 
implemented by 2021).  

As regards ecological  flows, their determination has been harmonised across the RBDs and some 
have  already  defined  and  implemented  them  (e.g.  in  the  RBD  Oder  or  Elbe)  (as  called  for  by  the 
Commission in the past) but work for others is still ongoing19. Issues that are not entirely clear from 
the  content  of  the  reports  are  a)  related  to  the  periodic  review  of  permits  to  address 
hydromorphological  pressures20  b)  the  extent  in  which  the  concept  of  ecological  flows  considers 
downstream areas and countries, and c) the timeline for completing the implementation of ecological 
flows. With respect to the recommendation from the 2nd RBMPs compliance assessment, related to 
lowering the hydromorphological pressures from agriculture, there is seemingly hardly any progress. 
The main measures planned beyond 2027 are the following21: 

•  Renaturation measures to create habitats in water bodies (e.g. hydromorphological conditions of 

water bodies other than longitudinal continuity (KTM6)): 27% of surface water bodies; 

•  Measures  establishing  longitudinal  continuity  (e.g.  establishing  fish  passes,  demolishing  old 

dams) (KTM5): 26% of surface water bodies; 

•  Measures  to  improve  a  near-natural  water  supply  or  for  a  dynamic  flow  regime  and/or 

establishment of ecological flows (KTM7): 19% of surface water bodies); 

•  Knowledge base, research and reducing uncertainty (KTM14) and;  
•  Natural water retention measures (KTM23). 

Germany is advised, when planning new dams or reservoirs, to carefully assess their environmental 
impacts  and  ensure  that  such  interventions  are  part  of  integrated  water  management  and  water 
resilience strategies, which e.g. consider long-term climate scenarios. 

3.6 What Germany is doing for abstractions and water scarcity 

Germany has not yet experienced nation-wide scale water scarcity issues, but the situation differs 
considerably per region. Shortages in water availability and depleted soil moisture levels have been 
registered in some regions (in the Northeast and in the central regions) during some summers in the 
past. Irrigation demands from agriculture are relatively low in comparison to other regions in Europe. 
As  a  result,  just  as  it  was  the  case  for  the  previous  cycle,  over-abstraction  (understood  as 
consumptive use or net consumption) has not been identified as a significant pressure at the RBD 
level or in significant portions of an RBD for any of the 10 RBDs. Still there are several surface and 
ground water bodies which are significantly affected by water abstractions for public water supply, 
industry, agriculture, hydropower, fish farms and other unspecified sectors. In all RBDs, where water 
abstraction is identified as a significant pressure for GWBs and SWBs failing to achieve good status, 
basic and (predominantly) supplementary measures to address water abstraction are planned. 

19 Ramboll, et al. (December 2021): Assessment of Member States’ progress in Programmes of Measures during the 
second planning cycle of the Water Framework Directive Reference, Member State: Germany: 
https://op.europa.eu/en/publication-detail/-/publication/8db873bd-6d11-11ec-9136-01aa75ed71a1/language-en/format-
PDF/source-313408706 
20 in accordance with the WFD article 11(3)(e) and 11(3)(i) 
21 UBA report (p.72): https://www.umweltbundesamt.de/publikationen/die-wasserrahmenrichtlinie-gewaesser-in-
deutschland 

20 

 
 
 
In Germany, the average annual freshwater abstraction for the period of 2016-2019 amounted to 
22.54 billion cubic metres (Eurostat data). The average water abstraction over that period per sector 
is  as  follows:  electricity  production  and  cooling  (44%),  public  water  supply  (23%),  manufacturing 
industry (19%), mining and quarrying (6%), construction (5%), agriculture (2%) and other services 
(1%). A trend analysis for this 4-year period shows that the amount of water abstracted by agriculture 
(+48%) and public water supplies (+3%) have increased. Conversely, abstractions by the electricity (-
31%), manufacturing (-7%) and construction sectors (-12%) have decreased22. 

There is  a  general  recognition, that  the  situation  will  likely  worsen  because  of  climate change.  In 
particular, the droughts of 2018, 2019, 2020 and 2022 left an impression on German water policy. 

As a result, the Federal Government issued the first ever National Water Strategy in March 202323. 
This strategy had no significant effect on the 3rd RBMPs, but it sets out 10 strategic issues and specific 
78 measures which will positively address the identified shortcomings in some of the RBMPs. The 
strategy states: “Water bodies and their catchment areas must therefore be managed in such a way 
that their functional capacity and resilience are maintained and, where possible, improved, restored, 
and protected for the long term. […] This requires a more integrated and systemic approach to water 
body management. This approach must reconcile habitat functions with the various water uses that 
humans want and need, under dynamically changing overall conditions“. 

It is unclear how this strategy will affect the implementation of the 3rd RBMPs, but the issue of water 
scarcity  and  droughts  is  addressed  in  many  RBMPs24.  Also,  climate  adaptation  strategies  exist  in 
many  Länder.  Overall,  Germany  has  taken  several  basic  and  mostly  supplementary  measures  on 
reducing pressures from abstractions in all RBDs which account for 8% of surface and 5% for ground 
water  bodies25.  In  surface  waters,  these  measures  are  largely  designed  to  ensure  a  minimum 
ecological flow. The determinations of ecological flows have been harmonised across the RBDs26 and 
some have already defined them (e.g. in the RBD Oder or Elbe). 

The main basic measures to control abstraction from surface and groundwater is the concession, 
authorisation,  and/  or  permitting  regime  to  control  surface  and  groundwater  abstractions  and 
impoundments required by Article 11(3)(e).  According to the German Water Resources Act (WHG), 
water withdrawals from a surface water body (e.g. lake or river) or from groundwater for drinking or 
industrial  water  supply  require  a  permit  or  authorisation.  For  abstractions  of  more  than  5,000 
m3/year, the need for an environmental impact assessment (EIA) must be investigated in accordance 
with  the  Environmental  Impact  Assessment  Act  (UVPG)  (case-by-case  assessment).  An  EIA  is 
generally required for water withdrawals of more than 10 million m3/year. 

In the 2nd RBMPs for water abstractions the following points were highlighted: “Water abstractions 
are a major pressure, with no existence of a register, insufficient use of register, updated only every 
6 years or longer, mismatch between permits registered and abstracted quantities allowed.” Since 
most of the German states have registers of abstractions from surface water and groundwater and 

22 Note: conventional statistic abstraction data of Eurostat, EEA and OECD do not take account of evaporation of 
rainwater stored in reservoirs or of water stored in reservoirs further to abstractions from natural sources. Leakage and 
evapotranspiration losses can however be significant in MSs with many reservoirs and/or older irrigation and distribution 
systems. 
23 National Water Strategy – English version (Decision of the German Federal Government of 15 March 2023)  
24 Danube RBD (DE1000), Rhine RBD (DE2000), Weser RBD (DE4000), Elbe RBD (DE5000), Oder RBD (DE6000). 
25 UBA Report: Die Wasserrahmenrichtlinie - Gewässer in Deutschland 2021 | Umweltbundesamt 
26 https://www.lawa.de/documents/lawa-mindestwasser-barrierefrei_1689840769.pdf 

21 

 
 
a register of impoundments27 (the Länder Berlin and Hessen did not provide information on water 
registers) now, the situation has clearly improved. Permits are issued by state authorities for a fixed 
limited  period,  according  to  criteria  set  at  the  level  of  Länder.  Small  abstractions  by  private 
households  are  exempted.  Several  states  only  register  the  number  of  permits  but  not  the  actual 
abstracted amounts (or only as rough estimates). Due to this incomplete information situation, it is 
impossible to say whether there is a mismatch between registered permits and quantities allowed. 
The German States have the possibility to temporary or permanently restrict water extractions under 
the  Federal  Water  Act.  Consequently,  German  states  can  refuse,  or  revise  permits  under  specific 
conditions. 

Germany  is  advised  to increase  the  registration  of  the  actual  abstracted  amounts  to  achieve  the 
environmental objectives in the RBMPs especially in the Länder Bavaria, Thuringia, and Hessen where 
there  are  no  fees  in  place  for  groundwater  abstractions  by  (mining)  industry,  agriculture  or 
municipalities.  In  most  federal  states  that  levy  a  charge,  this  relates  both  to  the  abstraction  of 
groundwater and to the abstraction of water from surface waters. In Berlin, Hamburg and Saarland 
does the levy only cover the abstraction of groundwater. In these states, the abstraction of surface 
water is therefore free of charge28. In view of the increased occurrence of drought periods due to 
climate change, and the risk of over-abstractions, Germany is encouraged to keep track of the actual 
abstracted  amounts.  Also,  the  link  between  permits  and  ecological  flows,  which  are  increasingly 
defined, should be improved. On the positive side, water abstractions in Germany mostly need prior 
authorisation and national authorities conduct sample checks after authorisation or targeted checks 
after complaints to prevent unauthorised abstractions or violations of permit conditions. 

The 3rd RBMPs also include measures to increase water retention, but their number and scope remain 
limited although this an objective featuring prominently in the German Water Strategy. The available 
reporting suggests that water reuse is not foreseen as a measure in any RBD with available reporting. 

International  cooperation  on  water  abstraction/scarcity  issues  varies  significantly  among  the 
international RBDs. In some cases, there is established cooperation on low flows (e.g. Meuse, Rhine). 
The programme "Rhine 2040 – The Rhine and Its Catchment Area: Sustainably Managed and Climate-
Resilient",  launched  in  February  2020,  aims  at  improving  sustainable  management  and  climate 
resilience  in  the  Rhine  RBD.  The  backbone  of  the  planned  actions  is  “win-win”  and  “no-regret” 
measures  that  address  water  quality,  ecology,  low-flow,  and  high-flow  aspects.  It  includes  model 
projections indicating that by the end of the century (2061-2100), water temperatures will increase 
significantly, and average flow conditions will decrease substantially in some areas. 

3.7 Adaptation to climate change 

Considering the close relationship between overall water management and floods management and 
the  importance  of  climate  change  on  both,  the  considerations  of  droughts  and  floods  are  jointly 
addressed in this section. 

Germany  has  a  requirement  in  national  law  to  formulate  long-term  climate  change  adaptation 
programmes  or  measures,  hence  all  RBMPs  have  addressed  this  topic.  Moreover,  each  of  the 
international RBMPs also include climate change considerations. 

27 The 3rd RBMPs also include maps showing impoundments (e.g. reservoirs, retention basins). 
28 BUND-Studie: Die Wasserentnahmeentgelte der Länder 

22 

 
 
There is one main measure addressing climate change (national measure 509), while other measures 
may  still  be  applied  in  response  to  climate  adaptation  assessments.  Although  these  are  not 
consistently listed across all RBMPs, there is evidence that all of them incorporate such considerations 
within RBMPs and PoMs and prioritised against national standards. All RBMPs also conduct climate 
checks,  adopt  additional  measures  to  adapt  to  climate  impacts  and  have  a  targeted  climate 
monitoring programme (biological, chemical, groundwater quantity and quality). 

It is welcomed that German RBMPs include various analyses of the impacts of climate change on 
water management, yet this happens at a relatively general level. LAWA and BLANO have subjected 
the catalogue of measures on which the programmes of measures are based to a climate sensitivity 
analysis29. The "climate change assessment" is however not carried out at the level of the individual 
programmes of measures.  

Although Germany has made progress in addressing abstractions /water scarcity and has adopted a 
National Water Strategy (see above), there is no detailed information in the respective RBMPs which 
define drought and specify its current nor projected impact on individual water bodies in Germany, 
and  the  effects  of  this  upon  chemical  and  ecological  status.  Also,  although  all  RBMPs  contain 
information regarding seasonal droughts or water scarcity and their impacts on water use and diffuse 
point pollution, yet there is no direct mention of drought being the driver for the specific actions and 
measures within RBMPs, nor are water balances for all river basins established in detail, nor are they 
regularly updated and/or monitored. They should for example consider all inputs and abstractions 
and natural losses as well as the needs of water dependent ecosystems. Germany is encouraged to 
take  effective  measures  to  promote  water  efficiency,  while  maximising  the  use  of  nature-based 
solutions for water storage across soils and ecosystems. Drought management plans are not required 
by EU law but were recommended to Germany (and other Member States) by the Commission. No 
national or regional drought management plans exist yet, but it must be noted positively that some 
international river basins are either working on them or have already included them in their wider 
strategies (e.g. Danube or Rhine). Also, several Länder have included the issue in their adaptation or 
other strategies. Moreover, the 2023 National Water Strategy highlights to address droughts as part 
of their package of measures but not in the form of an overarching plan. Also, hardly any applications 
of Article 4(6) exemptions have been identified in the context of climate change. These developments 
are encouraging, and the consequences of droughts and effects of climate change will likely feature 
more prominently in future RBMPs. 

As regards floods, the Floods Directive requires to consider the impacts of climate change on the 
occurrence of floods, and therefore in the preparation of Flood Hazard and Risk Maps (FHRMs) and 
Flood Risk Management Plans (FRMPs). No changes have been identified since the first Flood Hazard 
and  Risk  Maps  (FHRMs).  The  current  influence  of  climate  change,  as  contained  in  hydrological 
statistical data, has been considered. 

The  five  Flood  Risk  Management  Plans  (FRMPs)  assessed  refer  to  coordination  with  Germany’s 
national adaptation strategy and refer to climate impacts and mention IPCC work. All plans have a 
chapter providing information how climate change was considered in the development of the FRMPs 
on a generic level. All five plans which were assessed note that flood events will very likely change 
because of climate change. There is a serious possibility that peak river discharges with a high annual 
frequency will increase. The plans note that heavy rains with the risk of uncontrolled runoff or flash 
floods, with climate change, will probably occur more frequently or more intensely in the future. In 

29 https://www.lawa.de/documents/lawa-blano-massnahmenkatalog_1594133389.pdf 

23 

 
 
catchment  areas  previously  influenced  by  snow  and  glaciers,  floods  can  also  be  influenced  by 
temperature increases causing increased flooding due to reduction in intermediate snow storage or 
intensified ice melt. As a result of an accelerated rise in sea level, increased hydrological loads, higher 
maintenance and adaptation costs for coastal protection systems are to be expected. Thus, the FRMPs 
refer to shifts in the occurrence of extreme events and changes in numerical recurrence times. The 
five FRMPs assessed all state that, in general, all their measures ultimately contribute to adaptation 
to climate change. The measures contribute to limiting the consequences of the aggravated flood 
events that occur with climate change. 

4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring  

On chemical status monitoring, some progress has been made since the previous cycle. This includes 
the inclusion of 12 new priority substances as well as improved emission inventories. The level of 
confidence in monitoring increased as is now very high (99%). Work on long-term monitoring and 
analysis of trends is still not complete but in principle all substances are covered and available for 
trend analysis once sufficient data points for robust statistical analysis have been collected. 

Reporting of emission inventories of all priority substances was carried out for all river basins. Within 
the  assessment,  apart  from  a  partial  indication  of  trends  for  a  limited  (less  than  5)  number  of 
substances, Germany provided some information on trend analysis and if measurements were done 
in sediment or biota. Saxony for example has designated trend monitoring sites for biota, but only 
for  selected  parameters  and  only  at  a  few  overview  monitoring  sites  (for  testing).  Germany  has 
maintained its monitoring capacity. All 45 priority substances were monitored in all German RBDs, 
but 16 substances were identified by Germany as not being relevant in all RBDs30. Meaning that for 
each RBD the number of relevant substances monitored and included in the inventories of emissions 
is different. While this is probably justified it nevertheless decreases the comparability between RBDs. 
The Danube includes 12 substances, but the pollution load could only be quantified for 6 substances; 
Ems  includes  12  substances;  Rhine  includes  27  substances,  Elbe  includes  35  substances;  Oder 
includes six substances; Meuse includes 20 substances; Eider includes 10 substances; Schlei /Trave 
includes 10 substances; and Warnow /Peene includes four substances. Figure 4.1. shows that 100% 
of  the  surface  water  bodies  fail  to  achieve  good  status.  This  is  unchanged  compared  to  the  2nd 
reporting cycle. 

Figure 4. Chemical status or potential of surface water bodies, as reported in 2010, 2015 & 2021. 

30 These are: alachlor, atrazine, benzene, chlorfenvinphos, dicofol, 1,2-dichloroethane, dichloromethane, endosulfan, 
HBCDD, hexachlorbutadiene, octylphenol, pentachlorophenol, simazine, trichlormethane, quinoxyfen and carbon 
tetrachloride. 

24 

 
 
Source: e-reporting from WISE. 

Note: Although Member States are already required to monitor all 45 priority substances that could be discharged into the 
river  basin  or  sub-basin,  the  quality  standards  themselves  must  ultimately  only  be  complied  with  by  2027.  Currently, 
compliance is limited to the 33 substances listed in 2008 (see figure 4.2) but monitoring of all 45 substances listed in the 
amended Directive 2013/39/EU is already mandatory. In 2027 compliance with the quality standards for all 45 substances 
will become mandatory. Figure 4.3 illustrates that PFOS (one of many PFASs /forever chemicals) will likely be a newcomer 
that is there to stay among the top-10 polluting substances in 2027. 

Like  in  other  countries  most  water  bodies  are  affected  by  several  pressures  simultaneously  and 
multiple pressures cause failures to achieve good status. Mostly one or more persistent pollutants 
are the leading cause for failure as they accumulate in the sediment of rivers and lakes or the tissue 
of  aquatic  species  (biota).  A  chart  with  the  top-10  of  priority  substances  causing  failure  of  good 
chemical status is included in figure 4.2. 

25 

 
 
 
 
Figure 5. Overview of top-10 out of 33 most polluting substances priority substances causing failure to 
achieve good chemical status of surface water bodies 

Source: e-reporting from WISE. 

Note: the table lists the 10 out of 33 substances listed in Annex I of Directive 2008/105/EC 

Figure 6. Overview of top-10 out of 45 most polluting substances priority substances causing failure to 
achieve good chemical  status of surface water bodies (including the 12 new substances  added to  the 
priority substance list i.e. numbered 34 to 45 added to Directive 2008/105/EC as amended by Directive 
2013/39/EU). 

Source: e-reporting from WISE. 

Note: For the 3rd RBMP, Member States have only had the obligation to monitor them. Compliance with the Environmental 
Quality Standard values for these 12 new priority substances will be assessed in 2027. 

26 

 
 
 
 
As  seen  for  many  other  countries,  the  priority  hazardous  substances  responsible  for  most  of  the 
failures  are  mercury  and  flame  retardants  (Polybrominated  diphenyl  ethers  -PBDEs).  Those  two 
pollutants are responsible for the failure to reach good chemical status in over 63% of the surface 
water bodies. Other substances for which the most inventories are established are total Polycyclic 
Aromatic Hydrocarbons (PAHs), brominated diphenylethers, isoproturon, benzo(a)pyrene and lead. 

Even with future measures, Germany only expects to achieve 3% of good chemical status by 2027 
and 4% by 2045 mainly due to the accumulation of mercury and PBDEs in the ecosystems which is 
likely to persist beyond 2045. 

Over 80% of all surface waters in Germany are affected by 2 to 6 pollution pressures simultaneously, 
and only 1% is considered unpolluted. Overall, more than 77% of the surface waters and 29% of the 
groundwaters is deteriorated due to agricultural pressures (mainly nutrients and pesticides). At the 
same time around 67% of all surface water bodies are affected by chemical pollutant emissions 
from the multiple sources like industry, mining, and energy sectors. Pollutants from municipalities 
and households impact the status of 35 percent of all the surface water bodies31. None of the surface 
waters  achieves  good  chemical  status,  which  is  caused  both  by  the  aerial  deposition  of  mercury 
originating from the combustion of fossil fuels, and combinations of other pollutants. By 2045, due 
the adoption of comprehensive and complex measures, a slight improvement to 4% is expected. 

Simultaneously, if the ubiquitous, Persistent, Bioaccumulative and Toxic substances (uPBTs)32 that 
cause most of the failures are excluded, depending on the source between 92% (WISE data)33 and 
84% (UBA data) of the surface water bodies would achieve good chemical status34. The variations 
between the RBDs are however considerable. For the Rhine RBD 59 % of water bodies would be in 
good chemical status (without uPBT) and in the Ems RBD this would be 96 %35. 

4.2 Groundwater Bodies: what is their chemical status 

Monitoring 

The monitoring approaches have improved but are still not fully harmonised or, at least, comparable, 
across  RBDs  and  across  German  federal  states.  The  chemical  status  of  groundwater  bodies  is 
assessed against the threshold values for polluting substances mentioned in GWD Annex I and Annex 
II  (Part  B).  The  status  assessments  do  mention  that  the  water  needs  of  Groundwater  Associated 
Aquatic  Ecosystems  (GWAAEs)  and  Groundwater  dependent  Terrestrial  Ecosystems  (GWDTEs)  and 
salinity were considered in the status assessment, but often without much information on how this 
was done and the outcomes. Since the assessment of groundwater monitoring data is decentralised 
in  Germany,  the  intercomparison  of  monitoring,  assessment,  and  classification  of  groundwater 
chemical status between the federal states and between previous and current RBMPs is inconsistent. 

31 Page 16 and 58 of report: https://www.umweltbundesamt.de/publikationen/die-wasserrahmenrichtlinie-gewaesser-in-
deutschland 
32 The uPBTs are: mercury, brominated diphenyl ethers (pBDE), tributyltin & polyaromatic hydrocarbons (PAHs) 
33 Workbook: WFD_SWB_SWPrioritySubstanceWithoutUPBT (europa.eu) 
34 16% of some 5000 monitoring states exceed the environment quality standards (EQS) (UBA report) 
35 WSP report: Compliance assessment of the 3rd River Basin Management Plans 

27 

 
 
 
 
Status assessment 

In 2021, Germany has achieved good chemical status for groundwaters in 67.3% of the groundwater 
bodies.  This  means  only  very  little  progress  is  observed  since  the  1st  RBMPs  and  2nd  RBMPs  with 
62.7% and 63.7 % respectively in good status. 

Figure 7. Chemical status or potential of groundwater bodies, as reported in 2010, 2015 & 2021. 

Source: e-reporting from WISE. 

The main parameters causing the failure to achieve good status are: nitrogen (mainly nitrates and 
ammonia), pesticides and, to a lesser extent, heavy metals (e.g. cadmium, lead, mercury and zinc), 
sulphate,  phosphate,  and  chloride.  Indeed,  across  Germany  22%  of  the  groundwater  bodies  are 
polluted  by  nitrates  and  exceed  the  concentration  threshold  set  by  both  EU  GWD  and  Nitrates 
Directive. Regrettably for those GWBs polluted by nitrates, 16% show an upward trend indicating that 
increasing pollution levels. Only in 1% of the GWBs, the trends depict some improvement although 
concentrations are still clearly above the threshold. For the rest, the trend is stable or unknown. The 
areas of exceedance coincide with the hotspots identified under the Nitrates Directive36 which lists 
27% of the monitoring stations above the threshold in the last reporting period covered the first 4 
years  of  the  2nd  RBMPs37.  As  a  result  of  the  ruling  of  the  European  Court  of  Justice  under  that 
Directive, Germany took additional measures during the 2nd RBMP (see section 4.3) but they have not 
yet resulted in groundwater quality improvements. 

In Germany 9.5% of GWBs are in poor status because of pesticides. Active substances that frequently 
cause failure to achieve good status are: Atrazine, Dimethachlor, Metazachlor, Bentazone, Metolachlor 
and  Chloridazon  (aka  Pyrazone).  Some  active  substances  are  approved  for  use  in  the  EU.  Other 
substances are banned, but e.g. for Chloridazon those bans only came into effect in 2018 and have 
thus not yet resulted in any substantial improvements. 

36 SWD(2021) 1001 – Part 19/38 
37 Commission report on the implementation of the EU directive on the protection of waters against nitrate pollution from 
agriculture https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021DC1000 

28 

 
 
 
4.3 What Germany is doing to combat pollution from agriculture 

Germany identified pollution from agriculture as one of the main pressures in all RBMPs. Overall, 
more  than  77%  of  the  surface  waters  and  29%  of  the  groundwaters  is  deteriorated  due  to 
agricultural  pressures  (mainly  nutrients  and  pesticides).  Although  some  progress  has  been  made, 
gaps and challenges in controlling diffuse pollution from agriculture remain in all RBDs38. Therefore, 
Germany  should  continue  its  efforts  to  address  these  pressures  and  take  effective  measures.  In 
response to a ruling of the European Court of Justice in relation to the Nitrates Directive, Germany 
adopted  a  revised  Fertilizer  Ordinance  (entering  into  force  on  30/04/2020)39.  The  associated 
designation of nitrate contaminated areas is considered one of the main measures in the 3rd RBMPs. 
Germany estimates that this measure alone will reduce the level of fertiliser use up to 20%. 

In addition, Germany has carried out gap assessments that quantify the necessary load reductions 
at the level of water bodies in all RBMPs. However, the results of this assessments are not reported 
in a systematic and comparable manner and not always linked to the planned measures. Examples 
are  available  with  the  biggest  gap  reduction  identified  in  the  Weser  RBMP  where  the  planned 
agricultural measures are expected to reduce the gap for nitrogen by 40% by 2027. 

In the 3rd RBMPs, measures to reduce nutrient pollution from agriculture are planned in over 50% of 
the SWBs and GWBs. For pesticides pollution, the planned measures will be applicable in 10% of the 
SWBs and 7% of GWBs. Over 40% of the measures to reduce nutrient pollution for groundwaters 
apply  in  drinking  water  protected  areas40.  The  funding  of  these  measures  is  secured  from  a 
combination of EU funds, in particular the CAP, and national or Länder funding. From 2010 to 2027, 
Germany estimated a total of EUR 7.9 billion (or 13% of the total investment)41 for the reduction of 
diffuse pollution sources. 

The German CAP Strategic Plan (SP) contains various support schemes for beneficial practises for 
climate and environment42. This includes management of grassland in a more nature-conserving way,  
which adds up to 1.9 million hectares and around EUR 1 billion allocated as EcoSchemes In addition, 
other interventions contribute to improve water quality, such as reducing the use of pesticides. Around 
30% of the agricultural land will benefit from support for practices to improve soil and water quality 
using biological pest management and Germany has a target to have 20% of agricultural land being 
farmed organically by 203043 and a strategy to get to 30% while in 2022 it is 10%44. 

Despite  these  efforts,  Germany  predicts  that  its  efforts  will  not  be  sufficient  to  reduce  nutrient 
pollution and achieve good status by 2027 also due time lag between the application of the measures 
and  the  resulting  improvements  in  water  quality.  Consequently,  Germany  should  conduct  a  more 
(nutrients, 
comprehensive  gap  assessment  for  diffuse  pollutant 

loads  from  agriculture 

38 Thünen Report - Quantifizierung aktueller und zukünftiger Nährstoffeinträge und Handlungsbedarfe für ein 
deutschlandweites Nährstoffmanagement – AGRUM-DE (thuenen.de) 
39  Contents  of  the  Fertilzer  Ordinance  of  30.04.2020  :  Lower  Saxony  Chamber  of  Agriculture  (duengebehoerde-
niedersachsen.de) 
/ 
https://www.bgbl.de/xaver/bgbl/start.xav?start=%2F%2F%2A%5B%40attr_id=%27bgbl120s0846.pdf%27%5D#__bgbl__
%2F%2F*%5B%40attr_id%3D%27bgbl120s0846.pdf%27%5D__1709488045515 

40 UBA Report: https://www.umweltbundesamt.de/publikationen/die-wasserrahmenrichtlinie-gewaesser-in-deutschland  
41 Over 85% of the costs of implementing measures in Germany are borne by the federal states, regional and local 
authorities (DE: Länder & Kommunen) and the federal government. 
42 Mapping and analysis of CAP strategic plans (2023-2027) 
43 At a glance: Germany’s CAP Strategic Plan (europa.eu) 
44 Developments in organic farming - Statistics Explained (europa.eu) 

29 

 
 
agrochemicals, (incl. (PFAS containing) pesticides) across waters in RBDs and link them clearly and 
directly to additional prevention and mitigation measures in the RBMPs (as per WFD Article 11(3)(h)), 
to facilitate the achievement of WFD objectives.  This includes considering long term alternatives to 
intensive agriculture by transitioning to sustainable agriculture, which is especially relevant in regions 
where pressures are particularly high, including more organic farming. 

4.4 What Germany is doing to combat pollution from other sectors 

Germany has taken many measures to address pollution from sectors other than agriculture and has, 
in general, improve its management of this type of pollution by increasing measures associated with 
Key Types of Meaures (KTMs) and by linking measures and pollution. However, not all RBMPs provided 
the same level of detail when it comes to linking individual substances explicitly to KTMs and specific 
measures to combat pollution as well as the availability of gap analysis. Moreover, Germany argues 
that  delays  in  implementing  measures  are  often  attributed  to  (financial/personnel)  resource 
constraints and general acceptance of a measure which hinder the pollution related objectives across 
multiple  RBDs.  While  this  is  partially  the  case  for  priority  substances  and  priority  hazardous 
substances, these shortcomings are most noticeable for River Basin Specific Pollutants. 

Having  said  this,  Germany  provided  targeted  information  on  basic  measures  required  under  WFD 
Article 11. Use of an authorisation and/or a permitting regime to control wastewater point source 
discharges (in line with WFD Article 11(3)(g)) was reported for all German RBDs including surface and 
groundwater. The register of wastewater discharges is available in all German RBDs for surface and 
groundwater. In none of the German RBDs, wastewater discharges were waived from permitting or 
registration obligations. Measures to eliminate or reduce pollution of priority substances and other 
substances (WFD Article 11(3)(k)) are reported to be in place in all RBDs in Germany. However, RBMPs 
note  that  the  recent  reviews  of  the  lists  of  priority  substances  have  affected  the  outcomes  of 
chemical status assessments and will require further emission reductions. 

The  sectors  that  need  to  reduce  their  emissions  further  are  industry,  mining,  municipalities  and 
households45.  For  around  2%  of  SWBs  and  3%  of  GWBs  it  is  mentioned  that  industry  is  taking 
measures  to  address  water  pollution,  often  related  to  the  remediation  of  contaminated  sites. 
Increasing  attention  is  also  given  to  reducing  heat pollution  from  cooling  water  from  energy  and 
industrial  production.  In  the  light  of  continuously  increasing  water  temperatures  due  to  climate 
change,  such  (additional)  heat  pollution  increasingly  affects  the  aquatic  biodiversity.  Measures  to 
reduce impact from mining activities are planned in 1% of the SWBs and 4% of the GWBs. As regards 
groundwater, measures are often related to managing their levels which has indirectly also an effect 
on the mobilisation of pollutants, e.g. heavy metals. In the Weser RBD some measures are also related 
to the salt pollution from mining activities. 

On the positive side, the 3rd RBMPs illustrate that more detailed information on emission inventories 
(for point sources and to a lesser extent for diffuse sources) has been provided mainly in relation to 
the discharges of priority substances. This suggests that more efforts are undertaken with a wider 
coverage.  However,  it  is  not  fully  clear  if  all  industrial  discharges  and  emissions,  including  salt 
emissions, are listed in a complete and up-to-date publicly accessible inventory of emissions in line 
with article 5 of Directive 2008/105/EC. 

45 Report: Die Wasserrahmenrichtlinie - Gewässer in Deutschland 2021 | Umweltbundesamt 

30 

 
 
It is also unclear whether Germany is working on reducing pollution loads by means of revising of 
existing  water  pollution  permits.  This  is  paramount  to  address  remaining  persistent  pollution 
challenges that will worsen due to climate change. In this context, licensing authorities and/or the 
Federal Government are also urged to set emission limit values for the discharge of PFAS containing 
waste waters into the Rhine to replace the current indicative values that are not legally enforceable. 
Doing so would also be in line with the findings of the EU  analysis report of the 2022 ecological 
disaster in the Oder River. One of the recommendations of that report is to review existing permits 
for industrial emissions and wastewater discharges to lower pollutant loads and introduce obligations 
to  temporarily  suspend  or  limit  discharges  in  case  of  emergencies,  while  considering  the  new 
obligations under the revised IED and UWWTD. 

4.5 What Germany is doing to combat significant pressures – overall 

assessment of the Programmes of Measures 

The 3rd RBMPs seems more detailed than before, with a larger number of measures and more detailed 
associations between Key Types of Measures (KTMs) and pressures. 

Germany identified 75 national basic measures (10 KTMs) and 443 national supplementary measures 
(18  KTMs)  which have been clearly mapped  against the KTMs. It appears that the programme of 
measures covers all water bodies which are not in good status.  Germany identified several obstacles 
which are responsible for the lack of progress in the implementation of measures planned in the 2nd 
RBMPs. These include, delays, lack of finance, lack of mechanism, lack of measures, measures are 
not  cost-effective  as  well  as  land  availability,  acceptance,  and  staff  resources.  International 
cooperation is coordinated well with the national work on programme of measures and complements 
it, where necessary. 

It is welcome that Germany  has taken a uniform approach for the reporting of gap indicators for 
achieving good status in all RBMPs and a catalogue of measures available in the Member State. The 
measures are linked to a pollution type as well as the pressures and impacts. 

Key pressures identified in Germany are:  

•  Flow regulation and hydromorphological changes for agriculture, municipalities and households, 
energy generation, flood protection, navigation, and mining. In Germany around 86% of the water 
bodies are affected by significant pressures in this category; 

•  Diffuse  pollution  sources  causing  emissions  of  pollutants  from  agriculture  (nutrients  and 
pesticides),  mining,  urban  areas,  contaminated  sites  or  abandoned  sites  and  spills  following 
accidents. In Germany 98% of the surface water bodies and 42% of the groundwater bodies are 
polluted by substance inputs from diffuse sources as they occur almost everywhere; 

•  Atmospheric deposition of air pollutants from industry, agriculture, and households; 

•  Point sources for substance inputs from municipalities and households, industry, and commerce, 
mixed and rainwater, mining, or contaminated sites. Substance inputs from point sources affect 
32%  of  surface  water  bodies.  The  points  sources  are  mainly  attributable  to  industry, 
municipalities and households, storm water overflows via combined sewage and rainwater as 
well as mining. 

31 

 
Water  abstraction  for  industry  and  commerce,  agriculture,  mining,  public  water  supply,  power 
generation, shipping, or fishing industry. Germany characterises water abstractions as significant if 
they, for example affect fish fauna and macro-zoobenthos (animal organisms at the bottom of the 
water body) and prevent the water body from achieving good status. This is the case in 9% of surface 
water bodies and in 4% of groundwater bodies. 

5. Exemptions and economics 

5.1 To what extent are exemptions applied in Germany 

Germany makes a considerable use of exemptions of all types. It should be noted that more than 
one  exemption  type  can  be  applied  to  the  same  surface  or  groundwater  body.  In  the  3rd  RBMPs, 
Germany has significantly improved the transparency and justification for the exemptions applied in 
comparison to the previous RBMPs. It is worth noting that Germany embraces a new ‘transparency 
approach’ which depicts a –according to Germany- realistic timeframe for the achievement of WFD 
objectives  well  beyond  the  legal  deadline.  Based  on  this  approach  Germany  claims  that  the 
environmental objectives will only be achieved beyond 2045. This means that Germany expects to 
fail compliance with good status in many water bodies (e.g. 16% of all SWBs are estimated to fail 
good ecological status by 2045). Because of this approach, Germany used mainly time exemptions 
(WFD Article 4(4)) with justifications why achievement of good status by 2027 will not be reached. 
Germany  has  adopted  a  harmonized  approach  for  applying  exemptions  (see  LAWA  document46). 
Detailed information on the types of exemptions used is included below and demonstrates that time 
related exemptions are indeed the most frequently used. 

Article 4(4) exemptions (time related exemptions) applied for reasons of technical feasibility, 
disproportionate costs, or natural conditions. Below a more detailed overview of the applied reasons: 

The time exemptions for SWBs are applied for reason of:  

•  Natural conditions: 51.2% for ecological status/potential and 63.1% for chemical status; 

•  Technical feasibility: 24% for ecological status/potential and 0.4% for chemical status; 

•  Disproportionate costs: 24.2% for ecological status/potential and 0.7% for chemical status. 

The time exemptions for GWBs are applied for reason of: 

•  Natural conditions: 16.8% for chemical status and 0.9% for quantitative status; 

•  Technical feasibility: 4.6% for chemical status and 0.7% for quantitative status; 

•  Disproportionate costs: 0.2% for chemical status. 

The main pressures resulting in the need to apply time exemptions come from pollution caused by 
atmospheric  deposition,  stormwater  overflows  and  historical  pollution  for  surface  waters  and 
agriculture,  mining,  and  historic  pollution  for  groundwaters.  The  large  number  of  SWBs  using 
temporary  exemptions  because  of  natural  conditions  linked  to  diffuse  atmospheric  deposition  is 

46 Approach to justifying Article 4 exemptions in Germany is set out in the Methodology document (2020 edition) 
Microsoft Word - 03_Anlage_3_LAWA-HA_Fristverl.docx 

32 

 
 
worth  investigating  in  more  detail  as  this  is  mainly  linked  to  air  pollution  from  mercury  which 
nowadays is mainly associated with burning of fossil fuels not natural sources of pollution (such as 
volcanoes). To a lesser extent time related exemptions can also be related to natural conditions and 
used to justify delays in restoring water quality, restoring hydromorphological conditions, recovery 
from acidification, delays in restoring water levels, and recolonisation of native species to recover 
from invasive alien species. 

Germany should ensure that the time related exemptions are correctly motivated and safeguard that 
all  measures  necessary  for  achieving  good  status  or  potential  by  end  of  2027  are  identified  and 
initiated (implemented) during this cycle, to avoid unjustified time exemptions beyond 2027 (i.e. other 
than exemptions based on natural conditions). 

Article 4(5) exemptions (lowered objectives) are justified on grounds that the achievement of 
the objectives would be infeasible or disproportionately expensive. Below a more detailed overview 
of the reasons. The assessment shows that they have been used much more sparsely.  

• 

Infeasibility: 0.2% for ecological status/potential and 0.1% for chemical status; 

•  Disproportionately  expensive:  0.2%  for  ecological  status/potential  and  0.1%  for  chemical 

status. 

The lowered objectives for GWBs are applied for reasons of: 

• 

Infeasibility: 1.3% for their chemical status and for 1.5 % for their quantitative status; 

•  Disproportionately expensive: 0.3% for chemical status and 0.1% for quantitative status. 

Article 4(6) exemptions (temporary deterioration) 

Germany hardly uses these exemptions (0.4 % of all water bodies for quantitative status). 

Article 4(7) exemptions (exemption to the obligation of non-deterioration, in case of new 
modifications or sustainable human development activities)  

In the 3rd RBMPs. A quite limited amount of Article 4(7) exemptions have been applied to allow for 
the deterioration of the status of certain water bodies without being in breach of the Directive. These 
exemptions have been applied to two surface water bodies and 14 groundwater bodies groundwater 
bodies. Although some information was provided, this aspect may merit further investigation as the 
WFD  requires  solid  information  and  justification  on  the  exemptions  under  Article  4(7)  WFD  in 
particular for new projects. 

The  exemptions  provided  for  by  the  Groundwater  Directive  (Article  6.3)  have  not  been  applied 
significantly in the 3rd RBMPs. Three GWBs in the Weser RBD are associated with these exemptions 
due to salt pollution from mining. 

5.2 Use of economic analysis and water pricing – cost recovery 

Financing of measures 

33 

 
The success of the implementation of the WFD depends on sufficient financing and investments. A 
clear improvement compared to the last management cycle is that in Germany, a uniform approach 
has been adopted for financing measures. In previous cycles, the numbers were calculated differently 
in the various federal states. The harmonised method specifies the following main areas of action47: 

Improvement of wastewater treatment 

1. 
2.  Reduction of nutrient inputs from agriculture to water 
3. 
4. 
5. 
6.  Reduction of mining impact on water bodies (only where relevant)  
7.  Remediation of contaminated sites (only where relevant) 

Improving the continuity of watercourses 
Improvement of water balance (only where relevant) 
Improvement of water structure – Habitats improvements above ground water bodies 

The total investment costs for the implementation of measures already implemented since 2010 
and planned until 2027, are around EUR 61.5 billion48. By way of comparison, in 2013 alone Germany 
spent €19.2 billion on roads, which is around €230/year per capita. With estimated water protection 
costs of around 21 billion for the period between 2022 and 2027 this means water protection costs 
are six times lower, with average cost of around €37/year per capita. It is noted very positively that, 
compared to the previous cycle, the investments increased from EUR 15 billion to EUR 21 billion. 
Figure 5.2a shows that of the 61.5 billion to be spent until 2027 roughly 49.3% will be attributed to 
wastewater related measures. Around 12.85 % (€ 7.9 billion), will be spent on reducing inputs from 
diffuse sources (incl. agricultural emissions) and 37.9% (€23.3 billion) on water measures ensuring 
continuity, improving water management and structure. Of the latter roughly 14.3 billion is attributed 
to improving water structures and habitats, 8.1 billion to improving the continuity of water courses, 
0.7 billion to improving the water balance, and 0.2 billion to reducing the impacts on standing waters 
(including impacts from mining and contaminated sites). These beforementioned figures are higher 
than those included in the individual RBMPs and reported to the EU which add up to total of EUR 17,6 
billion.  However,  it  is  noted  that  some  estimates  were  derived  from  cost  of  measures  in  the  1st 
RBMPs49.  In  view  of  the  water  quality  situation  in  Germany,  current  levels  of  investment  seem 
insufficient  to  adequately  address  the  situation.  Consequently,  investments  should  increase 
investments  and  ensure  adequate  financing  to  facilitate  a  timely  and  full  implementation  of  the 
Programmes of Measures to reach WFD-objectives. 

Figure 8. Cumulative costs of implementing measures (in % and in absolute amounts in € billion) by main 
field of action during the period 2010 to 2027 

47 https://www.lawa.de/documents/lawa-hintergrunddok-harmonisierte-berichte-final-stand-16-02-2021-
barrierefrei_1689844556.pdf 
48 UBA report P.96 https://www.umweltbundesamt.de/publikationen/die-wasserrahmenrichtlinie-gewaesser-in-deutschland 
49 Consultant report, p. 144 and https://www.lawa.de/documents/handlungsanleitung-wirtschaftliche-
analyse_2_3_1607682700.pdf 

34 

 
 
Cumulative costs of implementing measures (in % and in absolute 
amounts in € billion) by field of action during the period 2010 to 2027

12.85%
€7,90

37.89%
€23,30

49.27%
€30,30

Urban waste water / sewage
related measures

Water measures (incl. river
continuity, water balance,
hydromorphological measures
etc.)

Pollution from diffuse sources

Source: UBA report based on harmonised data Federal States (LAWA) / Berichtsportal WasserBlick/BfG. Date: 29.03.2022 

More than 80% of the costs of implementing measures in Germany are borne by the federal states 
and regional and local authorities (DE: Länder & Kommunen), 10% by private individuals and less 
than  5%  by  the  federal  government.  The  Länder  and  municipalities  finance  a  large  part  of  the 
measures through taxpayers’ money and through fees and levies. This raises concern on the correct 
application of the polluters pay principle.  

Cost recovery and adequate contribution by water use sectors - water pricing 

The cost recovery of water services is mainly implemented by following three instruments:  

1.  A drinking water fee (DE ‘Trinkwasserabgabe’).  

All RBMPs include a clear description of how the costs are recovered for drinking water services. For 
households  the  prices  vary  between  the  different  RBDs  as  it  is  strongly  influenced  by  regional 
conditions. The average consumption price per cubic meter was € 1.72/m³ but varies from 0.96 €/m³ 
(Eider RBD) to 1.88 €/m³ (Rhine RBD). The cost recovery rates for drinking water supply are around 
100% nationwide. So far resource costs were hardly influenced by water scarcity, except in individual 
regional cases. The extensive droughts of 2018, 2019 and 2020 illustrate that this will change due 
to climate change. The quality of raw water, for drinking water abstractions using surface waters or 
shore infiltrates will increasingly be negatively affected50. Overall, each inhabitant pays on average 
€200 /year for their drinking water supply and wastewater drainage. 

50 https://www.lawa.de/documents/lawa_auswirkungen_des_klimawandels_auf_die_wasserwirtschaft_1552292350.pdf 

35 

 
 
 
 
 
2.  A nationwide wastewater levy (DE ‘Abwasserabgabe’).  

In Germany, companies and (semi) public bodies (municipalities, wastewater associations51) pay a 
wastewater levy collected by the municipalities that clean and dispose of wastewater. The levy is 
partly based on the discharged amounts (quantity and harmfulness) of polluting substances. Finally 
fixed  basic  wastewater  charges  are  in  place  in  all  RBDs  (charges  based  on  population-weighted 
municipal  data).  The  average  is  €18.22/year  but  varies  between  €2.81/m3  (Meuse)  to  €83.04/m3 
(Warnow/Peene)52.  Germany  reports  full  (financial)  cost  recovery  for  wastewater  services  with 
recovery rates between 93% and 105%. Despite these levies, treated wastewater and stormwater 
overflows still contain levels of nutrients and micropollutants that cause failures of achieving the 
WFD objectives. Nevertheless, industrial point source pollution and diffuse pollution with nutrients 
and pesticides remains a major pressure for German surface water quality. Consequently, Germany 
is  encouraged  to  making  better  use  of  the  ‘polluter-pays  principle’  and  where  needed  eliminate 
environmental harmful subsidies whilst ensuring affordable, just and fair pricing mechanisms for all 
water users in line with Article 9 WFD. 

3.  Water abstraction charges (DE: Wasserentnahmegelt) 

The federal states set their own charges for water abstraction. Most of them (13 out of the 16) levy 
charges for the abstraction, extraction, or discharge of groundwater (see figure 5.2b). The charge (in 
€ Cent/m3) vary between 1.5 to 31 cent/m3 and the total revenues per Federal State between €3.7 
to  €  90 million.  In  Bavaria,  Thuringia,  and Hessen there  are  no  ground  abstraction  charges  at  all 
(2023 data). For the abstraction and discharge of cooling or irrigation water from surface waters e.g. 
in the areas of hydropower, agriculture, mining, cooling and drinking water, the prices per cubic metre 
vary between 0.5 and 31 cents - if a charge is levied at all53. There are several exceptions to the 
application of the cost recovery principle for water services. For example,  agricultural irrigation in 
Baden-Württemberg,  Mecklenburg–Western  Pomerania,  North  Rhine-Westphalia  and  Rhineland-
Palatinate is free of charge. Detailed information on forecasts and volume estimates of water supply 
and demand of water services is also lacking. Consequently, efforts towards full application of the 
cost-recovery principle to all water use activities impacting water bodies should be increased. 

51 Under German law, groups of municipalities often jointly establish ‘special-purpose water associations’ or ‘special-
purpose wastewater associations’ (abbreviated to WZV (Wasserzweckverband) or AZV (Abwasserzweckverband)). They are 
tasked with wastewater treatment, water supplies, water maintenance or flood protection. Tariffs are put in place to cover 
the costs of the joint tasks. 
52 Figures 3-25 and 3-27 of Annex 6 of Elbe RBMP 
53 https://www.bund.net/fileadmin/user_upload_bund/publikationen/fluesse/fluesse_wasserentnahmeentgelt_studie.pdf 

36 

 
 
 
 
Figure 9. Groundwater abstraction charges and total revenues per federal state in Germany 2020 

Groundwater abstraction charges & total revenues per federal state 

Bayern
Thüringen
Hessen
Baden-Württemberg
Saarland
Rheinland-Pfalz
Sachsen
Sachsen-Anhalt
Brandenburg
Berlin
Nordrhein-Westfalen
Bremen
Niedersachsen
Hamburg
Mecklenburg-Vorpommern
Schleswig-Holstein

0

10

20

30

40

50

60

70

80

90

100

Total revenue (in € Mio)

Water abstraction charge (in Cent/m3)

(Source: Annex 6 - Elbe 3rd RBMP, page 57: https://lvwa.sachsen-
anhalt.de/fileadmin/Bibliothek/Politik_und_Verwaltung/LVWA/LVwA/Dokumente/4_landwirtschaftumwelt/404/Seite_Wasser
_bewegt/FGG_Elbe/Anhaenge/Bewirtschaftungsplan_FGG_Elbe_2021_Anhang_A6.pdf. 

The financing of measures related to industry and industrial emissions, including the mining industry, 
generally are financed directly by these industries if they are in operation. At the end of the activities, 
e.g. when mines are closed down, these measures are only partly covered by the mining companies 
but also by public finances. Overall, nearly a third of al SWBs are associated with measures to tackle 
pollution from municipalities and households. Nature-based solutions are also used, e.g. removing 
soil sealing so that rainwater drains directly into the ground which also has a positive effect on local 
groundwater levels and therefore prevents water scarcity. At a small scale, also the connection of 
remote areas to the sewerage systems or putting together small wastewater treatment plants into 
bigger  ones,  which  improves  treatment  efficiency,  are  planned.  In  addition,  the  costs  of  many 
precautionary and damage prevention measures, such as precautionary measures in water protection 
areas, voluntary quality assurance measures that go beyond the legal requirements, etc., are already 
covered. 

37 

 
  
 
 
6. WFD recommendations 

Recommendations - Germany should: 

1.  Address the identified lack of compliance of achieving good status by increasing the level of ambition and 

reducing the compliance gap as much as possible until the next reporting cycle. 

This means in particular, that: 

Where the objectives of the Directive for a specific water body cannot be met and exemptions are invoked, 
Germany should do so in line with ECJ jurisprudence on the restrictive interpretation of exemptions and 
better justify the use of exemptions, providing sufficiently detailed justifications at the level of the water 
body and ensure that their application is regularly reviewed. This implies: 

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

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

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

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

2. 

3. 

Increase  the  investments  and  ensure  adequate  financing  in  prevention  and  restoration  to  ensure 
achievement of good status as required by the Directive, e.g. by making better use of the ‘polluter-pays 
principle’  and  by  eliminating  environmental  harmful  subsidies  whilst  ensuring  affordable,  just  and 
implementing fair pricing mechanisms for all water users in line with Article 9 WFD. When using EU funds, 
ensure that programmed amounts under Cohesion Policy 2021-2027 and the Common Agriculture Policy 
are  adequately  implemented  and  effectively  contribute  to  implement  the  Programmes  of  Measures  to 
reach the objective of the Water Framework Directive and Floods Directive. 

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

This implies, inter alia: 

a)  Reduction of nutrient pollution including the setting and achievement of maximum nutrient loads in all 
river basin districts to achieve the objectives of Water Framework Directive (WFD), Marine Strategy 
Framework Directive (MSFD) and the Nitrates Directive (ND). 

b)  Addressing  diffuse  chemical  pollution,  e.g.  including  pesticide  pollution  by  reducing  their  use  and 

phasing out unsustainable practices. 

c)  Further prevent and reduce point source pollution to address nutrients and priority substances and river 
specific pollutants, e.g. by reviewing existing permits for point source emissions to lower pollutant loads 
or introduce obligations to temporarily suspend or limit discharges in case of emergencies (like the low 
flow conditions during the Oder ecological disaster). 

38 

 
d)  Expanding the efforts on nature-based solutions including renaturalisation and ecosystem restoration 
which will reduce the hydromorphological pressures on its water bodies (e.g. reducing pressures from 
agricultural drainage). 

e)  More  consistently  measuring  hydro  morphological  pressures  on  surface  waters  and  assess  river 
continuity as a hydromorphological quality element for classifying the ecological status and potential 
of  all  river  water bodies,  including  those  that  are  heavily  modified  and  artificial.  To  improve  those 
conditions Germany should step up its efforts to improve river continuity, ensuring minimum ecological 
flows, improve the general hydrological situation and increase fish protection. 

f)  More systematically include the water needs of groundwater dependent ecosystems (both terrestrial 

and aquatic) in the assessment of the quantitative status of groundwater bodies.  

g)  Provide, in its RBMPs, more complete information on the designated protected areas, and ensure the 
water  bodies  associated  with  protected  areas  have  an  appropriate  level  of  protection  and,  where 
needed, appropriate additional objectives and measures.  

h) 

In view of climate change induced increased dry periods, and the risk of over-abstractions, to increase 
and harmonise the use of abstraction permits and fees for all water users nationwide, monitor the 
actual abstracted amounts, and harmonise the inconsistent use of exemptions from water fees. This 
concerns  e.g.  groundwater  abstraction  fees  for  industry,  agriculture  and/or  municipalities,  but  also 
different regimes for surface water abstractions, abstraction fees and exemptions across the federal 
states. 

4.  A further improvement of governance and a better coordination between the different administrative levels 
and authorities dealing with the implementation of the WFD and other related pieces of legislation. This 
also  includes  removing  obstacles  identified  in  the  implementation  of  measures,  such  as  insufficient 
administrative capacities and resources. 

Points of attention are:  

•  Strengthening synergies and coordination between the WFD, MSFD and other EU legislation (notably 

BHD) by taking adequate and coherent measures.  

• 

Improving the EU wide comparability of the results of the status assessments, specifically regarding 
the  assessment  of  physico-chemical  and  hydromorphological  conditions  related  to  their  sensitive 
biological  quality  elements.  Existing  excellent  cooperations  between  Member  States  on  reference 
conditions and monitoring is acknowledged and praised by the Commission and should preferably by 
widened to EU-wide harmonised classification and status assessments; 

5. 

Improving the work on international River Basin Management Plans for e.g. the Oder and the Rhine rivers.; 

•  Similarly, also for groundwater bodies international cooperation is almost non-existent; 

• 

Furthermore, on water abstraction an increased transboundary cooperation is desirable; 

•  Although overall, the work on applying ecological flows is on-going implementation elements between 
the Länder can be further harmonised e.g. in relation to ecological flows and the interrelations with 
water abstractions and related permits. 

6. 

Further close knowledge gaps and improve data availability, access to data, as well as data quality and 
comparability by harmonising methods and electronically collected data across river basin districts and 
marine regions, on monitoring, assessments, projections, economic assessment, etc. and make all data 
openly  available  through  timely  publication  in  line  with  the  requirements  of  the  INSPIRE,  Open  Data 
Directive /Public Sector Information (PSI) Directives and the public sector High Value Datasets (Commission 

39 

 
Implementing  Regulation  (EU)  2023/138)  to  help  eliminate  the  need  for  reporting.  This  implies  better 
connecting data and information systems of all administrations involved in the implementation (also others 
than the water competent authorities) and make better use of the opportunities from digitalisation and 
earth observation. 

7.  Enhance the consideration of climate change in all its RBMPs ensuring that the actions identified under the 
new National Water Strategy are already implemented during the 3rd RBMP. Where relevant measures for 
climate resilience and drought management should be developed to achieve the objectives of the WFD 
more effectively. Failure to do so will make it increasingly difficult to achieve the Directive’s objectives and, 
in some cases, might even lead to a deterioration of waters where progress has been achieved. 

SECTION B: 
FLOODS DIRECTIVE 

40 

 
 
 
 
7. Flood risk management under floods directive (FD) 

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

There are ten Units of Management (UoMs) in Germany, which are the same as the Water Framework 
Directive’s  River  Basin  Districts  (RBD).  Fluvial  and  sea  water  floods  are  considered  as  potentially 
significant  sources  of  flooding  in  Germany.  Germany  has  designated  732  Areas  of  Potential 
Significant Flood Risk (APSFRs). The impacts of climate change on flood risk have been considered in 
Germany at the time of the second preliminary flood risk assessment. For inland flooding modelling 
was carried out by linking global and regional climate models with water balance models, to obtain 
statements  about  future  climate  change.  For  the  future  climate  projections,  the  development 
scenarios of the Intergovernmental Panel on Climate Change (IPCC) were used as a basis. For coastal 
flooding a “climate surcharge” on dykes is applied to cover risks due to future climate change driven 
sea level rise. 

7.1 Flood hazard and risk maps 

Germany is using online map portals54 for their FHRMs. FHRMs were prepared at the national level 
and  show  the  whole  country.  Maps  for  floods  with  low  probability  (>1/200  years),  with  medium 
probability (1/100 years) and with high probability (1/10 – 1/30 years) are provided. There is however 
a difference between the Laender regarding what is considered as low and high probability (e.g., 20 
years, 25 years). The medium probability is set to 100 years return period, as this is set in the German 
water law (reflecting the FD). Flood extent is shown on all maps. Water depth is shown on all maps. 
Number of inhabitants is clearly shown on all maps. Likewise, type of economic activity is shown on 
all  maps.  Industrial  Emissions  Directive  (IED)  installations  are  shown  and  potentially  affected 
protected  areas  identified  in  Annex  IV(1)(i),  (iii)  and  (v)  to  Water  Framework  Directive  (WFD)  are 
included in the FHRMs. 

Germany  has for  the  second  FHRMs  reported  one  single  GIS  Portal  compared  to  several  hundred 
maps for the first FHRMs. Germany provided for all APSFRs internet links to information that give an 
update on any changes to the maps or to the process used to develop the maps since the previous 
reporting  of  FHRMs.  The  internet  link  refers  to  a  LAWA55  guidance  document  that  has 
recommendations  on  the  national  level  for  the  development  of  FHRMs.  In  2018  LAWA  published 
recommendations  for  the  establishment  of  flood  hazard  maps  and  flood  risk  maps.  These 
recommendations have been applied in all German Laender (federal states). This common approach 
sets a framework for the Laender to fulfil the requirements of the Floods Directive via their individual 
mapping of flood risk. 

54 https://geoportal.bafg.de/karten/HWRM/ 

55 Bund/Länder-Arbeitsgemeinschaft Wasser (federal/state working group on water). 

41 

 
 
 
In terms of changes of contextual information (i.e. the way in which information about the maps is 
conveyed to the public) since the first FHRMs, a noteworthy change is that Germany is now using one 
geoportal  with  all  the  information  stored  digitally  there.  For  the  first  FHRMs  there  was  a  mix  of 
approaches,  with  some Länder  using  geoportals  and  others  only providing  PDF  maps.  For  several 
Laender,  PDF  maps  and  geoportals  still  are  in  use,  which  PDFs  can  be  accessed  via  the  national 
geoportal. Both formats provide more detailed scales (e.g., PDF maps in North Rhine Westphalia at 
1:5 000, geoportal Bavaria at 1:1 200) than the national  geoportal. There has also been progress 
with  the  harmonisation  of  the  categories  of  the  legends  (e.g.,  water  depth,  potential  impacts). 
Common elements in all risk maps are people affected, IED plants, land use (agricultural and forestry 
areas, transport routes,  surface water, settlements, industrial  and commercial areas) and cultural 
heritage (however, not all maps of all Länder refer to UNESCO and not all include protected heritage 
sites of national/regional importance). 

In terms of changes in methodologies used to prepare flood hazard maps since the first FHRMs, no 
changes have been identified. Concerning changes in methodologies used to prepare flood risk maps 
since  the  first  FHRMs,  in  contrast  to  the  first  FHRMs,  now  the  same  approaches  for  all  potential 
adverse consequences are applied across all UoM. 

Climate change in the second FHRMs 

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

7.2 Flood risk management plans 

Objectives and measures 

The ten FRMPs can be downloaded online via a web page56. All German FRMPs have the same four 
general objectives, which were set in the first FRMPs. These objectives are on a high level and are 
based on the risk management cycle. In terms of adverse consequences, it is only mentioned that 
with the objectives, a "reduction of the adverse consequences for all protected assets is aimed for". 
The second FRMPs also have the same specific objectives under these four general objectives. The 
specific objectives were redefined for the second FRMPs. Two general objectives and their specific 
objectives aim to reduce the vulnerability and to mitigate new risks and reduce existing risks. Several 
specific objectives refer to non-structural initiatives. Germany reported preparedness measures for 
all  its  UoMs,  including  measures  for  flood  forecasting  and  early  warning.  However,  no  specific 
information is provided on the established Early Warning Systems. Germany reported measures for 
land use in all UoMs and are found in the five plans assessed. Germany reported that the total number 
of individual measures is 35 721, and the number of aggregated measures is 11 044. The FRMPs 
assessed,  though  not  providing  the  same  detail,  include  a  set  of  types  of  measures  to  be 
implemented. Germany has set priorities (very high, high or medium) for all the measures it reported 
in EIONET. The plans assessed do not, however, contain the prioritisation for each measure, though 
they note that measures are assigned either very high, high or medium priority. 29 873 are reported 
as very high priority (64%), 15 350 as high priority (33%) and 1 572 as moderate priority (3%). The 
shares for these priorities were very similar in the first FRMPs. The prioritisation of measures was 
primarily conducted based on a LAWA guidance document. 12 384 measures, 26% of the total, were 
reported  as  completed,  6 532  measures  (14%)  were  reported  as in  ongoing construction,  16 431 

56 https://www.wasserblick.net/servlet/is/118755/  

42 

 
 
measures (35%) were reported as ongoing maintenance, 5 248 measures (11%) were reported as in 
preparation,  and  6 170  measures  (13%)  were  reported  as  not  started.  The  five  FRMPs  assessed 
provide  overviews  of  the  progress  of  measures  since  the  first  FRMPs,  in  terms  of  their  progress 
towards the specific objectives. It is stated in the plans that economic considerations have a role in 
the  planning  processes  (and  the  implementation  of  measures  is  done  on  several  levels  and 
responsibility is with different stakeholders), but no cost-benefit analysis (CBA) was carried out in the 
preparation of the FRMPs, and no detail is provided on the approach for CBA. Nature conservation is 
mentioned in some plans assessed, but no details are provided. Natural water retention measures 
(NWRMs) are found in all plans assessed. Germany has reported that coordination with the WFD was 
an aspect considered in all its FRMPs. The FRMPs assessed cite the necessity of coordination with 
River Basin Management Plans (RBMPs), and the obligation to foster the achievement of the WFD 
objectives. Measure types are categorised according to whether they support, hamper, or have no 
effect on the implementation of the WFD. The five FRMPs reviewed all refer to the use of public funds 
for  flood  measures;  All  FRMPs  refer  to  the  national  Flood  management  programme  (Nationales 
Hochwasserschutzprogramm57) and to funding by the governments of the Federal States, which also 
have specific funding programmes for flood measures. 

Consideration of climate change in the second FRMPs 

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

Governance 

The five FRMPs that are part of international river basins provide only limited information, referring 
to general coordination mechanisms. The FRMPs that are part of international river basins with a 
river basin commission refer to coordination via existing mechanisms. The FRMPs for the Danube and 
Elbe also refer to bilateral coordination with neighbouring Member States. The FRMP for the Schlei 
/Trave refers to continuous coordination as well as annual exchanges between Germany and Denmark 
on the respective implementation of the Floods Directive on the border area, including on measures 
taken. 

In all five UoMs assessed, the competent authorities made significant efforts for public consultation 
and for the active involvement of stakeholders, using a broad range of methods from an early stage 
in planning. As a result, a wide range of stakeholders contributed actively during the various stages 
of the plan development. 

Progress identified in the second FRMPs 

The  national  flood  web  portal  informs  the  public  about  flood  warnings  and  a  mobile  app  was 
developed to provide up-to-date information on water and flood levels. Germany prepared one FRMP 
per UoM, including the Rhine UoM, in contrast to the first FRMPs, when Germany prepared FRMPs at 
both Federal State and UoM levels. This more uniform approach indicates closer coordination among 
the Federal States on flood risk management. Besides, the second FRMPs follow a common structure, 
also indicating closer coordination across Germany. In the second FRMPs, Germany has developed a 
system to measure the progress towards the objectives. Based on this system, each of the plans 
assessed presents the progress made towards the objectives since 2010. The progress is provided 

57 https://www.lawa.de/documents/230531-broschuere-10-jahre-nhwsp-barr_1685951529.pdf  

43 

 
 
for the four objectives and for their sub-objectives. The criteria for the prioritisation of measures and 
their application are now described in the second FRMPs. The FRMPs assessed clearly identify the 
responsible  authorities  for  monitoring  the  implementation  of  measures  and  overall  progress.  The 
second FRMPs explain that CBA is carried out as part of the planning of measures, therefore it can 
be  assumed  that  it  is  used  for  the  prioritisation  of  measures.  National  recommendations  for  the 
coordination  of  the  FD  and  the  WFD  have  been  developed.  All  five  FRMPs  assessed  now  refer  to 
coordination  with  Germany’s  national  adaptation  strategy,  though  they  do  not  provide  details. 
Germany’s  catalogue  of  flood  measures  underwent  a  climate  assessment,  and  as  a  result  all  its 
measures  were  climate  proofed  on  a  generic  level  (though  details  on  this  assessment  were  not 
provided). 

8. FD recommendations 

Based on the reported information and the FHRMs and FRMPs assessed, the following recommendations are 
made to enhance flood risk management, i.e. Germany should: 

•  Present potential future impacts of climate change in the FHRMs or impacts should be discussed in a 

background document; 

• 

Further harmonise between the UoMs return periods for the three probability scenarios for flood hazard 
mapping or explain why this is not the case;  

•  Consider pluvial flooding in the FHRM; 

•  Provide details in the FRMP on how the FHRM was used in the choice of objectives and measures; 

•  Where possible link the FRMP’s objectives to quantitative indicators and be timebound (building on the 

qualitative monitoring of progress that Germany already does); 

•  Provide information in the FRMP on the expected timetables for the implementation of measures; 

•  Set out in the FRMP a clear overview of the use of cost-benefit analysis (CBA) and the methodology 

behind it; 

•  Provide detail in the FRMP on coordination with other Member States in international river basins, next 

to referring to international FRMPs for further information; 

•  Where appropriate, consider in the FHRM the flow velocity or relevant water flow and the FRMP flood 

conveyance routes, as these are relevant to emergency response. 

44