REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Third river basin management plans Second flood risk management plans
Date: 2025-02-04
Institutions: Directorate-General for Environment, European Commission
Subjects: EU Member State, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2025  COM(2025) 2 final  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 {SWD(2025) 13 final} - {SWD(2025) 14 final} - {SWD(2025) 15 final} - {SWD(2025) 16 final} - {SWD(2025) 17 final} - {SWD(2025) 18 final} - {SWD(2025) 19 final} - {SWD(2025) 20 final} - {SWD(2025) 21 final} - {SWD(2025) 22 final} - {SWD(2025) 23 final} - {SWD(2025) 24 final} - {SWD(2025) 25 final} - {SWD(2025) 26 final} - {SWD(2025) 27 final} - {SWD(2025) 28 final} - {SWD(2025) 29 final} - {SWD(2025) 30 final} - {SWD(2025) 31 final} - {SWD(2025) 32 final} - {SWD(2025) 33 final} - {SWD(2025) 34 final} - {SWD(2025) 35 final}  
 
 
1.  INTRODUCTION 

Water  is  essential  for  life  and  thus  for  our  society  and  economy.  However,  the  EU’s  water 
resources  continue  to  be  under  severe  pressure  due  to  structural  mismanagement, 
unsustainable  land  use,  hydro-morphological  changes,  pollution,  climate  change,  increased 
demand for water and urbanisation. As outlined in the European Climate Risk Assessment1, 
climate change is exacerbating these pressures and increasing water-related risks in the form 
of more frequent,  prolonged droughts  and extreme precipitation  that threaten Europe’s food 
security, public health, ecosystems, infrastructure and economy. Just in recent months, Europe 
has  once  again  witnessed  the  significant  impacts  of  extreme  water-related  events  that  have 
caused tragic losses of human life and many billions of euro of damage. In 2024, prolonged 
droughts  were  experienced  in  several  Mediterranean  countries,  particularly  affecting  central 
and southern  Italy, north-western Spain,  Greece,  and were followed by severe  floods which 
affected most of central and eastern Europe, and later on also in Italy and Spain.  

Sustainable water management, enshrined in the key EU Water Framework Directive2 (WFD) 
and the Floods Directive3 (FD), is at the heart of the response to the triple planetary crisis of 
climate  change,  biodiversity  loss  and  pollution.  It  plays  a  pivotal  role  in  strengthening  the 
EU’s resilience. 

The adoption of this implementation report, a legal obligation of the Commission4, comes at a 
crucial moment, when the realisation of the importance of water, both at EU and global level, 
is increasing in all parts of society. A large majority of the EU population participating in the 
most recent Eurobarometer survey on the environment5 considers pollution, overconsumption 
and  climate  change  as  the  main  threats  to  water  and  support  additional  EU  measures  to 
address  water  problems  in  Europe.  They  also  think  that  almost  none  of  the  main  economic 
sectors are doing enough to use water efficiently. These concerns have also been reflected by 
EU institutions and stakeholders. The European Parliament called for the development of an 
EU  Water  Strategy6.  The  European  Economic  and  Social  Committee  and  the  Committee  of 
the Regions have been calling for an “EU Blue Deal”7. In the strategic agenda 2024–20298, 
the European Council committed to strengthening “water resilience across the Union” in the 
next mandate. The private sector and civil society organizations have also been increasingly 
calling for further action at EU level on water as demonstrated by the letter addressed to the 
highest level of the Commission9. At global level, the UN Water Conference of March 2023 

1 EEA (2024), European climate risk assessment. No 1/2024, https://www.eea.europa.eu/publications/european-
climate-risk-assessment. 
2  Directive  2000/60/EC  of  the  European  Parliament  and  of  the  Council  of  23 October  2000  establishing  a 
framework for Community action in the field of water policy (OJ L 327, 22.12.2000, p. 1). 
3 Directive  2007/60/EC of the European Parliament and of the  Council of 23 October 2007 on the assessment 
and management of flood risks (OJ L 288, 6.11.2007, p. 27). 
4 As required by Article 18 of the WFD and Article 16 of the FD. 
5 https://europa.eu/eurobarometer/surveys/detail/3173 
6  EP  Resolution  of  15  September  2022  on  the  consequences  of  drought,  fire,  and  other  extreme  weather 
phenomena: increasing the EU’s efforts to fight climate  change (2022/2829(RSP)) and subsequent EP Plenary 
debates. 
7 The EESC Umbrella Opinion “A call for an EU Blue Deal” CCMI/209 (25 October 2023). 
8 https://www.consilium.europa.eu/en/european-council/strategic-agenda-2024-2029/ 
9 Joint-Letter-on-the-Water-resilience-Initiative_-Final-Version-1.pdf (euase.net). 

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during which the EU presented its vision for a water-resilient world by 2050, provided strong 
momentum at international level. 
Responding to these calls, the 2024-2029 Political Guidelines for the next College announced 
the  adoption  of  a  new  European  Water  Resilience  Strategy  to  strengthen  Europe’s  water 
security  by  preserving  water  quality  and  quantity  in  the  EU  and  beyond,  enhancing  the 
competitive  innovative  edge  of  our  water  industry,  and  addressing  the  root  causes  of  water 
challenges, including pollution, biodiversity loss, and the impacts of climate change. 

This  report  aims  to  convey  to  the  Council,  the  new  Parliament  as  well  as  the  other  EU 
institutions  and  stakeholders  the  latest  evidence  on  the  state  of  water,  the  pressures  water 
resources are under and Member States’ measures to achieve the environmental objectives set 
in these two Directives. It provides a comprehensive mapping of water challenges in the EU 
that will inform the development of the future Water Resilience Strategy.   

In  addition,  given  the  2027  deadline  set  under  the  WFD  to  reach  good  status  for  all  EU 
waters, this report presents a unique opportunity to take stock of the situation on the ground 
and put forward recommendations to Member States to step up their efforts. The same applies 
for flood risk management objectives under the FD that are more relevant than ever. 

As  this  is  the  first  implementation  report  since  the  adoption  of  the  European  Green  Deal, 
Member  States’  progress  has  been  assessed  under  the  prism  of  achieving  the  EU’s 
biodiversity,  zero-pollution  and  climate  goals  and  an  increasingly  cleaner  and  circular 
economy.  Therefore,  the  report  is  structured  around  the  contribution  of  Member  States’ 
actions to tackling these three interrelated emergencies. 

The  report  is  based  on  the  Commission’s  assessment  of  the  third  river  basin  management 
plans  (RBMPs)  and  second  flood  risk  management  plans  (FRMPs)  for  2022-202710  as 
prepared and reported by Member States. These plans are based on monitoring data collected 
between  2016  and  2021.  This  means  that  while  published  after  the  Green  Deal,  the  report 
largely depicts the situation before the Green Deal. It does not capture the expected benefits 
of the groundbreaking initiatives that the Green Deal has set out. 

The report is accompanied by a series of Commission staff working documents providing an 
EU  overview  of  the  implementation  of  the  WFD,  related  directives  and  the  FD.  The  report 
includes individual Member State assessments and country-specific recommendations. 

These recommendations will serve as the foundation for a structured dialogue with Member 
States  to  significantly  improve  implementation  of  these  laws,  building  on  the  myriad  of 
excellent practices and achievements across the EU. 

Freshwater  and  marine  ecosystems  are  interconnected.  Riverine  pollution,  disruption  to 
sediment  flows  and  water  shortages  all  have  a  very  strong  impact  on  the  health  of  marine 
ecosystems,  particularly the coastal ones,  and the viability  of social and economic activities 
that depend on them, such as transport, fisheries, aquaculture or tourism. The Marine Strategy 
Framework  Directive  (MSFD)  complements  the  WFD  and  relies  on  the  water-related  and 
other EU policy instruments to achieve its objectives. To accelerate effective implementation, 
the Commission aims to encourage a more integrated and coherent approach in implementing 

10 The first RBMPs covered the period 2009-2015. The second RBMPs and the first FRMPs covered the period 
2016-2021. 

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freshwater  and  marine  water  legislation,  in  line  with  a  ‘source-to-sea’  approach11.  For  that 
reason, this report has been developed in close coordination with and is published at the same 
time as the assessments of the second programme of measures (PoMs) taken by the Member 
States under the Marine Strategy Framework Directive (MSFD). Particular attention has been 
paid  to  highlighting  coordination  efforts  in  the  implementation  of  the  Directives  and  the 
linkages  between  action  under  the  WFD  and  the  achievement  of  the  objectives  under  the 
MSFD. 

2.  RBMPS AND FRMPS: STATE OF PLAY IN ADOPTION AND REPORTING 

Although Member States were required to adopt their plans by March 2022, regrettably, many 
adopted them late. This led the Commission to launch legal proceedings against all Member 
States in breach of the legal requirements. Even at the time of finalising this assessment, not 
all  Member  States  had  adopted  their  RBMPs  and  FRMPs  and  submitted  them  to  the 
Commission12. For that reason, this report does not cover those countries or regions. 

The  7  Member  States  not  included  in  the  current  RBMP  assessment  are  Bulgaria,  Cyprus, 
Greece, Malta, Portugal, Slovenia and Ireland, and the 6 Member States not included in the 
current  FRMP  assessment  are  Bulgaria,  Cyprus,  Greece,  Malta,  Portugal  and  Slovakia. The 
data  from  their  RBMPs  and  FRMPs  will  be  published  once  submitted  electronically  on  the 
European  Environment  Agency's  (EEA)  Water  Information  System  for  Europe  (WISE) 
platform13.  In  addition,  the  Commission  will  prepare  country-specific  staff  working 
documents with an assessment of the plans and country-specific recommendations. The data 
will  also  become  part  of  the  2026  Zero  Pollution  Monitoring  and  Outlook  Report,  next  to 
informing work related to the implementation of the EU’s biodiversity and climate adaptation 
strategies.  

3.  METHODOLOGY AND CONSIDERATIONS ON DATA COMPARABILITY 

Both RBMPs and FRMPs are comprehensive documents, consisting of hundreds to thousands 
of  pages  of  information,  published  in  national  languages.  Their  assessment,  entailing 
processing  extensive  information  in  more  than  20  languages,  is  a  very  challenging  and 
complex task. The quality of the Commission assessments relies on the quality of the Member 
States'  reports.  Incomplete  or  deficient  reporting  can  lead  to  wrong  and/or  incomplete 
assessments. 

11 Source-to-sea approach refers to the establishment of governance that increases collaboration and coherence 
across the source-to-sea system and reduces alteration of key flows (water, pollution, sediment, materials, biota, 
ecosystem services) resulting in measurable economic, social and environmental improvement across freshwater, 
coastal, nearshore, transitional and marine environments. It considers the entire source-to-sea system – stressing 
upstream  and  downstream  environmental,  social,  and  economic  linkages  and  stimulating  coordination  across 
sectors and segments. 
12  By  the  cut-off  date  to  be  considered  for  this  report's  assessment  of  30  September  2023,  Bulgaria,  Cyprus, 
Greece,  Malta,  and  Portugal  failed  to  submit  their  RBMPs  and  FRMPs  e.  Slovenia  and  Ireland  only  reported 
FRMPs, and Slovakia only reported its RBMPs. Spain did not report RBMPs for the Canary Islands. 
13 https://water.europa.eu/freshwater.  

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The  lack  of  electronic  reporting14  or  the  partial  submission  of  electronic  reporting  by  some 
Member  States15  in  the  WISE  database16  made  the  Commission's  assessment  even  more 
challenging.  This  situation  is  partly  due  to  the  technical  difficulties  faced  by  the  Member 
States  when  using  the  EEA  reporting  platform  and  partly  to  Member  States’  insufficient 
progress in digitalising water data. As a result, the Commission had to base its assessment on 
data and information that was partly available in digital, easily comparable format and partly 
extracted manually from the RBMPs, the FRMPs and other relevant sources. 

In addition to the above, when reading this report it should be noted that the comparability of 
the  results  deriving  from  the  assessment  of  the  current  RBMP  2022-2027  with  those  of  the 
previous period 2016-2021 is hampered due to different factors as follows. 

1)  Some  Member  States  have  significantly  reclassified  and  re-delineated  part  of  their 
water bodies, leading in some cases to a substantial change in their overall number. 
2)  Significant  improvements  in  the  geographic  coverage  of  monitoring  systems  across 
Member States have reduced the number of bodies with a previously unknown status. 
3)  The  number  of  substances  included  in  Member  States’  monitoring  programmes  has 
also  increased17,  and  some  quality  standards  have  become  stricter  since  the  previous 
report. 

Different  national  approaches  to  designating  and  monitoring  the  pollutants  that  are  not  of 
concern to all the EU but just to some places (known as ‘river basin specific pollutants’) can 
have  a  strong  impact  on  the  assessment  status.  In  addition  to  a  common  set  of  pollutants, 
some countries monitor many more than others. 

4.  WHAT IS THE STATE OF EU WATERS? 

This report's assessment of the third RBMPs covers 20 Member States. This represents around 
90% of the EU’s surface water bodies (rivers, lakes and transitional and coastal waters) and a 
similar  percentage  of  the  EU's  groundwater  bodies  (or  approximately  97 000  surface  water 
bodies and 15 000 groundwater bodies). 

Further  insights  into  the  status  of  Europe’s  water  bodies  is  provided  in  the  EEA  State  of 
European Waters 2024 Report18 published on 15 Oct 2024. It should be noted however that that 
the  EEA  report  covers  a  slightly  smaller  (19  EU  Member  States)  and  different  subset  of 
Member States since it is only based on electronic data submitted to WISE. 

14  The  format  for  electronic  reporting  and  reporting  guidance  was  drawn  up  jointly  by  Member  States, 
stakeholders  and  the  Commission  as  part  of  a  collaborative  process  called  the  ‘Common  Implementation 
Strategy’ (CIS). 
15  For  Italy,  Germany  and  Belgium,  the  analysis  was  based  on  partly  complete  electronic  reporting, 
complemented  by  data  in  PDFs  submitted  for  some  RBMPs.  As  Denmark,  Finland,  Hungary,  Luxembourg, 
Poland, Slovakia and Sweden  either  did not submit data  electronically or did so at a  much later date  after  the 
PDFs were submitted, their analysis has only (or mostly) been based on the PDF documents. 
16 https://water.europa.eu/freshwater.  
17 Not only the 12 new priority substances added in 2013 have been monitored and used by some Member States 
for  status  assessment  (although  the  compliance date  is  only  22 December  2027),  but  also  substances  from  the 
original 33 priority substances that had not been previously covered, even though they should have been. 
18 EEA Report 7/2024, Europe's state of water 2024. The need for improved water resilience 
(https://www.eea.europa.eu/en/analysis/publications/europes-state-of-water-2024). 

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Member  States’  level  of  knowledge  of  the  state  of  water  bodies  has  increased.  There  have 
been significant improvements in the geographic coverage of monitoring systems across most 
Member States and in the number of biological and chemical water-quality elements covered. 
Moreover, the number of priority substances19 monitored by Member States has increased20, 
and quality standards have in some cases become stricter since the last report.  Nevertheless, 
there  are  still  gaps  in  monitoring  certain  substances  in  some  Member  States21,  while 
differences  in  the  methodologies  Member  States  apply  when  monitoring  priority  substances 
can make results  not  always comparable. This  means  that Member States know much more 
about  the  features  and  the  state  of  their  water  bodies.  Issues  that  were  once  unknown  or 
undetected  are  now  being  uncovered,  and  sometimes  these  discoveries  point  towards  bad 
water status22. Nevertheless, over two decades after the entry into force of the WFD, 3 out of 
the 20 assessed Member States still have a vast majority of their surface water bodies with an 
unknown chemical status. These are Lithuania (94.6% of surface waters in unknown status), 
Denmark (92.5%) and Estonia (82.7%).  

At  the  same  time,  the  assessment  clearly  shows  that,  although  the  WFD  prescribes  some 
common  elements  for  monitoring,  there  are  great  differences  in  Member  States’  practices, 
monitoring  frequency  and  parameters  measured.  This  is  a  major  challenge  in  terms  of 
comparability of the status assessment. 

In  addition  to  these  differences  and  despite  the  progress,  major  gaps  in  ecological  status 
monitoring remain, in terms of both spatial coverage and assessment confidence. An equally 
revealing  observation  is  that  Member  States,  rather  than  empirically  monitoring  the 
parameters, very often use expert judgement or extrapolation to group of waterbodies subject 
to similar pressures. 

Surface Waters: what is their ecological status or ecological potential? 

The  Commission  concludes  that  based  on  the  data  mainly  from  2016-2021  reported  in  the 
third RBMPs for 2022-2027, 39.5% of surface water bodies in Europe appear to be in good 
ecological  status  or  ecological  potential23.  This  figure  is  about  the  same  (39.1%)  as  that 
reported by the same countries in the second RBMPs for 2016-2021, which mainly used data 
from 2009-201524. This is consistent with findings from the Nitrates Directives, which show 
that  at  EU  level,  36%  of  rivers,  32%  of  lakes,  31%  of  coastal  waters,  32%  of  transitional 
waters and 81% of marine waters were reported as eutrophic25. 

19 Substances presenting a significant risk to or via the aquatic environment, listed in the Environment Quality 
Standards Directive, as amended in 2013 and in the Groundwater Directive. 
20 Not only the 12 new priority substances added in 2013 have been monitored and used by some Member States 
for  status  assessment  (although  the  compliance date  is  only  22 December  2027),  but  also  substances  from  the 
original 33 priority substances that had not been previously covered even though they should have been. 
21  The  substances  omitted  the  most  are  short-chain  chlorinated  paraffins.  Other  substances  not  included  in  all 
monitoring programmes included diuron, quinoxyfen and tributyltin. Feedback from the RBMPs indicated that 
the main reason that these substances were omitted was related to technical challenges in the analysis or lack of 
available standards to complete the analysis. 
22 Monitoring pollution presence across sediments and living species for long-term trend assessment continues to 
be varied within and across Member States and largely incomplete. 
23 Good ecological potential is the objective to be reached by a heavily modified or artificial water body. 
24 Data extracted from WISE Freshwater (https://water.europa.eu/freshwater). 
25 See the Report of the European Commission on the implementation of the Nitrates Directive from 2021, p. 5, 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021DC1000. 

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Figure 1 – Change in the ecological status assessment of EU surface water bodies from the 
first, second and third RBMPs (Source: WISE freshwater and PDF data mining) 

While  some  limited  improvements  have  been  observed  in  some  Member  States,  other 
Member States reported either no improvement or a significant reduction in the percentage of 
surface  water  bodies  with  good  or  high  ecological  status  or  ecological  potential.  The 
significant  reduction  in  the  number  of  water  bodies  in  good  ecological  status  or  ecological 
potential  was  reported  by  Poland  (-22.9%),  Lithuania  (-15.5%),  Slovakia  (-14.9%),  Czechia 
(-13.3%), Croatia (-9.1%) and Estonia (-7.6%). This reduction may be largely due to a much 
better knowledge and an improved understanding of the state of their water bodies compared 
to the previous cycle. 

Despite  the  overall  limited  improvement  in  the  percentage  of  water  bodies  in  good  or  high 
ecological status, it is encouraging to note that, compared to the two previous RBMP cycles 
(2009-2015  and  2016-2021),  there  has  been  an  improvement  in  certain  biological  and 
chemical  quality  parameters. This  may  reflect  the positive effects  of implementing previous 
measures. In particular, the recent EEA’s State of Waters 2024 report26 shows that the status of 
phytoplankton,  benthic  flora  and  invertebrates  has  improved  in  lakes,  and  there  are  visible 
improvements  in  benthic  invertebrates  in  rivers  and  transitional  waters.  However,  while 
noteworthy, these partial improvements are not sufficient to improve the overall state of water 
bodies  and  to  reduce  the  associated  risks  to  health  and  environment.  Furthermore,  these 
improvements  tend  to  be  overlooked  since  the  WFD  applies  a  ‘one  out,  all  out  approach’, 
which implies that a water body can only achieve good status if all biological and chemical 
quality elements are assessed at least as ‘good’. 

These partial and overlooked improvements may explain, at least partially, why the ecological 
status  assessment  in  the  third  RBMPs  (covering  2022-2027)  shows  an  overall  limited 
improvement  in  comparison  to  the  previous  report  assessing  the  second  RBMPs  (covering 
2016-2021). This lack of progress  can also be due, besides the above-mentioned increase in 
knowledge  and  accuracy,  to  a  possible  increase  in  the  underlying  pressures,  inadequate 
measures and insufficient progress in putting the planned measures in motion. 

26 https://www.eea.europa.eu/en/analysis/publications/europes-state-of-water-2024 

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Against this background, it is not surprising that most Member States indicated that they do 
not expect to achieve good ecological status or ecological potential for all their water bodies 
by 2027. 

Member States have made significant  progress  in  setting  reference conditions27  for different 
water  types.  Such  conditions  are  essential  to  set  benchmarks  and  measure  the  impacts  of 
human  activities  on  biological,  physico-chemical  and  hydro-morphological  elements.  In 
addition,  huge  progress  has  been  made  at  EU  level  thanks  to  the  intercalibration  exercise28, 
which harmonises the national classifications of good ecological status. However, there is still 
a harmonisation gap at EU level, which hampers comparing the overall status assessment. 

Surface Waters: what is their chemical status? 

Achieving good chemical status is an indicator for moving towards zero pollution. As in the 
previous  reporting  cycle,  there  is  a  very  big  difference  between  surface  and  groundwaters, 
with the latter being often better protected. 

The  information  provided  in  the  third  RBMPs  shows  that,  in  2021,  only  26.8%  of  surface 
waterbodies were in good chemical status, as compared to the 33.5% in 2015. This appears to 
show a significant deterioration. 

While the share of surface waters in good status has remained stable or slightly improved in 
some  Member  States  compared  to  2015,  it  has  decreased  and,  in  some  cases,  significantly 
decreased in some others. The latter is the case, for example, in Lithuania (-98.7%), Finland (-
49.5%),  Poland  (-34.2%),  Czechia  (-29.9%),  the  Netherlands  (-29.8%),  Slovakia  (-26.3%), 
Croatia (-11.4%) and Latvia (-10.6%). 

This  deterioration  may  be  largely  due  to  improved  monitoring  and  better  knowledge  of 
‘ubiquitous  persistent,  bioaccumulative and toxic’ substances (uPBTs), major changes in  the 
delineation of water bodies and more stringent standards for some substances. 

Regarding  surface  waters,  the  significant  lack  of  compliance  is  largely  due  to  uPBTs. The 
most  common  of  these  compounds  are  mercury  and  polycyclic  aromatic  hydrocarbons 
(PAHs).  These  are  already  present  in  large  quantities  due  to  legacy  pollution  and  new 
pollution that continues to enter the aquatic environment via atmospheric emissions from the 
combustion  of  fossil  fuels  and  other  fuels.  Another  major  group  of  uPBTs  are 
polybrominated diphenyl ethers (PBDEs), which are heavily used in paints, plastics, foam 
furniture padding, textiles, building materials and industrial processes. These ‘usual suspects’ 
have a very dominant effect on the classification of chemical status, because the environment 
has  a  limited  ability  to  self-purify  itself  of  these  very  frequent  and  persistent  pollutants. 
Without  these  uPBT  compounds,  81%  of  surface  waterbodies  would  have  reached  good 
chemical status, which is roughly the same percentage as in the previous reporting cycle.  

The other substances that cause Environmental Quality Standards’ exceedance and the failure 
to  achieve  good  chemical  status  vary  across  Member  States.  However,  metals  (e.g.  lead, 

27  The  WFD  defines  the  reference  conditions  for  an  ecological  system  as  the  conditions  that  prevail  in  the 
absence or near absence of human disturbance. 
28 OJ L, 2024/721, 8.3.2024: http://data.europa.eu/eli/dec/2024/721/oj. 

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cadmium,  nickel  which  are  typically  linked  to  mining  waste,  municipal  and  industrial 
wastewater,  urban  run-off),  biocides  and  pesticides  (tributyltin,  chlorpyrifos),  and  some 
persistent organic pollutants (e.g. hexachlorobenzene) continue to commonly feature in the 
top of the list of substances leading to failure even if the use of some of these substances has 
been banned since many years. 

It should be noted that uPBTs also continue to be responsible for the failure to meet the good 
environmental status objective for contamination under the MSFD for 80% of the sea area29. 

Figure  2  –  Change  in  the  chemical  status  assessment  of  EU  surface  water  bodies  from  the 
first,  second  and  third  RBMPs  (all  substances,  including  uPBTs)  (Source:  WISE  freshwater 
and PDF data mining) 

SWB chemical status for EU average

3rd

2nd

1st

0%

20%

40%

60%

80%

100%

Good

Failing to achieve good

Unknown

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

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

SWB chemical status without uPBT for 
EU average

3rd

2nd

0%

20%

40%

60%

80%

100%

Good

Failing to achieve good

Unknown

Groundwater bodies: what is their chemical status? 

Regarding groundwater bodies, in 2021, based on the information provided in the 3rd RBMP, 
86%  of  ground  water  bodies  were  in  good  chemical  status. This  is  a  slight  improvement  as 
compared to 82.2% for the same subset of countries in 2015.  

The most commonly reported pollutants leading to poor chemical status are nitrates30. These 
mainly  come  from  intensive  agriculture  and  livestock  farming  through  the  improper  or 
excessive  use  of  fertilisers  and  slurries/manures,  all  of  which  contain  nitrogen  and 
phosphorous. This is the case for 17 out of the 20 Member States. Only Estonia, Latvia and 
Lithuania  do  not  report  nitrates  as  causing  chemical  status  failure  in  their  groundwaters. 
Pesticides and their metabolites are responsible for the failure to achieve good chemical status 
in nine Member States (Austria, Belgium, Czechia, Denmark, Estonia, France, Luxembourg, 
the  Netherlands  and  Spain).  Phosphate  and  ammonium,  which  also,  mainly  come  from 
intensive agriculture and livestock farming, also lead to poor chemical status with a particular 
impact in countries such as Slovakia and Czechia.  

Other  substances  mentioned  as  leading  to  a  smaller  percentage  of  groundwater  bodies  with 
poor chemical status (i.e. less than 10% according to some Member States) include naturally 
occurring  pollutants,  such  as  chloride,  sulphate,  potassium,  iron  and  total  organic  carbon. 
Industrial solvents, PAHs, methyl tert-butyl ether (MTBE - primarily used as a fuel additive) 
and  anionic  surfactants  (common  in  soaps  and  detergents)  are  less  commonly  cited  as  the 
cause of poor status (but were reported by Finland, France, Italy and Latvia). 

30  According  to  the  EEA,  the  average  nitrate  concentration  in  EU  groundwater  bodies  has  not  changed 
significantly since 2021 (EEA, 2023). 

9 

 
 
 
 
 
Figure 4 – Change in the chemical status assessment of EU groundwater bodies from the first, 
second and third RBMPs (Source: WISE freshwater and PDF data mining) 

GWB chemical status for EU average

3rd

2nd

1st

0%

20%

40%

60%

80%

100%

Good

Poor

Unknown

Groundwater bodies quantitative status – have they sufficient water? 

Comparing  the  quantitative  status  of  groundwaters  in  the  same  set  of  Member  States,  it  is 
encouraging  to  observe  a  small  improvement:  95%  of  groundwater  bodies  were  reported  in 
good  status  in  2016-2021  against  92.4%  in  2009-2015.  The  reported  data  show  that  the 
replenishment of groundwater bodies, a big proportion of the EU’s reserves, appears mostly 
secured.  Although  this  may  indicate  that  climate  change  has  not  (yet)  affected  the  EU’s 
groundwaters, it needs to be stressed that not all Member States adequately consider the needs 
of groundwater-dependent ecosystems, and that this picture taken in 2021 does not capture the 
impacts of subsequent years which have been the driest this century. 

Figure 5 – Change in the quantitative status assessment of EU’s groundwater bodies from the 
first, second and third RBMPs (Source: WISE freshwater and PDF data mining) 

GWB quantitative status for EU average

3rd

2nd

1st

0%

20%

40%

60%

80%

100%

Good

Poor

Unknown

10 

 
 
 
 
Nevertheless,  there  are  significant  geographical  differences  across  the  20  Member  States 
covered in this report (see Figure 6). 

Figure  6  –  Overview  of  the  quantitative  status  of  groundwater  bodies  by  Member  State  in 
2021 

In 84% of the identified cases groundwater bodies failed to achieve good quantitative status 
because more water is abstracted from the aquifer than its natural capacity to recharge. Other 
reasons  for  failing  good  quantitative  status  are  saline  intrusion  (25%),  impacts  on  aquatic 
ecosystems  connected  to  groundwater  bodies  (20%)  and  dependent  terrestrial  ecosystems 
(9%). 

Almost all reporting Member States31 carried out a water balance assessment32 for the third 
RBMPs, with most assessing long-term trends too. However, contrary to the provisions of the 
Groundwater  Directive,  when  assessing  the  quantitative  status  of  groundwater  bodies, 
Member  States  do  not  always  consider  the  needs  of  the  groundwater  associated  aquatic 
ecosystems  and groundwater dependent terrestrial ecosystems. This  is a major gap since 
human  activities  that  alter  groundwater  levels  can  significantly  affect  the  status  of  surface 
water bodies or damage precious ecosystems, such as wetlands. 

Throughout  the  past  three  implementation  cycles,  Member  States  have  reported  a  high 
proportion of groundwaters as being in good quantitative status. However, this sits in contrast 
with  the  increase  in  water  scarcity  across  the  EU  and  the  observed  increased  reliance  on 
groundwater  bodies  as  a  source  of  supply  for  public  services  and  irrigation,  which  leads  to 

31 Except Luxembourg where the exercise is ongoing. 
32 A water balance is the amount of water available for allocation, counted as inflows minus outflows in a given 
river basin or sub-basin. 

11 

 
 
 
 
increased  abstractions33.  This  stresses  the  importance  for  Member  States  to  better  apply 
agreed methodologies to assess the quantitative status by duly factoring in seasonal variations 
and  the  accelerating  impacts  of  climate  change,  while  relying  less  on  historical  trends  and 
fully considering the role of groundwaters in supporting rivers and ecosystems. An assessment 
that  is  only  based  on  groundwater  levels  is  insufficient34.  The  situation  also  indicates,  as 
suggested by the EEA, that there could be a need to revise existing methodologies. 

Significantly,  several  Member  States  expect  the  situation  to  worsen  as  they  predict  that  the 
number of groundwater bodies at risk of not achieving good quantitative status by 2027 will 
increase in some cases quite substantially (see Figure 7 below). 

Figure  7  –  Percentage  of  groundwater  bodies  that  Member  States  report  as  at  risk  of  not 
achieving good quantitative status by 2027 (only countries with e-reporting) 

• 
• 

• 

Box 1: Why is the EU still so far from reaching the WFD’s objectives? 
Over the years,  implementation  of the WFD has  gradually improved the knowledge 
and  understanding  of  the  state  of  the  EU’s  rivers,  lakes,  transitional  waters,  coastal 
waters  and  groundwaters.  This  improved  knowledge  partly  explains  some  of  the 
trends outlined above. 
However,  as  well  documented  in  the  2019  Fitness  Check  of  the  Water  Framework 
Directive35,  many  factors  have  played  and  continue  to  play  a  role  in  hindering 
effective WFD implementation and contributed to the overall slow progress since its 

33 According to the EEA,  the groundwater share of total water abstraction has increased from 19% in 2000 to 
23% in 2019. 
34 See Common Implementation Strategy Guidance note No. 18. 
35 SWD(2019) 439 final, p. 116. 

12 

 
 
 
 
 
inception. These factors include: 

o 

late identification or underestimation of the pressures as well as of the efforts needed 
to create a governance framework fit for specific conditions in Member States; 

o 

o  an insufficient reduction in the overall pressures on waterbodies, particularly linked to 
diffuse  pollution  (unlike  the  relative  success  in  dealing  with  point  source  pollution) 
and habitat degradation (for which restoration measures to address pressures from the 
past,  including  hydro-morphological  changes  and  legacy  pollution,  would  be  much 
needed); 
the slow introduction of effective policy measures as Member States’ programmes of 
measures  are often insufficiently based on the analysis of pressures and impacts, and 
there  is  a  tendency  to  rely  on  easy  technological  fixes  that  address  point  source 
pollution but leave other sources of pollution largely untargeted; 
limited  consistency  across  relevant  policies  as  good  status  of  water  bodies  also 
critically  depends  on  integrating  water  objectives  into  other  policy  areas,  such  as 
agriculture, energy and transport; 

o 

o  measures  to  achieve  good  water  status  are  not  prioritised  unlike  other  economic 

activities; 

o  a  predominant  reliance  on  basic  measures36  instead  of  additional  supplementary 

measures implemented at a scale sufficient to reach the WFD objectives; 
the time for nature to respond to measures before the expected results are produced; 
the increasingly felt impacts of climate change (i.e. water temperature increase); 
the lack of funding and constraints in administrative capacity. 

o 
o 
o 

5.  GOVERNANCE AND CROSS-CUTTING ASPECTS 

Proper  governance  is  essential  for  the  smooth  operation  of  complex  water  management 
systems  in  Member  States,  which  rely  on  the  involvement  of  many  different  administrative 
levels  and affected parties. All  Member States have designated their  competent authorities 
for  each  river  basin  district  (RBD).  These  districts  often  involve  several  authorities  with 
responsibilities  for  different  aspects  of  the  RBMPs.  Similarly,  all  Member  States  have 
designated  competent  authorities  for  the  Floods  Directive  (FD).  These  may  differ  from  the 
ones appointed under the WFD, and, in certain Member States, management units identified 
in line with the FD are not the same as the RBDs. 

As required by the FD, many Member States indicate that the FRMPs and the RBMPs have 
been developed in a coordinated and sometimes simultaneous manner37. The vast majority of 
Member States has carried out  a joint consultation of their RBMPs and the FRMPs38, and a 
few have integrated the two plans into a single plan. The situation among Member States  is 
clearly  more  uneven  for  the  MSFD’s  programme  of  measures.  Only  a  few  Member  States 
show  evidence  of  clear  coordination  in  developing  the  WFD  and  MSFD’s  programmes  of 
measures  in  terms  of  process,  content  and  consistency  in  response  to  the  same  pressures. 
Similar  evidence  of  little  coordination  emerges  from  the  parallel  MSFD  reporting  on  the 

36  In  particular,  the  Urban  Wastewater  Treatment  Directive  and  the  Nitrates  Directive,  which  appear  as  ‘basic 
measures’ in the WFD programmes of measures. 
37 Overall, 15 of the 21 Member States provided strong evidence in their FRMPs that coordination was ensured 
with the WFD, while the other 6 had at least some evidence. 
38 Regarding joint consultations of draft FRMPs and RBMPs, 15 Member States reported having carried them 
out, compared to 13 Member States in the previous cycle. 

13 

 
 
 
 
 
second  programme  of  measures39.  This  is  therefore  an  area  where  Member  States  need  to 
intensify efforts to implement a source-to-sea approach. 

Coordination  mechanisms,  while  in  place  overall,  mainly  appear  insufficient  in  ensuring 
there  are  complete  synergies  and  the  appropriate  consistency  across  different  government 
levels  (e.g.  insufficiently  harmonised  approaches  to  implementing  the  WFD  at  subnational 
levels). Coordination with other sectoral policies (e.g. agriculture, energy) is also insufficient, 
particularly  in  relation  to  measures  needed  to  address  the  most  significant  pressures. 
Notwithstanding the fact that proper implementation and enforcement of the WFD and other 
environmental  legislation  is  the  responsibility  of  environmental  competent  authorities,  it  is 
essential  to  ensure  a  more  effective  integration  of  WFD  objectives  in  sectoral  policies  and 
funding instruments  (such as the CAP). This  entails aligning  the interventions supported by 
the CAP with the measures in the RBMPs.  

Most Member States have made notable efforts to boost public participation and the active 
involvement  of  stakeholders  in  developing  their  RBMPs  and  FRMPs  using  a  variety  of 
consultation channels and mechanisms. Overall, a broad range of stakeholders was involved 
in  most  Member  States.  However,  many  plans  do  not  explain  how  the  input  received  was 
taken  on  board  and  whether  those  consulted  were  informed  of  how  their  views  were 
considered.  Such  transparent  communication  would  increase  collective  ownership  of  the 
plans. 

Pressures 

from  atmospheric  deposition 

The most significant pressures for surface water bodies40 in all reporting Member States are: 
pollution 
(affecting  59%  of  waterbodies),  hydro-
morphological  changes  (57%)  stemming  from  drainage  and  irrigation  for  agriculture, 
hydropower,  flood  protection,  navigation  or  drinking  water  supply,  and  pollution  from 
agriculture  (32%).  Other  main  pressures  across  the  EU  are  urban  wastewater  discharges 
(14%),  discharges  not  connected  to  the  sewage  system  (9%)  and  abstraction  (9%)  for 
multiple  purposes.  Other  pressures  most  commonly  identified  in  the  RBMPs  are  pollution 
from  urban  run-off  (8%)  storm  overflows  (5%)  and  discharges  from  industrial 
installations  (6%).  It  should  be  noted  that  the  same  water  body  can  be  subject  to  multiple 
pressures, so the total does not add up to 100%.  

Regrettably,  13%  of  the  EU’s  water  bodies  also  continue  to  be  affected  by  unidentified 
anthropogenic  pressures,  so  there  is  still  room  for  increasing  knowledge  in  this  area.  No 
significant pressure is only identified in 10% of the reported water bodies. 

The  pressure  from  invasive  alien  species  –  those  of  both  EU41  and  national  concern  –  on 
freshwater and marine  ecosystems  in  Europe is  increasing,  as demonstrated by a number of 

39  Commission  Report  to  the  Council  and  the  European  Parliament  on  the  Commission’s  Assessment  of  the 
Member States’ Programmes of Measures as updated under Article 17 of Directive 2008/56/EC  COM(2025) 3 
and related Staff Working Document SWD(2025) 1 
40  Based  on  WISE  freshwater  data  covering  18  of  the  20  Member  States  for  which  the  data  are  available 
electronically as of June 2024. 
41 As listed in Regulation (EU) No 1143/2014 of the European Parliament and of the Council of 22 October 2014 
on the prevention and management of the introduction and spread of invasive alien species. 

14 

 
 
 
reports42.  Despite  the  direct  impact  these  species  can  have  on  achieving  good  ecological 
status,  this  pressure  seems  to  be  understated  and  is  only  identified  in  2.2%  of  the  reported 
waterbodies.  Information  on  invasive  alien  species  and  the  measures  taken  to  tackle  the 
problem is very often missing or not very detailed in the RBMPs. 

While  71%  of  the  EU’s  groundwater  bodies  are  reported  as  not  being  subject  to  any 
significant pressures, almost 30% of them is affected by a range of pressures. This particularly 
includes diffuse agricultural pollution (e.g. pesticides and fertilisers), which affects 59% of 
the impacted groundwater bodies, abstraction for public water supply (25%), abstraction 
for  agriculture  (22%),  industrial  use  (12%)  and  other  purposes  (12%).  Diffuse  pollution 
from other sources, notably urban run-off (16%) and discharges not connected to sewerage 
network (6%), are also major pressures, as are pollution from contaminated or abandoned 
industrial sites (17%) and legacy pollution (13%). 

Programmes of measures 

The picture is nuanced for the analysis of the programmes of measures (PoMs) that Member 
States are obliged to draw up to prevent or limit those pressures. 

A considerable number of measures announced in the second RBMPs were not implemented. 
As  in  the  past,  insufficient  funding  of  measures  has  been  identified  as  the  most  significant 
obstacle  (86%),  followed  by  unexpected  delays  (81%),  the  lack  of  appropriate  national 
mechanisms,  such  as  national  regulations  and  other  measures  not  yet  adopted  (70%),  and 
governance  issues  (57%).  Difficulties  to  acquire  the  land  required  to  implement  certain 
measures is also regularly raised as a key challenge. 

The  third  PoMs  presented  in  the  2022-2027  RBMPs  show  that  Member  States  continue  to 
have different approaches to their design and reporting. The PoMs often contain a fairly long 
set of measures but do not seem to feature several key elements. Most notably, there’s no clear 
assessment of the gap to be bridged to reach good status. There is also insufficient information 
on  the  prioritisation  of  the  measures  based  on  the  required  cost-effectiveness  analysis.  The 
costs and the financing of the planned measures are often missing. Since Member States often 
argue  that  they  face  funding  difficulties,  it  suggests  that  the  resources  needed  to  implement 
the PoMs are not always secured upfront. This weakens the effectiveness of the PoMs. 

6.  TACKLING THE TRIPLE PLANETARY CRISIS 

6.1.  TOWARDS  ZERO-POLLUTION  RIVERS,  LAKES,  COASTAL  WATERS  AND 
GROUNDWATERS 

6.1.1 What is being done to combat pollution from agriculture? 

Diffuse pollution from agriculture is one of the main pollution pressures on EU water bodies 
identified  by  all  reporting  Member  States  in  almost  all  RBDs  and  affects  both  surface  and 
groundwater bodies. This is essentially due to unsustainable land management practices and 

42  For  instance,  freshwater  invasive  non-native  species  have  increased  seven-fold  in  number  over  the  last  100 
years  according  to  Cid,  N.  and  Cardoso,  A.  C.,  2013,  European  freshwater  alien  species,  'Global  Freshwater 
Biodiversity Atlas' (atlas. freshwaterbiodiversity.eu). 

15 

 
 
 
 
excessive  and  improper  use  on  one  hand  of  fertilisers  and  slurries/manures  which  contain 
nitrogen  leading  to  nitrates  in  water,  on  the  other  hand  of  pesticides  and  other  hazardous 
substances. As  set  out  in  Section  2  above,  nitrates  are  the  biggest  pollutant  in  groundwater 
bodies, and they also cause surface water bodies to become eutrophic. This is consistent with 
the  findings  on  the  nutrient  loads  across  EU  marine  regions  that  show  that  for  all  regions, 
except  the  Black  Sea,  the  largest  source  of  nitrogen  in  the  sea  comes  from  agriculture43. A 
more nuanced picture is seen for phosphorous, where the largest contributor for almost all the 
marine regions is wastewater, and agriculture is the second largest. 

Although  considerable  improvements  have  been  observed  compared  to  the  1990s  and  most 
Member States and farmers have made significant efforts to reduce nutrient losses in waters, 
the freshwater quality data show that results have stagnated. This indicates that, to reignite a 
downward trend in nutrient concentrations, more radical measures are needed, which could be 
politically difficult to adopt. Current measures are still not sufficient to reach the objectives of 
the Nitrates Directive and the WFD, almost 35 and 25 years after their adoption, respectively. 
This can also be seen in the marine environment, notably in the Baltic Sea, the marine region 
with  the highest  proportion of coastal waters where nutrient  conditions  is  a problem  (58%). 
Eutrophication also occurs in the southern North Sea, along the north-western coast of France 
and near riverine outflows in the Mediterranean Sea. At the same time, widespread oxygen-
depleted  areas  are  observed  in  the  Baltic  Sea  and  the  Black  Sea,  which  are  caused  by 
eutrophication,  natural  conditions  and  higher  water  temperatures  due  to  climate  change 
impacts. 

This  stagnation  can  be  explained  by  the  fact  that  there  is  limited  progress  in  most  Member 
States in developing quantitative gap assessments as a basis to determine how to reduce the 
load  of  nutrients  and  pesticides.  The  Commission  made  this  recommendation  during  the 
previous cycle, but few Member States have presented the nutrient load reductions and even 
fewer Member States have reported having carried out assessments of the effectiveness of the 
measures taken so far. 

At  the  same  time,  a  clear  and  encouraging  trend  is  the  steady  increase  in  the  share  of 
farmland under organic farming in the EU, which usually results in lower levels of nutrient 
and pesticide pollution. However, the pace of adoption varies across Member States, ranging 
from close to 30% of total farming production in Austria to less than 1% in Malta (see Figure 
8 below). 

43 Report on the implementation of the Marine Strategy Framework Directive (europa.eu). 

16 

 
 
 
 
 
 
 
 
 
 
 
Figure 8 – Share of the total utilised agricultural area under organic farming in 2022 by 
Member State (Source: EUROSTAT 2024)44 

Basic  measures  are  usually  in  place,  but  not  all  Member  States  assess  whether  the  planned 
measures  will  be  sufficient  to  gradually  achieve  good  status.  Where  gap  assessments  have 
been made,  Member States report that the measures will ‘not fully’ close the gap needed to 
reduce  nutrient  and  pesticide  pollution  by  2027.  This  is  consistent  with  the  Commission’s 
previous findings, including under the Nitrates Directive. 

In  addition,  mandatory measures are limited to  those set  out  under relevant  EU legislation45 
and applicable requirements (cross-compliance and greening) under the  common agriculture 
policy (CAP) 2014-2022.  

Many Member States seem to impose restrictions on the use of pesticides mainly when it is 
necessary  to  improve  the  status  of  water  bodies  used  for  drinking  water  abstraction.  Such 
mandatory  requirements  for  farmers  stemming  from  the  implementation  of  the  Water 
Framework Directive can be supported by the CAP under the so-called WFD payments, but 
this instrument remains under-utilised46. 

Several  voluntary  measures  have  been  in  place  often  supported  through  the  CAP,  notably 
through  agri-environment  climate  commitments47  (AECC)  and  other  relevant  measures 

44 EU organic farming: 16.9 million hectares in 2022 - Eurostat (europa.eu). 
45  In  particular,  the  Nitrates  Directive,  the  Regulation  on  placing  of  Plant  Protection  Products  on  the  Market 
(Regulation (EC) No 1107/2009), the Sustainable Use Directive (2009/128/EC). 
46 Four Member States (Austria, Denmark, Luxembourg and Spain) supported these payments under the  Rural 
Development  Programmes  (2014-2022)  and  five  Member  States  have  included  such  payments  in  their  CAP 
Strategic  Plans  2023-2027  (Austria,  Denmark,  Italy,  Luxembourg  and  Spain).  These  payments  have  mostly 
focussed on restrictions on / ban on fertilisation and pesticide use. in drinking water protected areas, and nitrogen 
reducing measures in coastal catchment areas in the case of DK. 
47 Payments for multi-annual commitments for environment and climate friendly agricultural practices which go 
beyond the baseline of mandatory requirements. 

17 

 
 
 
 
 
included  in  the  Rural  Development  Programmes  (2014-2022)  developed  by  Member  States. 
However,  these  measures,  together  with  the  basic  measures  implemented,  have  not  been 
sufficient  to  reduce  pressures  from  nitrates  and  pesticides.  This  might  have  been  due  to  a 
variety  of  factors  including  intrinsic  limitations  in  the  design  of  the  voluntary  measures  in 
questions, the fact that measures were not sufficiently programmed by Member States, limited 
uptake by farmers, or limited uptake in the most affected areas. 

Based  on  the  submitted  information,  the  agricultural  measures  announced  under  the  second 
RBMP  have  not  all  been  implemented  as  planned.  The  reported  challenges  include 
insufficient funding and delays. 

With  respect  to  the  CAP  2023-2027,  an  increased  contribution  to  tackling  pollution  from 
nitrates and pesticides can be expected48. It includes enhanced conditionality49 standards, such 
as  strengthened  soil  management  requirements  (e.g.  crop  rotation/  diversification,  buffer 
strips)  and  a  new  requirement  linked  to  controls  on  diffuse  sources  of  pollution  from 
phosphates. The instruments available under rural development funding50 (AECCs including 
organic  farming,  support  for  investments, WFD  payments,  training  /  advice,  innovation  and 
cooperation) continue to be available and have been complemented with eco-schemes which 
support environment/climate friendly practices; Member States have to dedicate at least 25% 
of EAGF funding to these schemes51. Support from eco-schemes and AECC covers inter alia 
improved nutrient management52 and the sustainable use of pesticides53. 

No  Member  State  is  using  thresholds  for  nutrient  concentrations  to  assess  the  good 
ecological  status  of  surface  waters,  and  only  some  are  determining  the  required  load 
reduction upstream in the relevant river basin. As outlined earlier, this also has an impact on 
achieving the objectives set in the Marine Strategy Framework Directive since, based on the 
data reported by the Member States under Article 8 of the MSFD in 2018, 87% of the sea area 
did not achieve the good environmental status objective for eutrophication. 

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

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

Basic measures to deal with pollution from these sectors are generally in place. These include 
authorisation and permitting systems to control wastewater point source discharges, registers 
of wastewater discharges, the prohibition or restriction of all direct discharges to groundwater, 

of 

See 

and 

CAP 

plans” 

analysis 

strategic 

“Mapping 

(2023-2027) 

48 
(file:///C:/Users/faltech/Downloads/mapping%20and%20analysis%20of%20cap%20strategic%20plans-
KF0323354ENN%20(3).pdf).  
49  Conditionality links the full receipt of CAP support to the compliance of farmers and other beneficiaries with 
basic standards concerning the environment, climate change, public health, plant health and animal welfare. The 
basic standards encompass statutory management requirements (SMRs) and standards of good agricultural and 
environmental conditions of land (GAEC standards). 
50 European Agricultural Fund for Rural Development (EAFRD), c.f. Regulation 1305/2013 
51  See article 97(1) and (2) of Regulation 2021/2115. 
52 Support for farming practices to improve nutrient management are planned to be carried out on 15,2% of the 
EU’s agricultural area. 
53 27% of EU’s agricultural area is planned to be covered with commitments which lead to a sustainable use of 
pesticides in order to reduce risks and impacts of pesticides such as pesticides leakage. 

18 

 
 
 
 
and/or dedicated measures to eliminate or reduce pollution from priority substances and other 
substances. 

In  most  cases,  specific  measures  have  been  implemented  to  deal  with  pollutants  that  are 
causing  failures  to  reach  good  chemical  or  ecological  status  of  waterbodies.  Examples  of 
these measures include efforts to reduce or stop the release of certain pollutants into water and 
the  remediation  of  contaminated  sites,  addressing  historical  pollution  in  sediments, 
groundwater and soil. However, not  all national  RBMPs provide the same level of detail  in 
terms  of  explicitly  linking  individual  substances  to  specific  measures  to  combat  pollution. 
More progress is needed on this front and in developing a gap analysis to inform the design of 
the measures. 

All  Member  States  reported  inventories  of  emissions,  discharges  and  losses  of  harmful 
substances. However, there are large differences among and within Member States in both the 
coverage of the relevant toxic substances and their completeness. The top 10 substances for 
which  emission  inventories  have  been  most  commonly  set  up  are  mercury,  benzo(a)pyrene, 
fluoranthene,  benzo  (g,h,i)perylene  (PAHs),  nickel,  lead,  and  cadmium  (heavy  metals),  and 
nonylphenol  (non-ionic  surfactants),  perfluorooctanesulfonic  acid  (PFOS,  a  type  of  PFAS) 
and tributyltin-cation (a highly toxic biocide). 

Most Member States have reported basic measures related to the construction or upgrade of 
wastewater treatments plants acknowledging that additional efforts are needed to comply with 
the  Urban  Wastewater  Treatment  Directive  (UWWTD).  Currently,  82%  of  EU’s  urban 
wastewaters are collected and treated in line with EU standards. 

The  implementation  of  the  revised  UWWTD  will  further  reduce  pollution  from  urban 
wastewaters.  It  includes  new  rules  on  storm  overflows  and  urban  run-off  that  will  help 
Member States to more effectively address these pressures that had not been covered by EU 
legislation. 

While  the  WFD  does  not  cover  pollution  from  litter,  including  plastics,  this  is  a  key  area 
where synergies with the MSFD must be created since a very large amount of plastic in the 
sea come from rivers. The assessment of the programmes of measures under the MSFD shows 
that Member States have taken many measures to address the main sources of litter, starting 
with activities related to sewage from urban areas and other land-based sources (e.g. industry, 
agriculture).  This  has  led  to  an  estimated  29%  reduction  in  beach  litter  between  2015  and 
2021 across all EU sea basins. These measures are also likely to have had a positive impact on 
rivers, lakes and coastal waters. 

Given the significant pressure that atmospheric depositions continue to pose on the health of 
water  bodies,  action  at  source  to  reduce  emissions  of  pollutants,  including  uPBTs,  resulting 
from  the  use  of  fossil  fuels  through  the  integrated  approach  to  the  pollution  in  different 
environmental  media  advocated  for  in  the  Zero  Pollution Action  Plan  remains  a  priority  to 
achieve the objectives of the WFD. In this respect, the more stringent standards adopted under 
the recently revised Ambient Air Quality Directive, the revised industrial Emissions Directive, 
the effective implementation of the Mercury Regulation, and the EU’s overall decarbonisation 
efforts  are  expected  to  have  a  positive  impact  on  the  reduction  of  emissions  of  some 
individual substances that enter the water environment via air emissions. 

19 

 
 
6.2 RESTORING RIVERS, LAKES, COASTAL WATERS AND GROUNDWATERS 

6.2.1 Changes to physical features and natural flow of water bodies – what is the level of 
human intervention in the water system? 

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

The  RBMPs  show  very  big  differences  between  Member  States  on  the  degree  of  human 
intervention in their natural aquatic environments. The more intense the human intervention, 
the  more  waterbody  features  are  modified,  with  some  becoming  completely  artificial.  The 
proportion  of  these  heavily  modified  water  bodies  (HMWBs)  and  artificial  water  bodies 
(AWBs)  has  slightly  increased  in  this  reporting  cycle:  12.4%  of  them  were  designated  as 
heavily modified and 4.4% as artificial54 in the 20 Member States considered in the analysis 
compared to 11.9% and 4.1% in the previous reporting cycle. 

Figure  9  below  reveals  the  very  high  level  of  human  intervention  in  some  Member  States 
(Netherlands, Hungary, Germany and Belgium) and the well-preserved natural state in some 
others (such as Finland and Sweden). 

Figure 9 – Percentage of surface water bodies that have been designated as heavily modified or 
artificial in the third RBMPs by Member State 

54  However,  there  are  still  three  Member  States  for  which  the  designation  is  either  not  yet  complete  (Croatia, 
Slovakia) or undergoing revision (Sweden). 

20 

 
 
 
 
Three Member States (Austria, Croatia, Slovakia) reported a significant increase in their share 
of  HMWBs  and AWBs,  which  seems  to  be  the  result  of  a  reclassification  of  certain  water 
bodies  and,  to  a  lesser  extent,  new  alterations.  Sweden  is  also  expected  to  significantly 
increase its own share as a result of a new methodology. 

The main uses of water that triggered a high degree of human intervention that led to water 
bodies  being  classified  as  heavily  modified  are:  (i)  flood  protection  (37%);  (ii)  agriculture 
(land  drainage  23%,  irrigation  15%);  (iii)  hydropower  (21%);  (iv)  drinking  water  supply 
(11%); and (v) other urban development (10%). 

Given  their  altered  features,  such  waterbodies  are  not  required  to  achieve  good  ecological 
status  but  only  good  ecological  potential  (GEP),  which  needs  to  be  defined  by  the  Member 
State following the requirements in WFD Annex V". 

It is encouraging to see that there have been methodological improvements to determine what 
would constitute GEP as required by the WFD. However, Member States continue to define 
GEP  differently  and  use  different  assumptions  and  criteria  in  their  assessments.  Moreover, 
some  Member  States  have  failed  to  define  the  GEP  for  all  HMWBs,  which  leaves  them 
without clear objectives to be reached. 

Based  on  information  available  in  WISE  for  the  16  Member  States55  that  had  managed  to 
report  electronically  by  the  time  this  report  was  finalised,  only  16.8%  of  the  HMWBs  and 
AWBs  have  reached  GEP.  However,  this  hides  considerable  differences  among  Member 
States  (with  the  proportion  of  relevant  waterbodies  meeting  GEP  ranging  from  none  in 
Belgium and the Netherlands to about half in Spain and Romania). 

6.2.2 Protected areas 

There  are  different  reasons  why  certain  water  bodies  are  protected  by  the  law.  For  surface 
water bodies, protected areas have been designated under the Drinking Water, Bathing Water, 
Habitats  and  Birds  and  Nitrates  Directives  as  well  as  for  the  protection  of  economically 
significant  aquatic  species  (i.e.  aquaculture).  In  this  reporting  cycle,  most  Member  States 
reported  a  higher  number  of  water  bodies  associated  with  protected  areas  designated  under 
other  EU  legislation  and,  as  required  by  the  WFD,  have  an  updated  register  of  protected 
areas in place. 

A  very  positive  development  is  that,  with  few  exceptions,  there  seems  to  be  better 
monitoring of these areas – probably linked to the general monitoring improvements under 
the WFD. 

Water bodies associated with protected areas may need to achieve more stringent or specific 
water management objectives, compared to the good status objectives set by the WFD. This is 
to  ensure  compliance  with  the  relevant  legislation  aiming  to  protect  specific  ecosystems, 
species, and drinking and bathing water. This may entail adopting additional measures. 

As  required  by  the  Nature  Directives,  Member  States  have  predominantly  set  up  specific 
objectives for habitats and species protected areas (Natura 2000 sites), although in some 
cases work is ongoing to determine the exact needs. In some cases, Member States have also 

55 As available by 31 May 2024. 

21 

 
 
 
set  additional  objectives  and  measures  for  sensitive  areas  under  the  UWWTD,  bathing 
waters  and  drinking water safeguard zones  although the objectives  or measures  are often 
reported  in  somewhat  general  terms56.  Some  Member  States  with  a  commercial  interest  in 
shellfish  production  (or  less  often  in  freshwater  fish)  have  designated  protected  areas  for 
economically  significant  aquatic  species57.  For  the  shellfish  areas,  some  Member  States 
(Croatia, the Netherlands and Romania) have set the same objectives that were in the Shellfish 
Directives, which have since been repealed58. One Member States  (France) applies different 
microbiological  standards  as  compared  to  the  repealed  directives  for  all  these  areas.  While 
Italy and Spain apply the same standards in some areas and different standards in other areas. 
For Poland, the information on standards is unclear. 

Where  additional  objectives  have  been  set,  they  have  been  predominantly  achieved  for 
drinking  water  safeguard  zones  shellfish  designated  areas  and  bathing  waters,  while  only  a 
small share of the objectives set for Natura 2000 sites have been achieved. 

Regrettably, in almost all Member States the designation of protected areas does not seem to 
bring  about  the  expected  improvements  in  the  overall  status  of  the  water  bodies.  On  the 
contrary,  as  illustrated  in  Figure  10  below,  data  show  an  increase  in  the  number  of  water 
bodies associated with protected areas in bad status compared to the previous cycle. This 
could  partly  be  linked  to  the  significant  reduction  in  the  number  of  areas  with  an  unknown 
status.  However,  it  also  confirms  limited  progress  in  implementing  the  Nature  Directives 
compared to the 2013-2018 period assessed in the 2020 ‘State of Nature’ report. This report 
revealed  that  only  17%  of  protected  river,  lake,  alluvial  and  riparian  habitats  were  in  good 
conservation status, and a large majority of protected fish and amphibian species were in poor 
or bad conservation status (80% and 60% of the population, respectively)59. This suggests that 
the  ‘protected  area’  designation  still  falls  short  of  ensuring  the  better  water  management 
needed to protect the surface and groundwaters in these areas. 

Figure 10 – Status of water bodies in protected areas based on second and third RBMP data 
(Source: Third RBMP electronic reporting) 

56 For habitats and species protected areas, some Member States reported measures, while others clearly referred 
to management plans under the relevant directives (Birds and Habitats). In some cases, for these protected areas, 
it is assumed that reaching WFD good status is sufficient to meet the additional objectives. 
57 These are Croatia, France, Italy, the Netherlands, Poland, Romania, and Spain for shellfish and Croatia, Italy 
and Latvia for freshwater fish. 
58 Former Directive 2006/44/EC of the European Parliament and of the Council on the quality of fresh waters 
needing  protection  or  improvement  in  order  to  support  fish  life,  and  Directive  2006/113/EC  of  the  European 
Parliament and of the Council of 12 December 2006  on the quality required of shellfish waters, whose validity 
ended  in  2013.  According  to  the  WFD,  the  level  of  protection  from  these  repealed  Directives  should  be 
maintained  through  the  inclusion  of  the  areas,  designated  under  the  previous  Fish  and  Shellfish  directives,  as 
protected areas under WFD. 
59  State  of  nature 
https://www.eea.europa.eu/publications/state-of-nature-in-the-eu-2020. 

the  EU  -  Results  from  reporting  under 

the  nature  directives  2013-2018; 

in 

22 

 
 
 
3rd Plan Ecological status/potential SWB

2nd Plan Ecological status/potential SWB

3rd Plan Chemical status SWB

2nd Plan Chemical status SWB

3rd Plan Quantitative status GWB

2nd Plan Quantitative status GWB

3rd Plan Chemical status GWB

2nd Plan Chemical status GWB

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

High

Good

Moderate

Poor

Bad

Unknown

6.2.3 What is being done to reduce hydro-morphological pressures and restore nature? 

Physical and hydrological alterations are reported as being a significant pressure in almost all 
river  basin  districts.  The  sectors  causing  this  significant  pressure  include  agriculture  (both 
irrigation and drainage), hydropower, flood protection, navigation, and drinking water supply. 

All  Member  States  have  reported  measures  that  aim  to  reduce  the  negative  environmental 
impacts  of  hydro-morphological  pressures  by  improving  flow  regime,  restoring  river 
continuity  and  ensuring  ecological  flows  are  respected.  This  includes  building  fish  passes, 
demolishing old and obsolete barriers, restoring rivers by improving riparian areas and flood 
plains and restoring riverbanks to their natural state. For instance, based on a recent report of 
Dam Removal Europe60 – a coalition of non-governmental organisations – 487 barriers were 
removed  in  15  European  countries  in  2023,  up  50%  from  2022’s  record  number.  France 
appears  to  be  the  trailblazer,  followed  by  Spain,  Sweden,  Denmark  and  Estonia.  These 
measures can contribute to 25 000 km of free-flowing rivers, the 2030 target set under the EU 
biodiversity  strategy and the recently adopted Nature Restoration Law61. Nevertheless, river 
fragmentation  and  degradation  of  protected  EU  aquatic  and  water-dependent  habitats  and 
species, particularly wetlands and floodplains, remain a major challenge. 

While not all the barriers in rivers are related to hydropower production, hydropower plants 
(HPPs)  continue  to  be  a  very  significant  pressure  on  ecological  status  in  several  Member 

60  New  Report:  Dam  Removal  Movement  Breaks  Barriers  and  Records  -  Dam  Removal  Europe.  Data  were 
provided  by  ministries,  municipalities,  water  agencies,  river  trusts,  NGOs,  scientists,  researchers  and  river 
restoration practitioners. 
61 OJ L, 2024/1991, 29.7.2024. 

23 

 
 
 
 
States  due  to  the  disruption  of  river  continuity  with  major  impacts  on  fish  migration,  fish 
mortality and changes in hydrological flows and sediments movement. Refurbishing existing 
HPPs,  including  through  win-win  solutions  that  can  contribute  to  achieving  the  WFD 
objectives, should generally be prioritised over new HPPs. Further efforts should be made to 
ensure that such plants’ operations are more sustainable and adapted to evolving hydrological 
conditions linked to accelerating climate change impacts. This includes the periodic review of 
permits, including mitigation measures to reduce impacts of HPPs operation. 

Only  a  few  Member  States  (Austria,  Belgium,  France,  Latvia,  Luxembourg,  Poland, 
Romania) report specifically prioritising nature-based solutions over other measures. 

Determining  and  implementing  minimum  ecological  flows  (e-flows)62  is  essential  for 
safeguarding the ecological status of surface water bodies. However, it is a source of strong 
concern  that  this  work  is  progressing  slowly  in  many  Member  States.  In  addition,  despite 
guidance at EU level, there is  a lack of consistency in how e-flows are defined. With a few 
exceptions, in most Member States the definition of e-flows is still being developed, and their 
actual  implementation  on  the  ground  is  progressing  slowly  and  often  only  for  some  water 
bodies.  The  respect  of  e-flows  only  seems  to  be  clearly  linked  to  granting  and  reviewing 
abstraction permits in some cases. 

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

It  is  important  to  differentiate  between  droughts  (a  lower  level  of  precipitation)  and  water 
scarcity (a more systemic unbalance between available water and demand). Water scarcity is 
perceived as a growing issue in most Member States, with over-abstractions reported as being 
responsible for failure to achieve good quantitative or ecological status of a significant portion 
of water bodies63. 

There are significant differences in water use across different regions in the EU. In 201964, 
at EU level, abstraction for cooling in electricity generation was the largest contributor to total 
annual  water abstraction (32%),  followed by  abstraction for  agriculture (28%), public water 
supply  (20%),  manufacturing  (13%)  and  cooling  in  manufacturing  (5%),  with  mining, 
quarrying  and  construction  accounting  for  only  1%  of  total  abstraction  each.  However, 
agriculture, including livestock farming activities, is the largest net consumer  65with 59% of 

62 For the purpose of the WFD, an ecological flow is ‘a hydrological regime consistent with the achievement of 
the environmental objectives in natural surface water bodies as mentioned in Article 4(1)’. In other words, it is 
the "amount of water required for the aquatic ecosystem to continue to thrive and provide the services we rely 
upon". 
63  Among  the  13  countries  for which  the  information  is  available  thanks  to  e-reporting,  water  abstractions  are 
reported  to  be  responsible  for  the  failure  to  achieve  good  quantitative  or  ecological  status  in  Spain  (25%), 
Hungary  (20%),  Italy  (19%),  France  (11%)  and  Belgium  (11%)  as  regards  groundwater  and  France  (17%), 
Austria (12%), Spain (11%), Italy (9%) and Croatia (8%) in relation to surface waters.  Although they failed to 
submit their reports, this is known to be also a significant issue in Cyprus, Greece and Malta. 
64 EEA’s analysis of water abstractions between 2000 and 2019, 
https://www.eea.europa.eu/en/analysis/indicators/water-abstraction-by-source-and. 
65  According  to  the  EEA  Report  12/2021  “Water  resources  across  Europe —    confronting  water  stress:  an 
updated assessment”, “water consumption” is the part of water used that is not returned to groundwater or surface 
water  because  it  is  incorporated  into  products  (e.g.  food  and  beverages)  or  consumed  by  households  (e.g. 
drinking water) or livestock.  

24 

 
 
 
EU  water  consumption  in  201966  as  most  water  abstracted  is  either  consumed  by  crops  and 
farm  animals  or  evaporates,  rather  than  being  returned  to  the  same  source  it  was  abstracted 
from.  Other  main  water  consuming  sectors  are  cooling  for  manufacturing  and  electricity 
generation  (17  %),  households  and  services  (13%)  and  mining,  quarrying,  construction  and 
manufacturing (11 %). EEA analysis shows that, between 2000 and 2019, there was a 17.6% 
reduction in water abstraction, reflecting policy measures implemented under the WFD. 

However,  while  abstraction  declined  in  some  sectors,  such  as  for  cooling  in  electricity 
generation  (-27%),  it  increased  in  others.  For  instance,  water  abstraction  for  cooling  in 
manufacturing almost tripled, and abstraction for public water supply increased by 4%, with a 
particularly sharp increase since 2010 (14%). Water abstraction for agriculture decreased by 
15% during the same 2000-2019 period, but has, since 2010 increased by 8%, mainly because 
of the increasing demand for irrigation in southern Europe where water scarcity is exacerbated 
by  climate  change.  There  is  therefore  an  increasingly  compelling  need  to  adopt  changes  in 
practices,  including  a  much  better  uptake  of  water  reuse  in  line  with  the  2020 Water  Reuse 
Regulation,  and  to  switch  to  crops  more  adapted  to  the  region-specific  hydrological 
conditions,  as  well  as  improved  soil  management. Without  such  changes,  water  demand  for 
agricultural irrigation will also significantly increase in regions where, to date, there is limited 
irrigation: this will only exacerbate water scarcity. 

The  CAP  2023-2027  is  supporting  efforts  to  increase  water  resilience  in  agriculture. 
Conditionality has been strengthened to include inter alia a new standard67 covering controls 
on abstraction. Inter alia the Member States’ CAP Strategic Plans provide significant support 
for  practices  to  improve  soil  health,  with  positive  effects  on  water  storage  capacity  with  a 
target to cover 47% of the EU’s agricultural area with such support. Investments in improving 
the efficiency of irrigation installations, the use of recycled water for irrigation and rainwater 
harvesting  can  also  be  supported.  However,  in  the  regions  most  affected  by  water  scarcity 
support  for  more  systemic  transformative  changes  towards  less  water  intensive  production 
systems will need to be envisaged. 

66  EEA  Report  7/2024,  Europe's  state  of  water  2024.  The  need 
for 
(https://www.eea.europa.eu/en/analysis/publications/europes-state-of-water-2024).  
67 Statutory management requirement 1 (SMR1) on controls on abstraction and impoundment and controls on 
diffuse pollution from phosphates (WFD articles 11(3)(e) and (h)). 

improved  water  resilience 

25 

 
 
 
 
 
 
 
 
 
 
Figure 11  –  Water abstraction by economic sector in  the 27 EU Member States, 2000-2019 
(EEA, 2022) 

Basic  and  supplementary  measures  to  reduce  abstraction  have  generally  been  set  out,  but 
their  implementation  is  inconsistent  across  Europe.  These  measures  focus  on  control  of 
abstractions,  water  efficiency  and  reuse,  natural  water  retention,  e-flows,  research  and 
knowledge  building.  There  have  been  some  notable  attempts  to  reduce  water  consumption, 
such as the new French Water Plan that has a target to reduce abstractions by 10% by 2030. 

As reported in 2021 by the European Court of Auditors (ECA)68, Member States have made 
progress  in  setting  up  prior  authorisation  systems  for  water  abstraction,  systems  for 
detecting  illegal  water  use  and  in  some  cases  pricing  mechanisms  with  the  potential  to 
incentivise  water  efficiency.  However,  the  fact  that  most  of  them  exempt  small  abstractions 
from  inspections  or  registration  is  problematic.  This  can  lead  to  the  cumulative  impact  of 
many, continued small abstractions over a whole river basin, negatively affecting the status of 
water  bodies,  particularly  in  Member  States  already  facing  water  scarcity  problems.  While 
noting that several Member States have introduced water pricing mechanisms that incentivise 
efficient  use  of  irrigation  water,  the  ECA  also  identified  as  problematic  the  practice  of 
significantly  lower  water  prices  in  agriculture  than  elsewhere  in  the  economy,  including 
derogations for irrigation. 

The  frequency  with  which  Member  States  review  abstraction  permits,  as  required  by  the 
WFD69, is very different, ranging from 6 years to several decades or even indefinite periods of 
time. This situation makes it sometimes impossible to properly factor in the evolving situation 
in  water  bodies,  including  from  a  climate  change  perspective. The  Commission  is  currently 

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

26 

 
 
 
 
involved  in  enforcing  the  obligation  to  review  such  permits  to  ensure  all  Member  States 
correctly implement it70. 

The issue of unauthorised / illegal water abstraction (i.e. abstraction either without a permit 
or  exceeding  permit  conditions)  is  only  explicitly  mentioned  in  some  RBMPs  from  four 
Member  States.  However,  the  problem  has  also  been  recognised  in  other  parts  of  Europe. 
Even where mentioned, these references usually lack a quantification of the current issue and 
trends  compared  to  the  second  RBMPs.  In  some  of  these  countries,  efforts  are  ongoing  to 
close illegal wells to prevent such unlawful appropriation of this common resource. 

As in the past, several Member States are tackling water scarcity by focusing their measures 
on increasing supply. These measures include drilling new wells, constructing new dams and 
reservoirs,  expanding  irrigation  infrastructure  for  agriculture  and  constructing  large-
scale  water  transfer  infrastructure  and  desalinisation  plants.  However,  very  limited 
information  is  provided  in  the  RBMPs  on  such  measures,  including  as  regards  their 
environmental and economic viability and the consideration of long-term climate scenarios. 

6.3 TACKLING THE CLIMATE CRISIS 
As outlined in the European Climate Risk Assessment71 and as recognized by the Commission 
in  its  Communication  on  managing  climate  risks72,  the  EU  and  its  Member  States  must 
become  significantly  better  at  preparing  for  and  effectively  addressing  climate  risks73.  The 
evidence  that  climate  change  is  already  having  a  substantial  impact  on  the  occurrence  and 
severity of water-related risks, such as droughts and floods, in much of Europe is mounting74. 
Boosting  water  resilience75  through  effective  implementation  of  the  WFD  and  the  FD  is 
therefore a pre-requisite to achieve the climate resilience objectives of the EU climate law76 

70 Letters of formal notice on this subject have been sent to Austria, Finland, the Netherlands and Slovenia,; for 
Ireland,  the  issue  is  dealt  with  in  the  context  of  the  long-standing  infringement  procedure  for  lack  of  correct 
transposition of several provisions of the WFD, including Article 11. 
71 EEA (2024), European climate risk assessment. No 1/2024, https://www.eea.europa.eu/publications/european-
climate-risk-assessment. Europe is the fastest-warming continent in the world. Extreme heat is becoming more 
frequent while precipitation patterns are changing. Downpours and other precipitation extremes are increasing in 
severity, and recent years have seen catastrophic floods in various regions. At the same time, southern Europe 
can expect considerable declines in overall rainfall and more severe droughts. 
72 Communication from the Commission to the European Parliament, The Council, The European Economic and 
Social Committee and the Committee of the Regions Managing climate risks - protecting people and prosperity, 
COM(2024) 91 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52024DC0091 
73 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions – Managing climate risks - protecting people and prosperity 
(COM(2024) 91 final), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52024DC0091. 
74 Temperatures in Europe have increased more than twice the global average over the past 30 years – the highest 
of  any  continent 
the  World  Meteorological  Organization, 
https://wmo.int/publication-series/state-of-climate-europe-2022  and  Climate  Change  2022:  Impacts,  Adaptation 
and Vulnerability, https://www.ipcc.ch/report/ar6/wg2/downloads/report/IPCC_AR6_WGII_FullReport.pdf. 
75 The need to strengthening resilience to climate change climate was stressed in the 2021 EU Strategy on 
Adaptation to Climate Change and in the 2021 European Climate Law. 
76 Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the 
framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 
(‘European Climate Law’). 

the  world,  November  2022  report, 

in 

27 

 
 
 
and the EU adaptation strategy77. At the same time, the objectives of the WFD and the FD can 
only be achieved by taking into full consideration the impacts of climate change. 

6.3.1 Have climate resilience and drought risk management been duly considered? 

Although the obligation to adapt the RBMPs to climate change is not explicitly stated in the 
WFD,  the  stepwise  and  cyclical  approach  of  the  WFD  planning  process  is  well  suited  to 
managing climate change impacts in an adaptive way. 

An increasing number of Member States reported a systemic consideration of climate change 
impacts  and  an  effort  to  align  their  programme  of  measures  with  their  national  climate 
adaptation plan. 70% of the assessed Member States (14 of 20) reported having completed 
an analysis of how climate change is affecting their water bodies. However, it is often unclear 
whether and to what extent the result of such analysis helped identify the key pressures and 
determine the most effective measures. 

In the third RBMPs, climate change effects were mostly linked to droughts and lower water 
availability, even if floods continued to remain a major concern. Most Member States framed 
these climate impacts  around their effects on  agriculture (irrigation risks), inland navigation 
and energy generation (hydropower, some thermal  power). This  is  a considerable difference 
from  the second RBMP, where excess  water (i.e. floods) was perceived as the main climate 
impact.  This  is  also  coherent  with  the  increased  concern  over  water  scarcity  across  most 
Member  States  outlined  in  section  6.2.4  above.  Importantly,  although  not  legally  required 
under  the  WFD,  16  of  the  20  assessed  Member  States  reported  droughts  as  a  significant 
occurrence; an increasing number of Member States reported that they had developed or were 
developing drought management plans at national, regional or RBD levels. 

Climate change is also having a growing impact on water quality in several Member States. 
An  increasing  number  of  Member  States  have  invoked  the  Article 4(6)  exemption  for 
temporarily failing to reach good ecological status due to prolonged droughts. 

Some  Member  States  have  recently  developed  national  water  strategies  (e.g.  France  and 
Germany) in response to the increased number of droughts. These are complementary to the 
RBMPs but have not been considered in the Member States’ reports. However, these national 
strategies can include major additional measures that should be implemented with the RBMPs 
in a cohesive manner. 

As  regards  the  impacts  of  climate  change  on  flood  risk  management,  the  findings  from  the 
assessment of the second FRMPs and the two steps78 before the FRMPs are encouraging. All 
Member  States  (compared  to  just  half  in  the  first  preliminary  flood  risk  assessments) 
considered  climate  change  in  their  second  preliminary  flood  risk  assessments  (PFRAs)  and 
nearly all considered it in their second flood hazard and risk maps (FHRMs) (also compared 
to just half previously), even though this is not explicitly required for maps in the FD. In the 
second FRMPs, all 21 assessed Member States provided evidence that climate change impacts 
were considered (compared to over a third previously). Nearly all Member States, compared 
to only half in the first cycle, discussed future climate scenarios in their FRMPs with varying 

77 COM(2021) 82 final - Communication from the Commission to the European Parliament, the Council, the 
European Economic and Social Committee and the Committee of the Regions “Forging a climate-resilient 
Europe - the new EU Strategy on Adaptation to Climate Change”. 
78 The preliminary flood risk assessments and the flood hazard and risk maps. 

28 

 
 
 
 
timeframes (between 2030 and 2115). Almost all Member States made the connection to their 
national adaptation strategies (compared to less than half for the first FRMPs). 

6.3.2 Progress towards climate resilience under the Floods Directive 
Floods  are  the  most  common  risk  in  Member  States’  National  Risk  Assessments79.  As 
indicated in the EUCRA, Europe is facing more and stronger climate hazards, including heavy 
precipitation leading pluvial and fluvial floods, and sea level rise leading to coastal floods.  

Notable  progress  in  flood  risk  management  has  been  achieved  throughout  the  EU  since  the 
introduction  of  the  2007  Floods  Directive.  FRMPs  are  the  main  tool  to  mitigate  potential 
adverse  consequences  of  flooding  and  are  the  third  of  the  cyclical,  three-step  approach 
introduced  by  the  FD. The  current  FRMPs,  which  are  the  second  set,  cover  2022-2027  just 
like the third RBMPs. The two steps before the FRMPs, namely the second PFRAs80 and the 
second  FHRMs  were  carried  out  by  the  Member  States  earlier.  Both  were  assessed  by  the 
Commission81. 

In terms of completeness, all 21 Member States that reported on time to be considered in this 
assessment provided contextual information in their FRMPs about their PFRAs and FHRMs 

Compared  to  the  previous  cycle,  flood  risk  management  has    improved  in  the  assessed 
Member  States. All  Member  States  have  set  flood  risk  management  objectives.  Some  set  a 
few  broad  objectives  supported  by  more  specific  sub-objectives,  and  others  presented  a 
number of more detailed objectives, compared to the past. All of them included measures to 
achieve their objectives. 

A  few  Member  States  have  set  targets  that  allow  for  quantitatively  assessing  progress 
compared to the previous cycle. However, several Member States make a clear link between 
the  measures  in  the  plans  and  the  objectives  these  measures  are  intended  to  achieve. When 
comparing the same Member States, 14 have this clear link in their plans compared to only 7 
in the previous plans. 

The  plans  include  progress  on  implementing  the  measures  rather  than  the  progress  towards 
targets  set  by  the  objectives  to  reducing  flood  risks.  It  is  thus  difficult  to  conclude  how 
effective flood risk management has been across the EU. 

The  number  of  measures  in  the  FRMPs  varies  significantly  across  Member  States,  ranging 
from below 100 to over 10 000 measures. This variation depends on the size of the country, 
the amount of areas of potential significant flood risk and the choice of individual or grouped 
measures. 

79 COM(2024) 130 final - Report from the Commission to the European Parliament and the Council on progress 
on  implementation  of  article  6  of  the  Union  Civil  Protection  Mechanism  (Decision  No  1313/2013/EU) 
Preventing and managing disaster risk in Europe. 
80 There are about 14 000 areas of potential significant flood risk (APSFRs) in the EU, for an overview see the 
flood risk areas viewer available at https://discomap.eea.europa.eu/floodsviewer/. 
81 For the Commission’s assessments of Member States’ second PFRAs, see the documents published under the 
Sixth Implementation Report. For the Commission’s assessments of Member States’ second FHRMs and second 
FRMPs, see the documents under the current Seventh Implementation Report, 
 https://environment.ec.europa.eu/topics/water/water-framework-directive/implementation-reports_en. 

29 

 
 
 
 
Figure 12 – Share of measure by type (prevention, protection, preparedness, recovery) 

There are two broad clusters of Member States: one consists of Member States that prioritise 
prevention and/or preparedness measures, and the other cluster of Member States prioritises 
protection . Although protection measures are still the most frequently reported in the second 
FRMPs, prevention and preparedness measures now account for a slightly larger share of the 
EU total. In terms of non-structural measures82, all assessed FRMPs refer to spatial planning. 
However,  references  to  legal  or  policy  frameworks  that  link  spatial  planning  and  flood  risk 
management  were  only  in  8  of  the  21  assessed  Member  States.  It  is  encouraging  that  all 
Member States include nature-based solutions in some or all their FRMPs; however, there is 
no evidence yet of a notable change on the ground in terms of large-scale uptake of nature-
based solutions instead of or combined with traditional infrastructure. Although the FD does 
not  mention  insurance,  12  of  the  21  Member  States  make  at  least  a  reference  to  it.  This 
confirms  the  valuable  role  that  insurance  as  a  risk  transfer  mechanism  could  play  in 
promoting  climate adaptation. 

A  positive  trend  is  how  Member  States  prioritise  flood  risk  management  measures.  All 
Member States prioritised measures or provided a timeframe for their implementation (not all 
did  so  in  their  first  FRMPs).  For  example,  the  analysis  indicates  that  most  measures  were 
classified  in  the  three  highest  priority  categories  (high,  very  high  and  critical),  i.e.  50%  or 
more  of  the  measures  in  13  Member  States  (out  of  the  21  analysed)  falls  in  one  of  these 
categories. In contrast, far fewer Member States reported significant shares of measures in the 
two lowest priority categories (medium and low). In the transition from the first to the second 
FRMPs, there has  been  a slight  downward shift  in  the urgency of measures across Member 
States, from critical to very high priority and from very high to high priority. There have also 
been some upward shifts in urgency, mainly from low and moderate priority to high priority. 
15 of the 21 Member States have made some cost-benefit analysis of their measures although 
few  have  used  it  to  prioritise  them.  Because  the  ratio  of  Member  States  using  cost-benefit 
analysis  is  more  or  less  the  same  as  in  the  previous  cycle,  progress  mainly  relates  to  the 
improved methodologies applied in some Member States. 

82  Measures  not  involving  civil  engineering  structures,  such  as  raising  awareness,  ensuring  early  warning 

systems, disaster prevention and response plans and spatial planning. 

30 

 
 
 
 
Indespensible elements  of flood risk management  are reliable  forecasting and early warning 
systems to promptly activate civil protection measures, along with a strong response capacity 
during and after such events. The Commission is supporting Member States through action in 
this field at EU level, including through the Copernicus’ European Flood Awareness System 
which  support  preparatory  measures  before  and  during  major  flood  events  strike83. 
Copernicus’  rapid  mapping  service  provides  on-demand  and  fast  provision  (within  hours  or 
days) of geospatial information, supporting emergency management activities before, during 
and immediately after a disaster. Once disaster strikes, Member States can call on the Union 
Civil  Protection  Mechanism,  which  has  substantially  strengthened  cooperation  between 
countries  on  civil  protection  and  improved  prevention,  preparedness  and  response  to 
disasters84,  for  instance,  by  developing  disaster  resilience  goals85.  The  Commission  is 
encouraging the uptake  of Copernicus’ emergency management  services,  and promoting the 
sharing  of  lessons  learnt  and  best  practices  among  Member  States,  especially  after  major 
flood events. 

7. ENSURING SOCIO-ECONOMIC SOUNDNESS 

Given  the  limited  progress  in  reaching  good  status,  a  large  majority  of  water  bodies  are 
covered by various exemptions set out in Article 4 of the WFD86. It must be mentioned that 
the  number  of  exemptions  related  to Articles  4(4)  and  4(5)  of  the WFD  has  increased.  The 
justifications  for  such  exemptions  have  generally  improved  in  terms  of  meeting  the  WFD 
requirements  to  be  based  on  appropriate,  evident  and  transparent  criteria.  However,  not  all 
Member  States  provide  sufficiently  detailed  information  at  the  level  of  the  affected  water 
body  and  only  about  half  of  the  assessed  Member  States  provide  sufficient  details  in  all 
RBMPs. 

In  line  with Articles  9  and  11  of  the  WFD  and  its Annex  III87,  updating  and  reporting  the 
water economic analysis and the related use of cost recovery instruments, including water 
pricing,  are  becoming  a  more  established  practice  in  RBMPs.  Nevertheless,  the  reporting 
often does not make clear links to key challenges and developments in the river basin district. 
Therefore, it is unclear how the economic analysis has informed the choices on cost recovery, 
pricing  and  more  generally  the  design  of  the  PoMs.  For  instance,  the  reporting  on  water 

83 EFAS is the first operational European system monitoring and forecasting floods across Europe. It supports 
preparatory  measures  before  and  during  major  flood  events  strike.  It  provides  complementary,  added-value 
information  to  the  relevant  national  and  regional  authorities.  EFAS  also  keeps  the  Emergency  Response 
Coordination  Centre  informed  about  ongoing  and  possibly  upcoming  flood  events  across  Europe.  Recently 
EFAS v5.0 introduced several major changes to the system, including a higher spatial resolution.  
84  Report  to  the  European  Parliament  and  the  Council  on  progress  on  implementing  Article 6  (UCPM) 
Preventing and managing disaster risk in Europe 12.3.2024 COM(2024)130 & SWD(2024)130. 
85https://civil-protection-humanitarian-aid.ec.europa.eu/document/download/7b124199-d4d7-43fe-b852-
8cee69674d19_en 
86 Article 4(4) allows for an extension of the deadline for achieving good status or potential beyond 2015 (as set 
by  Article 4(1)).  Article 4(5)  allows  for  the  achievement  of  less  stringent  objectives.  Article 4(6)  allows  for  a 
temporary deterioration in the status of water bodies. Article 4(7) sets out conditions in which deterioration of 
status  or  failure  to  achieve  the  WFD  objectives  may  be  permitted  for  new  modifications  to  the  physical 
characteristics  of  surface  water  bodies,  alterations  to  the  level  of  groundwater  and  deterioration  from  high  to 
good status as a result of new sustainable human development activities. 
87 Annex III to the WFD stipulates that the economic analysis should contain enough information in sufficient 
detail  to  describe  and  justify  the  cost  recovery  arrangements  for  water  services  and  related  obligations 
(Article 9). The analysis should also be able to  help  judge the most cost-effective  combination of measures in 
respect of water uses to be included in the programme of measures, PoMs (Article 11). 

31 

 
 
 
services  does  not  provide  much  detail.  Many  of  the  RBMPs  typically  report  on  the  two 
broadly  defined  water  services,  namely  drinking  water  supply  and  sanitation  services; 
therefore, they tend not to recognise and discuss the individual water services that fall under 
or  are  directly  linked  to  these  categories,  such  as  water  storage  and  reuse.  This  makes  it 
difficult to have a sufficiently complete understanding of water uses in the country, including 
their  economic  significance  and  potential  for  cost  recovery,  and  the  pressures  they  put  on 
water bodies. 

In  addition,  compared  to  the  elements  required  under  Article 9  of  the  WFD,  some  major 
implementation gaps remain, in particular those listed below. 

•  The assessment of whether existing pricing policies provide ‘adequate incentives’ for 

more efficient water use. 

•  The  assessment  of  environmental  and  resource  costs  and  their  inclusion  in  the  cost 

recovery arrangements. 

•  The  assessment  of  whether  water  uses  and  the  key  water-user  sectors  (including 
agriculture, industry and households) provide an ‘adequate contribution’ to the costs of 
providing  water  services  in  line  with  the  polluter-pays  principle.  The  reported  data 
often lack details on the environmental and resource costs as well as on the water uses 
that  exert  the  most  significant  cost  pressures  on  the  main  water  services  (i.e.  water 
supply and sanitation). 

More  investments  are  essential  to  meet  the  WFD  objectives  and  make  EU  societies  more 
water resilient. For Member States that submitted reports electronically, some information on 
the  funding  needs  for  the  WFD  is  available  and  shows  that  an  increase  in  funding  to 
implement  their  measures  is  often  required.  This  would  include  an  additional  EU  financial 
contribution. However, the information is either incomplete, contradictory or even missing for 
some of the electronic reports (i.e. Estonia, Latvia and the Netherlands). For the 10 Member 
States  for  which  information  is  available,  the  cumulative  funding  needs  between  2022  and 
2027 is  calculated to  be EUR 89.4 billion (approximately EUR 15 billion a year) but,  given 
data limitations, this is likely to be an underestimation. 

As regards the funding needs for implementing the FRMPs, 16 Member States (compared to 
10  in  the  first  FRMPs)  provided  some  information  on  the  estimated  cost  of  measures. This 
comes  to  roughly  EUR 35  billion  between  2022  and  2027  (approximately  EUR 6  billion  a 
year)  although  this  is  likely  to  be  an  underestimation.  The  information  provided  varied 
significantly  in  scope  and  detail  and  often  did  not  cover  all  measures  even  within  a  given 
Member State. 

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

32 

 
 
 
 
 
 
 
Nevertheless, analysis shows – for the EU as a whole – there is a failure to meet the annual 
investment  needs,  which  are  estimated  to  be  EUR 77  billion  a  year,  with  a  financing  gap 
currently estimated at around EUR 25 billion a year88. This amount is largely based on water 
supply and sanitation needs, while costs for other measures related to the implementation of 
the  WFD  and  the  FD  may  not  be  fully  reflected.  Regrettably,  for  most  Member  States,  the 
RBMPs do not contain a clear investment schedule that considers long-term water supply and 
demand  forecasts  based  on  the  latest  climate  scenarios  and  adaptation  strategies.  More 
generally,  the  reported  economic  analyses  do  not  clearly  show  how  cost-effectiveness 
assessments  have  informed  the  selection  of  measures  in  the  PoMs  (which  should  ideally 
include many more investment measures). Further progress in the economic underpinning of 
the PoMs would greatly facilitate water-related decisions and investments. 

8. TRANSBOUNDARY COOPERATION UNDER THE WFD AND THE FD 

For  river  basins  crossing  national  borders,  the  WFD  requires  Member  States  to  coordinate 
among  each  other  and  also  make  reasonable  efforts  with  non-EU  countries  where  relevant. 
The analysis shows that, while the degree of cooperation differs, there is a stable institutional 
framework in place for transboundary coordination mechanisms across different international 
river basin districts (iRBDs)89. There are a few examples of existing arrangements that were 
further ‘upgraded’, compared to the previous cycle. 

International RBMPs (iRBMPs) have been developed for  the largest iRBDs and provide the 
framework  for  cooperation  among  Member  States.  Such  frameworks  focus  on  data  sharing, 
joint  monitoring  and  research  projects,  joint  coordination  on  assessing  the  status,  relevant 
priority indicators and agreed threshold values. This cooperation on indicators and threshold 
values,  however,  does  not  imply  full  convergence  on  the  assessment  results  among  the 
different countries that share the river basins. 

Except  for  the  Danube  iRBMP  that  sets  out  measures  of  international  relevance,  the  other 
iRBMPs  essentially  compile  the  national  measures  drawn  up  by  each  Member  State; 
therefore,  it  is  unclear  to  what  extent  consistency  is  ensured  between  measures  taken  by 
upstream  and  downstream  countries.  For  instance,  fish  passes  have  been  installed  in  the 
upstream  parts  of  the  Rhine,  but  similar  measures  have  not  yet  been  fully  implemented 
downstream, which hampers the effectiveness of the upstream measures. Similarly, in the case 
of nutrient load reduction, there is a general lack of consideration of the upstream contribution 
needed to achieve the good status objectives for downstream waterbodies, particularly for the 
coastal and transitional waters that are most sensitive to nutrients. 

It  is  noted  with  concern  that  transboundary  cooperation  on  groundwaters  is  very  limited. 
Many  iRBDs  have  not  identified  cross-border  groundwaters;  therefore,  the  delineation  and 
characterisation  of  groundwater  bodies  are  performed  by  each  country  individually.  Where 
transboundary  aquifers  are  identified  (e.g.  the  Scheldt,  Vistula,  Elbe  and  Danube),  the 
characterisation is left to bilateral discussions. There is also limited cooperation on monitoring 
the qualitative and quantitative indicators for assessing the status of groundwaters. 

88 DG Environment, Environmental investment needs, financing and gaps in the EU-27 – update 2024 (internal 
analysis). Note that the next Environmental Implementation Report planned for spring 2025 will include further 
public information and updates on the topic. 
89 International agreements are in place for most iRDBs  and  often establish an international coordinating body 
and, less frequently, a joint RBMP. Only a few basins in the EU have neither of these. 

33 

 
 
 
With drought  and  water scarcity challenges becoming increasingly more pressing across the 
EU,  quantitative  aspects  of  water  management  are  likely  to  become  more  important  in  the 
context of iRBDs. With some exceptions, such as the Albufeira Convention between Portugal 
and Spain, cooperation in the iRBDs on tackling water scarcity and drought is so far limited 
and should be further encouraged. 

The WFD Article 12 procedure for issues that cannot be dealt with at Member State level 
has  been  invoked  once  since  the  previous  report.  In  2019,  Czechia  raised  concerns  about 
depleting  groundwater  levels  as  a  result  of  the  cross-border  impacts  of  the  Turow  mine  in 
Poland. The procedure was stopped in February 2022 following an agreement between Poland 
and Czechia in the context of a case brought before the Court of Justice (which had suspended 
the procedure under Article 12 itself). 

Although not directly linked to the activation of Article 12, the Oder River disaster, one of the 
largest ecological disasters in Europe in recent memory, which led to a massive fish die-off in 
July and August 2022, demonstrated the consequences of inadequate communication between 
neighbouring  countries  and  between  these  and  the  European  Commission.  The  incident 
underlined  the  importance  of  effective  transboundary  cooperation  to  ensure  a  timely  and 
adequate response to such disasters. The Commission provided support and expertise from the 
outset and produced, in cooperation with the EEA, a report that analysed the disaster’s causes 
and set out key recommendations to prevent future ecological disasters in EU rivers90. 

The Floods Directive, like the WFD, requires Member States to coordinate their efforts within 
transboundary river basins, including with non-EU countries. Where basin-wide coordination 
organisations are in place, the development of an international FRMP invariably led to setting 
out  common,  high  level  objectives  and,  in  almost  all  cases,  drawing  up  a  number  of 
coordinated  and  common  measures91.  Within  those  river  basin  organisations,  dedicated 
working  groups  follow  implementation  of  international  FRMPs  at  national  level.  Extensive 
public consultations on some of the basins, such as the Danube and the Rhine, took place. In 
addition, the existence of climate change adaptation strategies at basin level with direct links 
to the FD is significant in these efforts92. 

9. CONCLUSIONS AND OUTLOOK 

Overall,  the  assessment  shows  that  knowledge  and  monitoring  of  EU  water  bodies  have 
significantly improved compared to the previous cycle. Unfortunately,  the state of EU water 
bodies has failed to significantly improve when looking at the aggregated figures. There are 
clearly  positive  reductions  in  certain  pressures  where  Member  States  have  increased  their 
water  expenditure  or  made  significant  progress  in  implementing  other  relevant  legislation93. 
For  groundwaters  bodies,  a  large  majority  has  good  quantitative  and  chemical  status  with  a 
positive trend since the last reporting cycle.  

In  contrast,  surface  waters  are  in  a  highly  critical  situation.  Less  than  a half  (39.5%)  of  the 
assessed EU surface water bodies is in good ecological status, and less than a third (26.8%) in 

90 https://publications.jrc.ec.europa.eu/repository/handle/JRC132271 
91 Such as sharing hydrological data, exchanging national practices on pluvial floods and conducting studies on 
improving  flood  forecasting  across  the  basin,  as  opposed  to,  for  example,  flood-protection  building 
embankments. 
92 The strategy for the Rhine dates back to 2015 and the strategy for the Danube back to 2018. 
93 This concerns in particular the Urban Wastewater Treatment, Nitrates, and Industrial Emissions Directives and 
EU law on chemicals. 

34 

 
 
 
good chemical status. The reasons for this are manifold. For chemicals, some positive trends 
are  masked  by  historic,  widespread  contamination  of  mercury  and  other  ubiquitous, 
bioaccumulative  and  toxic  pollutants  or  were  overshadowed  by  new  emerging  pollution 
challenges. For the ecological status, there has been some improvement in certain biological 
quality elements. However, EU rivers, lakes and coastal waters are still subject to significant 
pressures  and,  even  when  effective  measures  are  taken,  progress  may  not  be  swiftly  visible 
when  monitoring  as  nature  needs  sufficient  time  to  recover.  It  is  encouraging  to  see  a 
reduction in  water bodies  with  an ‘unknown status’, but  there are new  challenges related to 
data comparability, which hinders objective assessments. All this requires reflections on how 
to improve data quality and comparability. 

Despite these data issues, much remains to be done to fully achieve the objectives of the WFD 
and related directives. The onus is primarily on Member States, who need to raise the level of 
ambition and accelerate action. 

It  is  already  clear  from  Member  States’  forecasts  that  full  compliance  with  the  WFD’s 
objectives by 2027 will not be achieved with the programme of measures set out in the third 
RBMPs. 

As  possibilities  for  exemptions  are  limited,  tackling  the  significant  funding  gaps  and  better 
integrating  water  in  other  relevant  policies  will  be  particularly  crucial.  Several  measures 
agreed  under  the  European  Green  Deal  (e.g.  the  revised  Industrial  Emissions  and  Urban 
Wastewater  Treatment  Directives)  can  help  make  swift  progress  if  implemented  early.  It  is 
worrying to note that several Member States have already indicated that they intend to make 
extensive  use  of  exemptions  in  2027,  either  by  applying  less  stringent  environmental 
objectives  or  extending  the  deadline.  The  Commission  will  also  continue  to  engage 
proactively with the co-legislators to strengthen measures to tackle water pollution, including 
by  paying  increased  attention  to  new  emerging  pollutants,  e.g.  PFAS,  microplastics  and 
pharmaceuticals. 

For the Floods Directive, Member States have built  on their experience  from  the  first  cycle 
and  made  incremental  changes  to  their  approaches  to  flood  risk  management.  Three 
developments stand out: (a) a significant increase at EU level in the number of areas identified 
as having a potentially significant flood risk; (b) the adoption, by nearly all Member States, of 
GIS-based internet  viewers to  publish their flood hazard and risk maps,  making them much 
more  accessible;  and  (c)  an  improvement  in  the  way  climate  change  is  considered,  e.g. 
through  modelling  and  scenarios.  To  continue  progress  in  reducing  the  potential  adverse 
effects  of  major  flooding,  Member  States  will  need  to  make  sustained  efforts  to  improve 
planning capacity, particularly in terms of better monitoring progress to reach their objectives 
to reduce flood risks. They also need to plan and implement measures which will help to deal 
with  future  climatic  conditions,  among  others  by  increasing  (or  restoring)  the  natural  water 
retention,  among  others  by restoring  and reconnecting flood plains, as  well as ensuring that 
flood  prevention  measures  are  dimensioned  on  future  flood  conditions.  They  also  need  to 
ensure adequate resources to effectively implement the FRMPs. 

In  this  report  and  its  accompanying  staff  working  documents,  the  Commission  issues  some 
general  and  country-specific  recommendations  on  how  Member  States  can  make  further 
progress  in  better  implementing  both  the WFD  and  the  FD,  thereby  helping  boost  the  EU’s 
water resilience. 

35 

 
 
These recommendations  will be the basis for a structured dialogue with  Member States that 
the  Commission  will  swiftly 
launch.  These  dialogues  will  enable  securing  better 
implementation  and,  where  appropriate,  better  enforcement  of  the  requirements  under  the 
WFD and the FD in  close coordination with  the enforcement  efforts  covering key pressures 
on the aquatic environment. 

Along  with  continuing  to  work  with  Member  States,  the  Commission  will  work  with  the 
public  and  all  stakeholders  to  promote  compliance.  This  will  also  be  reflected  in  the  next 
Environmental Implementation Review in 2025. 

The Commission, in consultation with Member States and the EEA, will collect lessons learnt 
from  this  reporting  exercise  and  identify  opportunities  to  simplify  and  reduce  the 
administrative burden and improve data management, in particular data comparability, while 
improving the electronic reporting platform’s efficiency. 

Finally,  the  Commission  will  continue  to  support  Member  States  in  their  implementation 
efforts by facilitating the use of available and future funding, strengthening the availability of 
relevant data, information and knowledge as well as the exchange of good practices as part of 
the Common Implementation Strategy. 

The  findings  of  this  assessment  will  also  feed  in  the  preparation  of  the  announced  Water 
Resilience Strategy. 

10. RECOMMENDATIONS 

Although  country-specific  recommendations  are  provided 
assessments, the recommendations set out below are relevant for all EU Member States. 

individual  country 

the 

in 

WATER FRAMEWORK DIRECTIVE 

1.  All Member States should increase their level of ambition and accelerate action to 

reduce the compliance gap as much as possible by 2027. This implies: 

a.  developing  more  robust  programmes  of  measures  based  on  a  clearer 
assessment  of  the  gap  to  be  bridged  to  reach  good  status  and  a  clearer 
prioritisation of measures; 

b.  decisively  tackling  structural  obstacles  identified  when  implementing 

measures, such as insufficient administrative capacity and resources; 

c.  strengthening  governance  by 

improving  public  consultations  and 
coordination  between  the  different  administrative  levels  and  authorities 
dealing with  implementation of other relevant  EU legislation, particularly  the 
Floods, the Marine Strategy Framework and the Nitrates Directives; 

d.  ensuring  full  compliance  with  WFD  provisions  on  the  periodic  review  of 
impacting  water  bodies  (including 
permits/controls  for  all  activities 
abstraction, 
impoundment,  discharges)  and  effective,  dissuasive,  and 
proportionate  sanction  regimes;  consider,  where  applicable,  revisions  to 
existing  exemptions  of  small  abstractions  from  registration  and  permitting 
requirements, so cumulative impacts are managed better. 

2.  All  Member  States  should  increase  investment  and  ensure  adequate  financing  to 
effectively implement the PoMs to reach the objectives. This involves in particular: 

a.  developing long-term investment plans and clearly identifying the source of 
financing for each measure, including the effective use of EU funding provided 

36 

 
 
 
through the Common Agricultural Policy, the Cohesion Policy 2021-2027 and 
the Recovery and Resilience Facility; 

b.  strengthening  efforts  to  fully  apply  the  cost  recovery  principle  for  water 
services so that all key water-users and water use sectors provide an adequate 
contribution to the water services costs; 

c.  making  better  and  wider  use  of  the  ‘polluter-pays  principle’,  eliminating 
harmful  environmental  subsidies  and  ensuring  affordable,  just  and  fair 
pricing mechanisms for all water users in line with Article 9 of the WFD. 

3.  All  Member  States  should  put  in  place  additional  measures  to  reduce  existing 
persistent environmental challenges (pressures) based on robust gap analyses.  
 This includes: 

a.  stepping  up  action  to  reduce  nutrient  pollution,  including  by  setting  and 
achieving maximum nutrient loads in all river basin districts, in line not only 
with the WFD but also the MSFD and Nitrates Directive; 

b.  Strengthening  measures  against  pesticide  pollution  by  reducing  the  use  of 
chemical  pesticides,  promoting  integrated  pest  management  and  more 
sustainable practices (e.g. precision farming), setting and achieving maximum 
chemical  pesticide  loads  in  all  river  basin  districts  and  introducing  more 
stringent restrictions in protected areas for drinking water abstraction; 

c.  further reducing point source pollution to tackle nutrients, priority substances 
and  river  specific  pollutants,  e.g.  by  reviewing  existing  permits  for  point 
source  emissions  to  lower  pollutant  loads  or  introducing  obligations  to 
temporarily  suspend  or  limit  discharges  in  emergencies,  considering  the  new 
obligations under the revised IED and UWWTD; 

d.  boosting  efforts  on  nature-based  solutions,  including  re-naturalisation  and 

ecosystem restoration to reduce hydro-morphological pressures; 

e.  stepping  up  efforts  to  improve  river  continuity,  the  general  hydrological 

situation and aquatic species protection, including for migratory species; 

f.  setting out ecological flows (i.e. the level of water that must be left in the 
water  body  for  the  ecosystem  to  properly  function)  for  all  RBDs  and 
effectively  applying  them  in  water-allocation  decisions  and  issuing  or 
periodically reviewing permits for abstractions and impoundments in line with 
Article 11 of the WFD. 

g.  more  systematically  including  the  water  needs  of  groundwater-dependent 
ecosystems (both terrestrial and aquatic) when assessing the quantitative status 
of groundwater bodies. 

4.  In light of water scarcities experienced across the EU, Member States should: 

a.  improve climate-proofing measures in the PoMs and, where relevant, develop 

suitable measures or plans for strengthened resilience; 

b.  proactively  draw  up  or  improve,  regularly  update  and  monitor  accurate 
water balances for all river basins, taking into account all water inputs and 
abstractions, natural losses and the needs of water-dependent ecosystems; this 
includes  increasing  direct  monitoring  and  metering  across  water  uses, 
continuously updating water abstraction registers and inspecting unauthorised 
and illegal water abstractions; 

c.  take  effective  measures  to  promote  water  reuse,  efficiency  and  circularity, 
while  maximising  the  use  of  nature-based  solutions  for  more  sustainable 
water storage across soils and ecosystems; 

37 

 
 
 
 
d.  when planning new dams and reservoirs, carefully assess their environmental 
impacts, including against the WFD objectives and ensure that such actions are 
part  of  integrated  water  management  and  of  coherent  water  resilience 
strategies, which include duly considering long-term climate scenarios. 

5.  To  achieve  the  WFD  objectives  and  strengthen  water  resilience,  Member  States 

should further improve transboundary cooperation, in particular on: 

a.  the  delineation  and  characterisation  of  water  bodies,  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. 

6.  If  the  WFD  objectives  cannot  be  met  for  a  specific  water  body  and  exemptions  are 
invoked,  Member  States  should  do  so  in  line  with  the  restrictive  interpretation 
stemming  from  case  law  of  the  Court  of  Justice of  the  European  Union  and  provide 
sufficiently  detailed  justifications,  ensuring  that  their  application  is  regularly 
reviewed. This implies: 

a.  ensuring  that  lowering  objectives  (-  Article 4(5)-  of  the  WFD))  -  is  well 
documented and justified, in particular as regards disproportionate costs and 
unfeasibility  and considering the implementation shortcomings to  date, rather 
than applying for the exemption  as a default option for the failure to  achieve 
the objectives by 2027; 

b.  recognising  that  the  possibilities  for  time  extensions  (Article 4(4)  of  the 

WFD- are extremely limited; 

c.  providing much better information on the exemptions for new projects under 
Article 4(7); this includes better justifications for the use of these exemptions 
by  detailing  cumulative  effects,  assessing  alternative,  more  environmentally 
friendly  options,  and  giving  information  on  the  measures  taken  to  mitigate 
possible adverse effects. 

7.  On  monitoring,  assessment,  data  management  and  reporting,  Member  States 

should: 

a.  ensure,  in  cooperation  with  the  Commission  and  the  EEA,  timely  and  more 
complete  electronic  reporting  for  future  cycles,  making  better  use  of  the 
opportunities stemming from digitalisation and earth observation to reduce the 
administrative burden and improve accuracy; 

b.  further  improve  data  quality  and  comparability  by  harmonising  data 
collection  methods  across  all  RBDs  on  monitoring,  assessments,  projections, 
etc.  and  make  all  data  publicly  available  via  their  timely  publication  in  line 
with  the  requirements  of  the  INSPIRE,  Open  Data  and  Public  Sector 
Information (PSI) Directives and the public sector High Value Datasets94 thus 
reducing the reporting burden; 

c.  further  strengthen  monitoring  systems  to  close  gaps  in  both  geographic 
coverage  and  the  parameters  analysed  in  order  to  increase  confidence  in  the 
status  assessments,  reduce  reliance  on  expert  judgement  or  the  grouping  of 

94 (Commission Implementing Regulation (EU) 2023/138) laying down a list of specific high-value datasets and 
the arrangements for their publication and re-use. 

38 

 
 
 
 
 
 
different  water  bodies,  and  complete  the  work  on  setting  up  reference 
conditions for all water types; 

d.  develop  methodologies  for  a  more  harmonised  definition  of  good  ecological 

potential to rapidly improve the status of HMWBs and AWBs. 

8.  Proactively use the new policies and legal instruments agreed in the context of the 
European  Green  Deal  to  step  up  implementation  efforts  that  benefit  the  WFD, 
focusing  on  the  co-benefits  arising  from,  amongst  others,  the  revised  Urban 
Wastewater Treatment Directive, the Industrial Emissions Directive and the new 
Nature Restoration Law. 

FLOODS DIRECTIVE 

1.  Member  States  should  continue  improving  their  flood  hazard  and  risk  maps 

(FHRMs), in particular by: 

a.  consistently  and  clearly  considering  water  abstraction  areas,  recreational 

waters and Natura 2000 areas; 

b.  Taking pluvial flooding into account more, given the increased frequency and 

intensity of heavy precipitation; 

c.  improving the GIS-based FHRM viewers that integrate all relevant information 

and are easy for the general public to use. 

2.  Member States  should continue making  further efforts to improve their flood risk 

management planning, in particular: 

a.  future FRMPs should provide details on how the FHRMs informed the choice 

of objectives and measures; 

b.  the  FRMP’s  objectives  should  be  specific,  have  a  deadline  where  possible 

and be linked to quantitative progress indicators; 

c.  the  FRMPs  should  contain  an  assessment  of  the  progress  made  towards 

achieving the objectives set in the previous FRMP. 

3.  To  improve  the  effectiveness  of  the  measures  taken,  Member  States  should  ensure 
that  there  is  a  clear  link  between  the  FRMP’s  objectives  and  its  measures  and 
provide information on the methods used to prioritise measures. Where possible, a 
cost-benefit  analysis  of  measures  should  be  carried  out  and  factored  into  their 
prioritisation.  In  addition,  the  FRMP  should  provide  information  on  the total  cost  of 
the planned measures. 

4.  The  FRMP  should  set  out  the  methods  to  monitor  progress  in  concretely 

implementing the measures. 

5.  All Member States should consider future climate scenarios in their FRMPs. 

6.  All Member States should increase efforts to implement Nature-based Solutions more 

widely, either in isolation or in combination with traditional infrastructure. 

7.  Next  to  investments  for  flood  prevention  and  protection,  all  Member  States  should 
consider the cost of flood events on public budgets; insurance should be considered as 
an option for adaptation to the impacts of climate change. 

39 

 
 
 
 
 
 
 
 
 
 
8.  Provisions  for  the  protection  of  cultural  heritage  from  flooding  risks  should 

systematically be integrated into the FRMP. 

9.  On  governance,  all  Member  States  should  clearly  set  out  in  their  FRMPs  how 
coordination with the WFD will happen and provide details on the public consultation 
and  stakeholder  involvement,  including  on  how  possible  comments  were  taken  into 
account. Consultations should be aimed to last 6 months. 

40