COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL NextGenerationEU - The road to 2026
Date: 2025-06-04
Institutions: European Commission, Reform and Investment Task Force
Subjects: EU aid, EU financial instrument, EU investment, EU strategy, competitiveness, economic independence, economic recovery, green economy, redevelopment aid

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.6.2025  COM(2025) 310 final/2  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL NextGenerationEU - The road to 2026  
 
 
NextGenerationEU – The road to 2026 

With one and a half years left to bring the Recovery and Resilience Facility (RRF) to a 
successful  conclusion,  this  Communication  takes  stock  of  the  implementation  of  this 
unique temporary instrument and looks ahead towards its closure end-2026.  

The Communication first summarises the key results achieved by the RRF and takes stock 
of the overall implementation so far. It then recalls the applicable legal framework and the 
relevant deadlines, together with their operational implications as regards the submission 
of payment requests, the provision of evidence, the payment suspension procedure and the 
revision of recovery and resilience plans (RRPs). To maximise results in the face of delays 
and the approaching end of the Facility, guidance to Member States is then provided on 
how to further streamline their RRPs, which options to consider when revising them, and 
how to plan ahead for the submission of the last payment requests in 2026.  

1.  THE RRF IS SHOWING TANGIBLE RESULTS ON THE GROUND 

1.1.  A swift reaction to the pandemic leading to long-lasting growth effects  

The Recovery and Resilience Facility has been a game-changer in Europe's response 
to  the  impacts  of  the  COVID-19  pandemic.  Its  announcement  in  2020,  as  the  core 
element  of  NextGenerationEU  (NGEU),  showcased  the  Union’s  commitment  to  a 
comprehensive and  forward-looking  action to  quickly and sustainably  recover  from the 
dramatic impacts of the pandemic. The first effects were immediate: markets and investors 
responded  positively,  sovereign  bond  spreads  narrowed,  and  financial  stability  was 
reinforced,  thus  stabilising  economic  and  social  conditions  for  EU  citizens  and 
businesses (1). 

The RRF’s support has fuelled Europe’s recovery. The RRF’s pre-financing (2) quickly 
provided financial support to Member States. In contrast to previous crises, which led to a 
sharp contraction of public investment in the EU, public investment was maintained in the 
aftermath of the COVID-19 crisis. It is expected to rise to 3.8% of GDP in 2025 before 
stabilising in 2026, up from 3.2% in 2019 (3). A significant part of this increase is related 
to investments financed by the RRF and other EU funds. The impact on GDP growth is 
expected to be long-lasting. Model simulations suggest that NGEU investments alone, that 
is without considering the impact of reforms, could increase EU GDP by 1.4% in 2026 (4). 

Combining reforms and investments under one comprehensive plan has been one of 
the most effective features of the RRF. Reforms, often frontloaded in the RRPs, have 
improved  framework  conditions  in  the  Member  States  and  paved  the  way  for  related 
investments to be more effective. Moreover, the RRF has fostered the implementation of 
the  country-specific 
structural  reforms 
recommendations  (CSRs)  in  the  context  of  the  European  Semester.  Overall,  the 

long  been  advocated  for 

that  had 

in 

(1)  Mid-term evaluation of the Recovery and Resilience Facility (RRF), 2024; Insights from the Recovery 

and Resilience Facility: The Business Perspective - European Commission 

(2)  Close to EUR 57 billion were disbursed in pre-financing between August 2021 and January 2022. This 

helped alleviate the short-term impact of the crisis on Member States budgets 

(3)  Spring 2025 Economic Forecast: European Economic Forecast. Spring 2025 

(4)   Mid-term evaluation of the Recovery and Resilience Facility (RRF), 2024 

 
 
 
implementation  of CSRs has accelerated,  with  Member States  addressing long-standing 
challenges, reflecting also common EU priorities (5). 

The  RRF  is  being  financed  by  joint  EU  borrowing  at  an  unprecedented  scale.  EU 
issuances  benefit  from  a  very  high  credit  rating,  which  also  allows  Member  States  to 
receive  RRF  loans  at  favourable  conditions  in  terms  of  both  interest  rates  and  long 
duration. EU borrowing is guaranteed by the EU budget, is appreciated by investors, and 
has  created  a  large  amount  of  euro-denominated  assets  that  provide  an  important 
benchmark  to  European  financial  markets  and  strengthen  the  position  of  the  euro  in 
international markets.  

1.2.  Investments and reforms produce results on the ground 

The support provided by the RRF covers a large variety of policy areas, reflecting 
the  instrument’s  ambition  to  deliver  structural  change.  The  RRF  is  the  first 
performance-based instrument of this magnitude in the EU. Payments to Member States 
are made for tangible progress in reforms and investments. The achieved milestones and 
targets  translate  into  concrete  benefits  to  citizens  and  business  in  various  areas:  from 
education and healthcare to energy, transport infrastructure, business environment, digital 
public services, employment policies, rule of law or research and innovation. Policy targets 
have been instrumental in steering the reforms and investments in line with EU priorities. 
Member  States'  plans  have  exceeded  the  20%  and  37%  targets  on  digital  and  climate 
objectives respectively. For the RRF as a whole, estimated climate expenditure amounts to 
about 42%, with some Member States dedicating over 50% of their total plan to the EU's 
green transition.    

Given the deep economic integration of EU economies, the benefits from each RRP 
extend well beyond national borders. The increase in demand triggered by the RRF in 
one  sector  leads  to  higher  demand  for  imported  final  or  intermediate  goods  from  other 
Member  States,  benefitting  many  European  companies.  For  instance,  the  increase  in 
production of electric cars in Germany or France benefits the producers of car components 
across  many  more  Member  States.  Similarly,  companies  of  one  Member  State  can  be 
involved in measures of another country's RRP. For example, Cyprus’ RRP is funding the 
construction  of  three  water  reservoirs  that  were  produced  by  an  Austrian  company  to 
enhance water security in Nicosia and Larnaca (Cyprus).  

The impact of the RRF is visible across the EU. Spillover effects can, in some Member 
States, more than double the direct impact of the national RRF envelope by 2030 (6). 
Given the scale of their RRPs, Italy and Spain stand out as the two main beneficiaries in 
terms  of  expected  GDP  growth.  Significant  GDP  gains  are  also  projected  for  Greece, 
Poland, Portugal, and Romania, largely driven by the direct effects of their national plans, 
namely an immediate boost in production and employment in recipient industries, along 
with increased demand for inputs from domestic suppliers. The third-largest beneficiary of 
the RRF is Germany, in large parts thanks to spillovers from other Member States’ plans. 
In Germany, Austria, and Denmark, spillover gains more than double the direct impact of 
their respective RRPs, while spillover gains triple the direct impact for the Netherlands, 

(5)  During the RRP implementation period, the share of 2019-2020 CSRs reaching at least ‘some progress’ 

increased from 52% in 2021 to 75% in the 2024 CSR assessment. 

(6)   Source: ‘Economic impacts of the Recovery and Resilience Facility: new insights at sectoral level and 

the case of Germany’, Michels et al. (2025) 

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Ireland  and  Luxembourg.  Belgium,  Finland  and  Sweden  also  see  considerable  benefits 
with  spillovers  nearly  doubling  the  direct  impact.  In  France,  spillovers  boost  the  direct 
impact by half of its national envelope. EU countries that are highly integrated in the Single 
Market  benefit  from  the  strongest  spillover-to-GDP  effects.  The  highest  spillover  gains 
relative  to  GDP  are  observed  in  Slovakia,  Slovenia,  and  Czechia,  due  to  their  deep 
integration into EU value chains. 

Figure 1: RRF Impact on the ground (7) 

(7)  Data as of 31 December 2024. Source: common indicators and thematic analyses. For Denmark’s annual 
electricity consumption, see Eurostat data on Supply, transformation and consumption of electricity in 
2023. For the installed capacity of wind and solar energy, see  Wind energy in Europe: 2024 Statistics 
and  the  outlook for 2025-2030  |  WindEurope  and  EU  Market  Outlook  for  Solar  Power 2024-2028  - 
SolarPower Europe. 

3 

 
 
 
 
The RRF Drives Structural Change (8) 

Many of the reforms included in the RRPs lead to structural improvements in Member 
States’ economies and societies.  

A quarter of RRF reforms improve the quality of institutions, a key pillar of long-term 
growth.  These  measures  aim  to  modernise  public  administration,  optimise  taxation 
systems, enhance public procurement, and strengthen the judiciary, anti-fraud and anti-
corruption frameworks.  

17%  of  RRF  reforms  focus  on  improving  the  business  environment.  This  includes 
reforms that simplify regulation, support research and development, enhance financial 
market functioning, and facilitate the digitalisation of businesses. 

Many reforms also aim to improve skills and labour market outcomes. These include 
reforms  to  strengthen  education  systems,  improve  labour  market  functioning,  and 
enhance the sustainability of social security and pension systems.  

Approximately two thirds of these reforms have already been implemented, creating the 
adequate framework conditions for related investments. 

(Source: Commission analysis, national recovery and resilience plans) 

Skills & labour
13%

Labour market 
3%

Energy (incl. permitting)
11%

Education
9%

Green 
30%

Social Housing
1%
Culture
1%

Health & 
Social
15%

Social (incl. long term and child 
care)
3%
Social security (e.g. Pensions)
3%
Health
6%
Public procurement 
2%
Implementation of the 
plan
2%

Public spending reviews
2%
Taxation
5%

Justice, anti-corruption and 
anti-fraud…

Institutions
25%

Transport
7%

Modernisation of 
buildings (e.g. energy 
efficiency)…

Water supply & waste
3%
Agriculture
2%
Digital & IT sector
5%

Simplification of regulation (cross-
cutting)…

Public administration
8%

Financial Markets
2%

Research & 
Development
3%
Professional and technical 
activities…

Business
17%

Figure 2: Overall distribution of reforms by key policy domains, in % of total number of reforms 
(total= 1,131)  (9) 

4 

 
 
 
2.  THE TIME REMAINING FOR IMPLEMENTATION IS SHORT 

2.1. 

 Implementation needs to be accelerated in many Member States  

The RRF is a temporary instrument, lasting until end-2026 to help Member States 
recover from the COVID-19 crisis and make their economies more resilient. The strict 
deadlines of the Facility reflect its temporary nature and its purpose to support the recovery 
from the COVID-19 pandemic, which in turn underpins its allocation key. These deadlines 
have provided a strong incentive to swiftly implement the reforms and investments in the 
RRPs, in  line  with  the  goal  of  the  Facility  to  drive  forward  a  fast  economic  and  social 
recovery (10).  

Overall, implementation and disbursements under the RRF have been fast, notably 
for  non-repayable  support.  This  reflects  the  speed  of  implementing  reforms  and 
investments,  in  addition  to  the  provision  of  pre-financing.  By  the  end  of  May  2025, 
disbursements had reached EUR 315 billion (49% of the total) for the achievement of 2,218 
milestones  and  targets,  pertaining  to  1,145  reforms  and  1,073  investments.  In  relative 
terms, 57% of the total non-repayable support and 38% of the total loan support has been 
paid  to  Member  States.  The  latter  also  reflects  that,  when  designing  the  initial  RRPs, 
Member States have prioritised grant over loan disbursements and a large portion of the 
loan support was added only with the REPowerEU chapters in 2023 (11). More than 31% 
of  all  milestones  and  targets  have  been  assessed  by  the  Commission  as  fulfilled,  and 
Member States have reported an additional 21% as completed.    

However, while substantial progress has been made and many success stories have 
materialised on the ground, implementation needs to be accelerated in most Member 
States. Some EUR 335 billion remain to be disbursed in the next year and a half (roughly 
EUR 154 billion in grants and EUR 180 billion in loans). Looking ahead, more than 4,300 
milestones and targets (out of 7,105) still need to be submitted for assessment by Member 
States. 

From the outset, implementing all RRF-funded projects was going to be a challenge, 
given  the  size  of  RRF  funding  relative  to  both  the  size  of  the  economy  in  major 
recipient countries and the amount of existing EU funding. RRF funds have also come 
in addition to other EU funds, and the RRF allocation represents a significant share of GDP 
in many Member States, reaching 16% for Greece, 13% for Croatia and 11% for Spain (12). 
While administrative capacity has been enhanced in many Member States throughout the 
lifetime of the RRF, including through measures contained in the plans, some constraints 

(8)   See the thematic analyses published on the RRF scoreboard to read more about the measures supported 

by the RRF in many different policy areas.   

(9)  This categorisation builds on the NACE code classification and follows an economic sector perspective. 
More details on the methodology can be found in the corresponding discussion paper:  Michels et al. 
(2025). Economic Impacts of the Recovery and Resilience Facility: New Insights at Sectoral Level and 
the Case of Germany, Discussion Paper 221, DG ECFIN. 

(10)  Mid-term evaluation of the Recovery and Resilience Facility (RRF), 2024 

(11)  Out of the total loan support currently committed (EUR 291 billion), EUR 125 billion (or 43%) was 
requested and committed only during the RRPs’ revisions in 2023. Accordingly, their related milestones, 
targets and payments have been set mainly for the second half of the RRF period. 

(12)  Calculated as share of 2024 GDP. Most beneficiary Member States recovered strongly after the COVID-
19 crisis, including thanks to the RRF. This reduced the 2024 GDP shares compared to the allocations 
in terms of 2020 GDP, the reference year when the RRF was set up in 2021.  

5 

 
 
 
remain  (for  example,  in  the  area  of  permitting,  where  bottlenecks  should  be  swiftly 
addressed).  In addition, identifying specific investment projects takes time.  

The implementation of the RRF has also taken place amidst several crises. Russia’s 
unprovoked  war  of  aggression  against  Ukraine  and  the  ensuing  energy  crisis,  high 
inflation, supply chain bottlenecks and some climate-related disasters have compromised 
or delayed the implementation of RRF measures. The addition of REPowerEU chapters to 
most RRPs in the second half of 2023, together with requests for additional RRF loans, 
provided  fresh  funding  for  new  priority  measures,  but  also  consumed  significant 
administrative capacity in the Member States temporarily diverting the focus away from 
implementation.  While  implementation  significantly  accelerated  in  the  first  half  of 
2024 (13), which helped catch up on disbursements, the amount of funding to be disbursed 
until end-2026 remains substantial.  

Administrative burden might also have affected the speed of implementation of the 
RRF.  In  the  RRF  mid-term  evaluation,  Member  States  considered  that  the  Council 
implementing decisions were too detailed. The legally binding character of each element 
contained therein, including in the description of the measure, has been reinforced by a 
literal  interpretation  by  the  European  Court  of  Auditors.  In  the  view  of  some  Member 
States, this has led to a higher-than-expected administrative burden in implementing the 
Facility and implementation delays.  

Implementation delays are reflected in the recent slowdown in disbursements. Despite 
improvements between the second half of 2023 and 2024, the first half of 2025 has seen a 
marked  slowdown  in  disbursements.  While  EUR  66  billion  had  been  disbursed  in  the 
second half of 2024, only EUR 9.5 billion have been disbursed in the first five months of 
2025, at a time when a further acceleration would have been necessary in view of the fast-
approaching 2026 deadlines. 

To  fully  implement  the  RRF  and  reap  its  benefits,  a  significant  acceleration  in 
implementation by the Member States is needed. The current pace of implementation 
is not sufficient to ensure the completion of all milestones and targets by August 2026 and 
the disbursement of the full RRF allocation by the end of the Facility in 2026.  

2.2.  Delays in implementation result in costs for the European Union 

Implementation  delays  have  compounded  an  already  backloaded  implementation 
profile with a financial cost for the EU budget. Due to the large amounts of funding 
needed for the final year of implementation, the Commission needs to plan its borrowing 
operations from the capital markets well in advance. This is particularly relevant for the 
RRF  borrowing,  due  to  the  significant  volume  of  the  programme  and  the  deadline  for 
disbursements  by  end-2026.  Since  the  launch  of  the  Facility,  the  Commission  has 
borrowed funds for the RRF based on the envisaged schedule of Member States’ payment 
requests  over  a  6  to  12  months  horizon  and  has  succeeded  in  releasing  funds  to  them 
immediately  after  the  disbursements  were  authorised.  However,  payment  requests  have 
frequently been submitted and completed with delays compared to the planned schedule, 
notably  when  Member  States  have  submitted  targeted  revisions  of  their  RRPs 
simultaneously. 

(13)  cf. Annual Report on the implementation of the Recovery and Resilience Facility, 2024 

6 

 
 
 
The first half of 2025 has seen two developments that make the liquidity management 
exercise  more  challenging.  First,  as  mentioned  above,  disbursements  have  fallen 
significantly  below  the  amounts  forecasted  based  on  indications  by  Member  States, 
resulting in an unexpected accumulation of large balances by the EU for a protracted period 
of  time.  Second,  changes  in  the  interest  rate  environment  mean  that  cash  balances  are 
starting to generate net liquidity costs for the EU budget and loan beneficiaries, despite the 
Commission’s  active  treasury  management  of  liquidity  pending  the  approval  of 
disbursements. Given the concentration of expected disbursements in the final phase of the 
RRF, the Commission will continue to use all funding opportunities to ensure that it can 
continue to make payments as required.  

2.3.  Planning for the closure of the RRF  

The  RRF  is  subject  to  strict  implementation  deadlines,  in  line  with  its  nature  as 
temporary  support  instrument  set  up  in  response  to  the  COVID-19  crisis.  As  a 
dedicated  instrument  designed  to  tackle  the  adverse  effects  and  consequences  of  the 
COVID-19 crisis in the Union, supported by the extraordinary and temporary additional 
means in the Own Resources Decision (14), the RRF was created with very strict time limits 
that are set out in the EURI Regulation (15), in the RRF Regulation  (16), and in the Own 
Resources Decision and cannot be derogated from. 

Member States have 454 days left to deliver on the reforms and investments included 
in  their  RRPs.  The  RRF  Regulation  and  the  adopted  Council  implementing  decisions 
provide that all milestones and targets for the implementation of reforms and investments 
must be completed by 31 August 2026 (17). In line with those provisions, any action taken 
after 31 August 2026 to fulfil milestones and targets cannot be taken into consideration in 
the  assessment  of  payment  requests.  This  also  applies  to  actions  taken  to  ensure  the 
satisfactory fulfilment of milestones and targets covered by suspension decisions adopted 
before 31 August 2026 and prevents the initiation of new suspension procedures after that 
date. Furthermore, this  means that there is no scope for  adopting amendments of RRPs 
after 31 August 2026. All payment requests, including the management declarations, the 
summaries of audits carried out (18), and all evidence necessary for their assessment, must 
be submitted by 30 September 2026 (19). The Commission will then assess the satisfactory 
fulfilment of milestones and targets included in the last payment requests in line with the 

(14)  Council Decision (EU, Euratom) 2020/2053 of 14 December 2020 on the system of own resources of 
the  European  Union  and  repealing  Decision  2014/335/EU,  Euratom,  OJ  L  424,  15.12.2020, 
ELI: http://data.europa.eu/eli/dec/2020/2053/oj 

(15)  Council Regulation (EU) 2020/2094 of 14 December 2020 establishing a European Union Recovery 
Instrument to support the recovery in the aftermath of the COVID-19 crisis, OJ L 433I, 22/12/2020,  
ELI: http://data.europa.eu/eli/reg/2020/2094/oj 

(16)  Regulation  (EU)  2021/241  of  the  European  Parliament  and  of  the  Council  of  12  February  2021 
18.2.2021,  ELI: 

and  Resilience  Facility,  OJ  L 

57, 

establishing 
http://data.europa.eu/eli/reg/2021/241/oj 

the  Recovery 

(17)  Articles  18  and  20  of  the  RRF  Regulation  and  Article  2(4)  of  the  respective  Council  Implementing 

Decisions 

(18)  In line with Article 22(c) of the RRF Regulation  

(19)  Article 6 of the RRF Financing Agreements and Article 7 of the RRF Loan Agreements 

7 

 
 
 
Framework for assessing milestones and targets under the RRF Regulation published on 
21 February 2023 (20). All payments must be made by 31 December 2026 (21). 

Figure 3: Timeline of the RRF closure 

3.  GUIDANCE FOR MEMBER STATES TOWARDS 2026 

Given the implementation delays and the upcoming 2026 deadlines under the RRF, this 
section  provides  guidance  to  Member  States  on  how  to  further  streamline  their  RRPs, 
which options to consider when revising them, and how to plan ahead for the submission 
of the last payment requests in 2026 (22). 

All revised RRPs must continue complying with all assessment criteria laid down in the 
RRF Regulation. This is to ensure that the plans continue supporting Member States in 
addressing their specific needs, that at least the funds required under the RRF Regulation 
are allocated to the green and digital transition, that the do-no-significant-harm principle 
is adhered by, and that the financial interests of the Union are protected. In this context, 
Member States should also review the implementation state of their projects with a positive 
climate coefficient and ensure that their reporting to the Commission is up to date (23). 

3.1.  Streamlining RRPs 

Member  States  should  comprehensively  review  their  RRPs  as  soon  as  possible  to 
ensure all milestones and targets can be implemented by the 31 August 2026 deadline. 
Only measures that are certain to be fully implemented by this deadline should remain in 

(20)  Annex  I  to  the  Communication  from  the  Commission  to  the  European  Parliament  and  the  Council 
Recovery and Resilience Facility: Two years on A unique instrument at the heart of the EU’s green and 
digital transformation, COM(2023) 99 final, 21 February 2023  

(21)  Article 24 of the RRF Regulation, see also Article 3(9) of Council Regulation (EU) 2020/2094 of 14 
December  2020  establishing  a  European  Union  Recovery  Instrument  to  support  the  recovery  in  the 
aftermath of the COVID-19 crisis and the exceptions mentioned therein 

(22)  The guidance in this section will be complemented with additional technical guidance for Member States 
on the ‘closure’ of the RRF. In preparing for the end of the RRF, the Commission will provide detailed 
guidance on all operational aspects linked to the closure of the Facility, including on clearing of pre-
financing, reporting and the protection of the financial interests of the Union. 

(23)  The reporting on the implementation of these measures is lagging behind. Given that the Commission 
relies  on  data  on  the  reported  green  expenditure  from  Member  States  for  the  issuance  of 
NextGenerationEU Green Bonds, Member States should swiftly report on relevant expenditure incurred 
and ensure timely reporting going forward. 

8 

 
 
 
 
the plans. Measures for which this cannot be guaranteed should be removed to avoid the 
decommitment of large amounts of RRF funds. Priority should be given to securing the 
grants  allocation.  To  leave  sufficient  time  for  the  implementation  of  all  milestones  and 
targets and the assessment of all payment requests, the Commission urges Member States 
to undertake such plan revisions as soon as possible and, in any event, by the end of 2025. 
Failure to carry out such revisions will lead to increased risks of non-implementation of 
RRF measures and thus decommitment of funds under the RRF.    

These  last  plan  revisions  should  also  be  used  to  review  the  wording  of  measures, 
milestones and targets to ensure that they focus on essential elements only. The goal 
should be to  facilitate the  implementation  and assessment of the implementation  of the 
RRPs, and reduce administrative burden, while preserving the ambition of the plan and 
continuing  complying  with  the  requirements  of  the  RRF  Regulation.  First,  following 
Member States’ requests, the Commission will propose to the Council to remove from the 
Council implementing decisions any ambiguous or unclear language, or any specification 
that  exceeds  the  requirements  needed  to  demonstrate  fulfilment  of  a  measure.  Second, 
Member States should reconsider the inclusion in their RRPs of minor reforms which do 
not  contribute  to  addressing  CSRs.  Third,  given  the  fast-approaching  deadline  for  the 
completion of measures, where appropriate, intermediary milestones and targets should be 
removed to focus on final outputs. Fourth, where possible, Member States are encouraged 
to amend their plans to advance any already achieved milestones and targets to payment 
requests  in  2025  in  order  to  reduce  the  size  of  payment  requests  in  2026.  When 
streamlining their  RRPs, Member States should ensure that all  RRF  assessment  criteria 
continue to be met, including that the plans continue addressing all or a significant subset 
of relevant CSRs, allocate sufficient funds to the green and digital transition, respect the 
do-no-significant-harm principle and ensure the protection of the financial interests of the 
Union, as reflected, where relevant, in audit and control milestones. The ambition of rule 
of law reforms should be maintained. The Commission will work together with Member 
States to help in this streamlining exercise, with a view to ensuring equal treatment and 
consistency across plans. The Commission will discuss with the Member States bilaterally 
and multilaterally and will provide concrete examples on how to streamline and simplify, 
and discuss whether further options may be pursued by the Member States, beyond those 
listed below, in particular contributing to well identified projects serving digital priorities, 
such as artificial intelligence (GigaFactories, AIFactories), cables and chips, as well as to 
research and innovation priorities. 

3.2.  Possible options when amending RRPs 

When amending their RRPs, Member States are encouraged to explore all available options 
to safeguard their RRP allocation, in particular for the non-repayable support component, 
while ensuring that the supported reforms and investments continue to deliver a high level 
of performance in line with the EU priorities. New investments should be easily shown to 
be compliant with the relevant legal requirements. To this end, the following options can 
be considered: 

•  Scaling up existing measures 

Member States should consider the possibility to scale up measures where implementation 
is going well, based on proven or likely demand. This could include investments for which 
delivery could be increased or measures with an already established overperformance.  

9 

 
 
•  Cutting down oversubscribed plans or downscaling the loan envelope  

In  case  the  total  estimated  costs  of  the  RRP  are  higher  than  the  financial  allocation, 
measures supported by RRF non-repayable support that are no longer implementable can 
be removed without being replaced, for an amount up to the oversubscription. In this case, 
the total non-repayable support under the RRF will remain unaffected.  

For Member States receiving loan support under the RRF, if grant-funded projects need to 
be  removed,  loan-funded  measures  can  be  moved  to  the  non-repayable  support 
compartment. This would allow to safeguard the grant amount, while reducing part of the 
loan support, unless compensated by new or upscaled loan-funded measures.  

Additionally, many RRF investments financed by loans are demand-based and may not 
receive as much demand as originally intended. These measures can thus be downscaled 
to match the effective demand and take up only the loan amount that is needed.  

•  Splitting RRF projects for continuation with national or other EU funds 

Projects that are no longer achievable by August 2026 can be downscaled to only retain 
the elements to be financed under the RRF that can be implemented within this timeframe. 
The part that remains financed under the RRF should constitute a standalone investment 
in the RRP. This means that the ‘retained’ elements should not be limited to intermediary 
steps  such  as  the  launch  of  a  call  for  tender.  The  rest  of  the  project  could  then  be 
implemented by national or, if eligible, other EU funds, on a longer timeline. The recent 
mid-term review of cohesion policy also encourages Member States to identify such RRF 
projects ahead of the amendments of the cohesion policy programmes (24). 

•  Financial instruments and grant schemes 

The  RRF  can  support  establishing  an  independently  managed  instrument  to  incentivise 
private investment. Under such investments, the milestones in the RRP would cover (i) the 
transfer of funds to the implementing partner upon signature of an implementing agreement 
and (ii) the signature of contracts with the final beneficiaries for the use of the totality of 
the funds transferred. To introduce such a financial instrument or grant scheme, Member 
States  should  determine  the  market  failure  they  seek  to  address  and  the  related  market 
demand, ensure that award decisions by the implementing partner are independent from 
the government and that the financial management is separate from the Member State, as 
well  as  examine  the  implementing  partner’s  operational  capacity  to  roll  out  such  an 
instrument.  

•  Transfers to InvestEU 

Member  States  can  transfer  funds  to  the  InvestEU  Member  State  Compartment  for  an 
amount  up  to  4%  of  their  total  RRF  allocation  and  an  additional  6%  for  measures 
contributing  to  the  Strategic  Technologies  for  Europe  Platform  (STEP)  objectives.  The 
final  milestone  in  the  RRP  would  be  the  approval  of  all  investment  operations  by  the 
InvestEU  Investment  Committee  by  31  August  2026.  Given  the  various  steps  of  the 
process, Member States seeking to transfer RRF funds to InvestEU must submit a revised 
RRP as soon as possible. 

(24)  See communication-mid-term-review-2025_en.pdf 

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•  Equity injections in National Promotional Banks and Institutions (NPBIs) 

The RRF can support capital injections into NPBIs (or their subsidiaries), in particular to 
support  projects  in  line  with  EU  strategic  priorities,  to  the  extent  that  those  address 
identified market needs and provided that the NPBI has capacity to expand its activity and 
that its investment policy is aligned with the policy objectives of the RRF. The specific 
milestones for such equity injection would be: (i) the subscription of all additional paid-in 
capital by the Member State, (ii) the adoption of a revised investment policy of the NPBI 
on how the increased equity will be utilised, and (iii) where needed, the entry into force of 
all the necessary changes to the governance as well as audit and control framework of the 
institution. Such an equity injection can involve broadening the mandate of the NPBI to 
activities  aligned  with  the  objectives  of  the  RRF  and  EU  priorities,  such  as  industrial 
decarbonisation,  energy  transition,  affordable  housing,  access  to  capital  or  security  and 
defence. 

•  Contributions to the European Defence Industry Programme (EDIP) 

The RRF could support voluntary national contributions to the future European Defence 
Industry Programme (EDIP). The contribution to EDIP in such a case would be considered 
an RRF investment. Specific projects would subsequently be selected and supported under 
EDIP, for the benefit of the Member State concerned, with implementation occurring over 
a longer time horizon. The RRF measure would include a milestone on the signature of a 
contribution agreement and the transfer of funds to EDIP and would clarify what type of 
activities under EDIP would be funded. For this option to work, a provision in the EDIP 
Regulation will need to ensure that RRF-supported voluntary contributions are used for 
the benefit of the Member State concerned. The Commission invites the co-legislators to 
introduce such a provision in the EDIP Regulation during the trilogues.    

•  Contributions to EU programmes for satellite communications 

The RRF can support contributions by Member States to the development of components 
of the Union Space Programme or of the Union Secure Connectivity Programme (25). Such 
contributions  would  be  considered  an  RRF  investment.  The  Union  Space  and  Secure 
Connectivity  programmes  enhance  the  Union’s  strategic  autonomy,  technological  non-
dependence and resilience, and contribute to security and defence. In particular, the Union 
Secure Connectivity Programme also aims to provide reliable, secured and cost-efficient 
governmental  satellite  connectivity.  These  programmes  underpin  EU  secure  satellite 
projects  such  as  Galileo  (satellite  navigation),  GOVSATCOM  or  IRIS²  (satellite 
communication). Under the RRF, Member States can make voluntary contributions to such 
programmes, where the contribution agreement between the Commission and the Member 
State  would  warrant  that  the  Member  State’s  contribution  will  be  used  under  these 
programmes  for  the  benefit  of  the  Member  State  concerned.  The  RRF  measure  would 
include a milestone on the signature of a contribution agreement and the transfer of funds 
to the programme in question.  

3.3.  Prepare for 2026 payment requests 

2026 will be a crucial year for payments, with short timelines and a substantial impact 
on  resources  for  both  Member  States  and  the  Commission.  As  the  deadline  for 

(25)  Regulation (EU) 2023/588 of the European Parliament and of the Council of 15 March 2023 establishing 

the Union Secure Connectivity Programme for the period 2023-2027 

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submitting  the  last  payment  request  is  30  September  2026,  with  disbursement  by  31 
December 2026, the assessment period will be extremely short. Combining this with the 
likely high number of milestones and targets to be assessed, it will be crucial to ensure an 
effective and smooth assessment process.  

Member  States  are  encouraged  to  plan  ahead  and  ensure  the  robustness  of  the 
evidence  provided  in  due  time,  to  limit  issues  arising  during  the  assessment.  The 
adoption of payment decisions within the deadline will only be possible if Member States 
submit sufficiently complete payment requests. Failure to provide evidence showing the 
fulfilment  of  all  requirements  of  milestones  and  targets  will  inevitably  result  in 
decommitments  of  funds.  All  the  necessary  evidence  to  demonstrate  the  satisfactory 
fulfilment of milestones and targets that are part of the last payment request will have to 
be provided by 30 September 2026, as there will be extremely little time for exchanges 
between the Commission services and Member States authorities  during the assessment 
period of the last payment requests. In that context, evidence should be informally shared 
with  the  Commission  services  as  soon  as  ready,  even  before  the  formal  submission  of 
payment requests. This is particularly relevant in the case of milestones and targets that are 
assessed via sampling, where experience has proven that several exchanges between the 
Member State and the Commission are needed to establish satisfactory fulfilment. 

Member States and the Commission should also ensure that sufficient resources are 
allocated to processing the submission of the last payment requests. In most Member 
States, the number of milestones and targets to be processed in 2026 will be considerably 
higher than in any previous year. Given these exceptional circumstances, the Commission 
services working on the RRF and on the Technical Support Instrument (TSI) are joining 
forces to ensure that sufficient resources are available to process the last RRF payment 
requests. Member States are encouraged to adjust their resources as necessary and possible 
to  ensure  they  have  the  administrative  capacity  to  pave  the  way  for  a  successful 
implementation  of  their  RRPs  in  line  with  the  legal  deadlines.  The  Commission  will 
continue to closely accompany Member States in all steps to implement their RRPs and 
submit the relevant payment requests. 

4.  CONCLUSION  

With the RRF, the EU has taken an unprecedented and effective step in collectively 
strengthening the recovery, resilience and competitiveness of its economy and society 
in response to the COVID-19 pandemic. Faced with one of the worst crises in its history, 
the EU bounced back quickly while investing in a more sustainable and prosperous future 
for  its  citizens  and  businesses.  Over  the  past  four  years,  much  has  been  accomplished 
despite a war on the continent and unexpected energy and trade shocks. Member States 
have implemented ambitious structural reforms, covering justice and pension systems as 
well  as  labour  markets,  public  procurement  and  many  other  sectors.  Thanks  to  RRF-
supported investments, the EU’s energy supply is cleaner and safer, the public transport 
network is  stronger and  more effective, citizens  benefit from better public services  and 
infrastructure, businesses are more digitalised and competitive, and benefit from a more 
skilled labour force.  

To allow the RRF to deliver its full potential, all efforts are now needed to accelerate 
implementation and ensure full disbursement of all committed resources. All Member 
States are encouraged to engage in a systematic review of their RRPs to streamline and 
simplify them, while ensuring that they continue complying with all assessment criteria 

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laid  down  in  the  RRF  Regulation.  As  implementation  accelerates,  intergenerational 
fairness remains at the core of NextGenerationEU. 

From the onset, the RRF was set up as a temporary instrument ending in 2026. As 
the end of the instrument is now within sight, the Commission stands ready to work with 
Member States to ensure a smooth and successful closure of the instrument. With 454 days 
left for implementation, the time to act and deliver is now. 

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