COMMISSION STAFF WORKING DOCUMENT Accompanying the document Communication from the Commission Nuclear Illustrative Programme presented under Article 40 of the Euratom Treaty for the opinion of the European Economic and Social Committee
Date: 2025-06-13
Institutions: Directorate-General for Energy, European Commission
Subjects: energy production, innovation, investment, nuclear energy, nuclear policy, nuclear power station, nuclear safety, nuclear technology, radioactive waste, storage of waste

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.6.2025  SWD(2025) 160 final  COMMISSION STAFF WORKING DOCUMENT   Accompanying the document Communication from the Commission Nuclear Illustrative Programme   presented under Article 40 of the Euratom Treaty for the opinion of the European Economic and Social Committee {COM(2025) 315 final}  
 
 
TABLE OF CONTENTS 

1.  Executive summary ......................................................................................... 4 

2.  Nuclear power outlook .................................................................................... 5 

2.1.1.  Electricity  generation  capacities  for 

2.1.  Generation capacity evolution ............................................................... 5 
large-scale  nuclear 
reactors for the years 2024 to 2050 ......................................... 7 
2.1.2.  Present value of required capital expenditures ...................... 10 
2.2.  Power system effects ........................................................................... 16 
2.2.1.  System integration ................................................................. 16 
2.2.2.  Flexibility .............................................................................. 18 
2.2.3.  Need for EU-wide coordination ............................................ 20 

3.  Beyond electricity generation ........................................................................ 22 

3.1.  Heat supply .......................................................................................... 22 
3.1.1.  Present and future role of nuclear in the energy system ........ 22 
3.1.2.  Nuclear heat use cases ........................................................... 23 
3.2.  Radioisotopes ...................................................................................... 25 
3.2.1.  The use of medical radioisotopes .......................................... 25 
3.2.2.  The global radioisotopes market and supply chain ............... 26 
3.2.3.  Changes  in  the  European  Union  nuclear  infrastructures 
supporting the supply of medical radioisotopes .................... 28 
3.2.4.  Findings and recommendations ............................................. 29 

4.  Analysis of the supply chain ......................................................................... 31 

4.1.  Overview ............................................................................................. 31 
4.2.  Supply chain for the nuclear fuel cycle ............................................... 32 
4.2.1.  Mining and milling ................................................................ 33 
4.2.2.  Conversion ............................................................................. 37 
4.2.3.  Enrichment ............................................................................ 40 
4.2.4.  Fuel fabrication ...................................................................... 44 
4.2.5.  Reprocessing .......................................................................... 47 
4.2.6.  Findings and conclusions on nuclear fuel supply chain ........ 48 
4.3.  Supply chain for nuclear installations life cycle.................................. 49 
4.3.1.  Supply of key materials for construction and operation ........ 50 
4.3.2.  Construction of new nuclear power plants ............................ 51 
4.3.3.  Long term operations ............................................................. 55 
4.3.4.  Distinctive features of Small Modular Reactors (SMRs) ...... 56 
4.3.5.  Decommissioning and waste management ............................ 58 
4.3.6.  Findings and conclusions on nuclear installations supply chain
 ............................................................................................... 66 

5. 

Innovation ...................................................................................................... 67 

1 

 
 
 
5.1.  Small Modular Reactors ...................................................................... 67 
5.1.1.  Technology of modular reactors ............................................ 67 
5.1.2.  Hybrid energy systems .......................................................... 70 
5.1.3.  Potential development of modular reactors in the EU ........... 70 
5.1.4.  Safety and licensing ............................................................... 74 
5.1.5.  The  European  SMRs  pre-Partnership  and  Industrial  Alliance
 ............................................................................................... 76 
5.2.  Nuclear fusion ..................................................................................... 78 
ITER: The EU’s Flagship Project to demonstrate the scientific 
and technological feasibility of fusion .................................. 80 
5.2.2.  The EURATOM Research & Training Programme .............. 81 
5.2.3.  Recent developments in private innovative projects ............. 83 
5.2.4.  Development of regulatory frameworks ................................ 86 
5.2.5.  Need for an EU Strategy on Fusion ....................................... 88 

5.2.1. 

6.  Enablers ......................................................................................................... 90 

the 

requirements  on 

6.1.1.  High-level  qualitative 

6.1.  Regulatory capacity ............................................................................. 90 
regulatory 
resources  in  the  international  and  Euratom  legislation  on 
nuclear safety, spent fuel and radioactive waste management 
and decommissioning ............................................................ 90 
6.1.2.  Diversity of national approaches to ensure the adequacy of the 
regulators’ financial and human resources ............................ 92 
6.1.3.  Regulators play a strategic role in ensuring the safe completion 
of nuclear new build investment projects .............................. 95 
6.1.4.  Regulatory  cooperation  as  a  solution  to  optimise  the  use  of 
resources ................................................................................ 98 
6.2.  Transparency ..................................................................................... 100 
6.2.1.  The importance of public information and public participation 
in  the  decision  making  on  nuclear  installations  is  globally 
recognised ............................................................................ 100 
6.2.2.  Variety of EU arrangements aiming to ensure that the public is 
properly informed and involved .......................................... 104 
6.2.3.  Nuclear safety is of high interest for the citizens calling for a 
continuous dialogue and exchange ...................................... 108 
6.3.  Skills and human resources ............................................................... 110 
6.3.1.  Skills shortage affects nuclear investments ......................... 110 
6.3.2.  Main challenges ................................................................... 112 
International cooperation ................................................................... 117 
6.4.1. 
International partnerships .................................................... 117 
6.4.2.  Nuclear cooperation agreements as facilitators and enablers for 
investments .......................................................................... 117 
6.4.3.  Bilateral agreements as enablers for investments ................ 119 
6.4.4.  Conclusion ........................................................................... 119 

6.4. 

7.  Financial models .......................................................................................... 121 

2 

 
relating 

investment  needs 

7.1.  Costs and benefits market participants do not fully take into account in 
nuclear energy and public intervention ............................................. 121 
7.1.1.  Lack of market-based instruments for risk allocation ......... 121 
7.1.2.  Hold-up risk ......................................................................... 124 
7.1.3.  Externalities 
in  other 
to 
infrastructure ........................................................................ 124 
7.1.4.  Costs  and  benefits  market  participants  do  not  fully  take  into 
account in the context of SMRs and AMRs ........................ 125 
7.2.  Legislation providing support instruments to manage risks .............. 126 
7.2.1.  Two-way CfDs .................................................................... 127 
7.2.2.  PPAs .................................................................................... 129 
7.2.3.  RAB model .......................................................................... 129 
7.3.  Allocating electricity market and construction risk is key ................ 131 
7.3.1.  Electricity market risk ......................................................... 132 
7.3.2.  Construction risk ................................................................. 133 
7.3.3.  Political and regulatory risk ................................................. 135 
7.4. 
Incentives ........................................................................................... 136 
7.5.  Conclusions ....................................................................................... 137 

Annex A 

Factual summary report on the Call for Evidence (CfE) () . 139 

1.  Objective of the Call for Evidence .............................................................. 139 

2.  Approach to the Call for Evidence .............................................................. 139 

3.  Feedback ...................................................................................................... 139 

3.1.  Respondent profile............................................................................. 139 
3.2.  Feedback content ............................................................................... 140 

3 

 
 
 
1.  EXECUTIVE SUMMARY 

This  Staff  Working  Document  (SWD)  accompanies  the  Communication  from  the 
Commission on Nuclear Illustrative Programme (PINC). The SWD is structured as 
follows.  

Section 2 presents an outlook for nuclear energy in the EU until 2050. It aggregates 
Member States’ plans for nuclear  energy as declared in their National  Energy and 
Climate  Plans  (NECPs)  and  derives  the  evolution  of  installed  generation  capacity 
from large-scale reactors, as well as the associated investment needs. The section also 
discusses the role of nuclear energy in the power system, including its potential to 
support system integration and its ability to address flexibility needs.  

Section  3  covers  use  cases  of  nuclear  energy  beyond  power  generation.  Nuclear 
energy already supports district heating networks today and may further contribute to 
the decarbonisation of heat in the future. It also has an important role to play for the 
supply of medical radioisotopes.  

Section 4 discusses two supply chains underpinning the use of nuclear energy: The 
supply chain  for nuclear fuel,  including  reprocessing  of spent  fuel,  and the supply 
chain for nuclear installations, including decommissioning and waste management. 
Rolling out Member States’ plans to use nuclear energy will require investments in 
both supply chains. 

Section 5 presents two areas of innovation in nuclear energy: small modular reactors 
(SMRs), including advanced modular reactors (AMRs), and microreactors on the one 
hand, as well as nuclear fusion on the other hand. Each area of innovation promises 
potential  benefits  for  further  decarbonisation,  security  of  supply,  and  affordable 
energy in the future, but requires investments to deliver these.  

Section 6 covers enabling functions of the nuclear ecosystem. Independent nuclear 
safety  authorities,  endowed  with  sufficient  resources,  are  an  indispensable 
prerequisite  for  the  use  of  nuclear  energy  while  guaranteeing  the  highest  safety 
standards. Ensuring adequate transparency and participation during decision making 
processes around nuclear energy is key. For Member States’ plans to materialise the 
nuclear workforce will have to replace retiring workers, and transfer skills to the next 
generation.  Finally,  international  cooperation  with  third  countries  allows  to  foster 
progress in the peaceful uses of nuclear energy and reduce dependencies throughout 
the fuel and components value chain through diversification. 

Section 7 addresses challenges in the financing of nuclear energy, arising from market 
incompleteness, hold-up risk, and possibly externalities relating to total system costs. 
The  section  provides  a  brief  overview  of  the  existing  support  measures  to  address 
these challenges and how they may be used to re-allocate risks affecting nuclear new-
build projects. It stresses the importance of preserving incentives when fine-tuning 
support instruments.  

4 

 
 
 
2.  NUCLEAR POWER OUTLOOK 

This section covers the role of large-scale civilian nuclear reactors in the electricity 
system. Sections 2.1.1 and 2.1.2 quantify investment needs by projecting generation 
capacity until 2050 (1). Sections 2.2.1 and 2.2.2 discuss the role of large-scale reactors 
in the wider electricity system, focusing on total system costs and their potential to 
provide flexibility. Section 2.2.3 discusses the need for EU wide coordination. 

Further  below,  Section  3  covers  non-power  uses,  and  Section  5.1  covers  small 
modular reactors (SMRs) and advanced modular reactors (AMRs). 

2.1.  Generation capacity evolution 

Analysing  global  trends  in  nuclear  energy  in  a  report  from  January  2025,  the 
International  Energy  Agency  (IEA)  documented  416  Giga  Watt  electric  capacity 
(GWe) of installed nuclear generation capacity at the end of 2023. It found that there 
were 63 nuclear reactors under construction, representing more than 70  Giga Watt 
(GW) of capacity, which was one of the highest levels seen since 1990. Three quarters 
of these were in emerging economies and half of them in China alone. Global annual 
investment  in  nuclear  –  encompassing  both  new  plants  and  lifetime  extensions  of 
existing ones – had increased by almost 50% in the three years since 2020, exceeding 
USD 60 billion. Across the three scenarios the IEA considered for the global capacity 
evolution, it projected an increase in installed capacity to 650 GWe, 870 GWe, and 
more  than  1,000  GWe  by  2050,  respectively (2).  The  IEA’s  2050  figures  include 
large-scale reactors and SMRs and AMRs alike. 

In the EU, there were 101 nuclear power reactors operating in 12 Member States (3) 
at the end of 2024. Their combined net electrical generation capacity was 98 GWe. In 
2023, they provided 22.8% of the EU’s electricity generation. Three nuclear reactors 
have recently connected to the grid. Two (Olkiluoto 3 in Finland, and Flamanville 3 
in France) were the first European Pressurised Water Reactors (EPR) to commence 
operations in Europe, while Mochovce 3 is a VVER-440 type reactor. One reactor in 
Slovakia (Mochovce 4) and two others in Hungary (Paks II) are under construction.  

The  cost  of  generating  electricity  from  nuclear  energy  is  a  recurring  theme  in  the 
ongoing policy debate around nuclear energy. Nuclear energy exhibits high upfront 
capital costs and relatively low operating costs, even after accounting for management 
of radioactive waste and spent fuel and eventual decommissioning of the plant. When 
authors  quantify  the  levelised  cost  of  electricity  (LCOE)  of  nuclear  energy,  they 
generally find comparably high figures driven by the high upfront capital costs for 
creating a new nuclear power plant. Figure 1 shows the LCOE for various generation 
technologies  in  2023.  Nuclear  new  build  exhibits  an  LCOE  of  around  150 

(1)  

(2)  

(3)  

The  analysis  focusses  on  the  investment  needs,  i.e.  the  capital  expenditures  required  to  deliver 
Member States’ plans. The attractiveness of the proposed investment  projects for potential private 
project sponsors, as could be quantified through a net present value (NPV) calculation, would at least 
require modelling the EU’s electricity market using a dispatch model. Electricity market modelling is 
outside of the scope of this Staff Working Document. 

IEA (2025), The Path to a New Era for Nuclear Energy, IEA, Paris https://www.iea.org/reports/the-
path-to-a-new-era-for-nuclear-energy, Licence: CC BY 4.0. 

Belgium,  Bulgaria,  Czech  Republic,  Spain,  France,  Hungary,  Netherlands,  Romania,  Slovenia 
(Croatia), Slovakia, Finland, and Sweden. 

5 

 
 
 
EUR/MWh (4).  Out  of  the  nine  generation  technologies  shown,  nuclear  and 
hydropower are the only ones providing clean, firm power. Clean, variable sources 
exhibit  lower  LCOEs.  The  LCOE  does  not  account  for  the  costs  to  integrate  a 
generation  source  with  the  electricity  system,  which  may  require  additional 
investments in network and storage infrastructure not reflected in the LCOE. Section 
2.2 covers power system aspects of nuclear energy.  

Figure 1 – Technology-fleet specific levelised costs of electricity (LCOE) for 2023 

Source:  Report  from  the  Commission  to  the  European  Parliament  and  the  Council:  Progress  on 
competitiveness of clean energy technologies (COM/2025/74 final), Figure 1, p. 8. 

Note:  

The solid blue lines denote the median and the light blue bars display a ±25% range across 
the  EU,  highlighting  differences  among  Member  States.  Based  on  JRC  METIS  model 
simulation; According to: Gasparella, A., Koolen, D. and Zucker, A., The Merit Order and 
Price Setting Dynamics in European Electricity Markets, Publications Office of the European 
Union,  2023.  Computation  based  on  annualised  costs  for  the  year  2023.  Capital 
Expenditure  (Capex)  and  Operating  Expenses  (Opex)  based  on  the  2040  climate  target 
PRIMES reference scenario, annualised by technical lifetimes and weighted average cost 
of  capital.  Annualised  costs  are  levelised  using capacity  factors  derived  from the METIS 
model. Variable costs are based on 2023 commodity prices, variable Opex and the dispatch 
in the METIS simulation. 

Several  Member  States  have  declared  plans  to  extend  the  operational  lifetime  of 
nuclear power plants or to build new ones in alignment with their National Energy 
and Climate Plans (NECPs) (5). This section quantifies the investment needs resulting 
from  these  plans,  considering  a  forecast  horizon  until  2050.  The  quantification  of 
investment needs takes two steps: section 2.1.1 projects nuclear generation capacities 
for the years 2024 to 2050; section 2.1.2 derives the present value of required capital 
expenditures to deploy the projected capacity. 

(4)   Other sources report different figures for the LCOE of nuclear new build projects, which may reflect 
different input assumptions. For instance, the IEA reports an LCOE for new build project of 75-110 
USD/MWh and significantly lower LCOEs for lifetime extensions. IEA (2025), The Path to a New 
Era  for  Nuclear  Energy,  IEA,  Paris  https://www.iea.org/reports/the-path-to-a-new-era-for-nuclear-
energy, Licence: CC BY 4.0. Figure 2.7, p.53. 

(5)  

Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 on 
the Governance of the Energy Union and Climate Action, OJ L 328, 21.12.2018, p. 1–77. 

6 

                                       
 
 
2.1.1. 

Electricity generation capacities for  large-scale nuclear reactors 
for the years 2024 to 2050 

The  investment  needs  quantification  relies  on  the  following  key  data  sources:  the 
IAEA “Power Reactor Information System” (PRIS) (6), the Member States’ (draft) 
updated NECPs (7), and investment projects notified to the Commission under Article 
41 of the Euratom Treaty. 

NECPs  include  information  on  national  plans  for  lifetime  extensions  of  existing 
plants,  and  on  plans  for  new  builds.  The  granularity  of  information  varies  across 
NECPs: some countries spell out in detail until what year they expect a given reactor 
to run, whereas other countries only provide high-level information. Combining (i) 
the information from PRIS on existing reactors, and (ii) the available information on 
lifetime extensions and new build plans from NECPs, complementing them with our 
best  estimates  where  Member  States  have  not  yet  spelled  out  their  plans in  detail, 
allowed to set a scenario of the evolution of nuclear generation capacities in the EU 
until 2050 (8).  

The section takes a bottom-up approach by developing a ‘base case’ scenario using 
the information available in NECPs for each existing reactor or new build project, 
filling information gaps with best estimates. The ‘base case’ scenario starts with the 
existing fleet of nuclear reactors. It considers the ongoing construction projects and 
adds planned new-build projects as announced in Member States’ NECPs. For each 
reactor, the scenario assumes a service life, based on information from NECPs where 
available, and best estimates reflecting the reactor model otherwise. Figure 2 shows 
the evolution of projected capacities in the ‘base case’ scenario. 

(6)  

(7)  

The  Power  Reactor  Information  System  (PRIS)  -  Home  Page  is  a  database  compiled  by  the 
International Atomic Energy Agency (IAEA). 

The national energy and climate plans (NECPs) were introduced by the Regulation on the governance 
of the energy union and climate action (EU)2018/1999, agreed as part of the  ‘Clean energy for all 
Europeans’ package which was adopted in 2019. The national plans outline how the EU countries 
intend to address the five dimensions of the Energy Union: (i) decarbonisation; (ii) energy efficiency; 
(iii) energy security; (iv) internal energy market; and (v) research, innovation and competitiveness. 
Member States were due to submit draft updated NECPs by 30 June 2023, and their final updated 
NECPs, taking account of the Commission’s assessment and recommendations, by 30 June 2024. The 
projection of future nuclear generation capacities reflects the final updated NECPs for those Member 
States which have submitted them at the time of writing, and it reflects the draft updated NECPs for the 
other Member States.  

(8)  

This  included  information  and  assumptions  on  design  lives  and  lifespans  of  individual plants,  the 
latter based on the information provided in the NECPs. 

7 

 
 
Figure 2 – ‘Base case’ scenario of large-scale power generation capacities in the EU, 2024 

– 2050 

Source:  European Commission. 

Notes: 

Section 5.1 treats SMRs separately. 

In Figure 2 capacities are broken down into three categories. The first category (in 
dark blue) shows reactors that exist today and are either within their design life or 
where the owners have already invested in a LTO programme in the past. The second 
category  (in  light  blue)  shows  reactors  that  exist  today,  but  where  new  LTO 
programmes are assumed to come up in 2025 or later. The third category (in yellow) 
shows  planned  new  build  capacities.  Without  lifetime  extensions,  all  but  the  most 
recently  added  reactors  would  retire  before  2050.  Taking  the  assumed  lifetime 
extensions into account, the installed capacity of existing reactors will decline from 
c. 98 GWe  today  to  c. 50 GWe  in  2050.  New  build  capacity  will  add  c. 60 GWe, 
leading to c. 109 GWe in 2050. This is an increase by 11% from today’s capacity. 
The  installed  capacity  may  reach  higher  levels  in  between,  if  new  builds  can 
commence operations early enough. These reactors would provide about 12% of all 
electricity produced in the EU in 2050. 

A  sensitivity  analysis  is  here  below  presented  as  there  is  uncertainty  around  the 
capacity evolution, arising mainly from two factors: (i) actual achievement of plants’ 
lifetime extension; and (ii) time of delivery of new build projects. 

Sensitivity to actual achievement of LTOs 

A sensitivity analysis to the ‘base case’ scenario shows that LTOs have a significant 
effect  on  the  installed  capacity  in  2050.  Operating  plants  undergo  Periodic  Safety 
Reviews at least every ten years (9). At each review, the Nuclear Safety Regulator 
decides  whether  the  plant  is  suitable  to  continue  safe  operations  or  not.  For  some 
existing plants, the Nuclear Safety Regulator has already approved a longer license, 
or the operators have announced plans to request permission to operate  beyond 60 

(9)  

Council Directive 2009/71/Euratom of 25 June 2009 establishing a Community framework for the 
nuclear safety of nuclear installations, OJ L 172, 2.7.2009, p. 18–22, Article 8c. 

8 

                                                                                                                     
 
 
years (10). If all other plants stopped their operations after reaching 60 years, Member 
States’ plans for new builds would not suffice to maintain the existing capacity by 
2050.  Instead,  the  installed  capacity  would  drop  to  around  91 GWe,  with 
approximately  31 GWe  from  existing  plants.  Alternatively,  if  all  existing  plants 
managed to achieve 70  or even 80 years of operation, the installed  capacity could 
reach up to 144 GWe by 2050, with around 84 GWe from existing plants. Thus, actual 
achievement of LTOs could shift the 2050 installed capacity by more than 50 GWe. 
Figure 3 shows sensitivity of the installed capacity by 2050 to the operating life of 
existing  plants.  It  illustrates  that  successful  LTO  programmes  are  essential  to 
maintaining today’s capacity by 2050.  

Figure 3 – Sensitivity of 2050 installed large-scale reactor capacity to LTOs 

Source:  European Commission. 

Notes: 

Section 5.1 treats SMRs separately. 

Sensitivity to actual construction time for new builds 

The  ‘base  case’  scenario  considers  new  build  projects  to  commence  commercial 
operations as announced in Member States’ NECPs. A sensitivity analysis to reflect 
potential delay in new build projects shows that delays can have a significant impact 
on the installed capacity in 2050. If all announced new build projects experienced a 
delay  of  10  years (11),  installed  capacity  by  2050  could  drop  to  c. 85 GWe,  with 
c. 35 GWe from new build plants. Thus, delays could shift the installed capacity in 
2050 by more than 20 GWe. Figure 4 illustrates sensitivity of the installed capacity 
to a delay in all new build projects. The installed capacity from large-scale reactors 
by  2050  decreases  as  the  assumed  delay  to  new  build  projects  increases.  This 
underscores the importance of the nuclear industry delivering projects on time. 

(10)  

In the ‘base case’ scenario, 36 out of the 101 existing nuclear power plants operate for more than 60 
years.  

(11)   Two recently completed new build projects in the EU, Flamanville 3 and Olkiluoto 3, experienced 
delays of more than 10 years. The recently completed Vogtle 3 project in the US experienced 7 years 
of delay. Since the analysis shows the effect of a delay to all new build projects announced in Member 
States’ NECPs, 10 years may suffice as upper limit for the sensitivity.  

9 

 
 
 
Figure 4 – Sensitivity of 2050 installed large-scale reactor capacity to delayed new build 

Source:  European Commission. 

Notes: 

    ‘         ’                                y. Section 5.1 treats SMRs separately. 

In a scenario, where most plants discontinue operations after 60 years of service and 
where new build projects experience a 10-year delay, the installed capacity could drop 
to less than 70 GWe by 2050. Thus, the range of uncertainty around the ‘base case’ 
scenario covers c. 77 GWe, as Figure 5 illustrates.  

Figure 5 – ‘Base case’ capacity evolution and uncertainty range 

Source: 

European Commission. 

Executing Member States’ plans requires simultaneously extending plants’ operating 
life beyond 60 years and delivering new build projects on time.  

2.1.2. 

Present value of required capital expenditures  

Converting  the  stream  of  LTOs  and  new  build  capacities  into  a  flow  of  capital 
expenditures requires assumptions on the unit investment costs for LTOs and for new 
build plants. The unit investment cost includes two parts: 

10 

                                                                                                       
 
 
 
•  The “overnight cost”, which refers to the cost of constructing the plant, including 
equipment,  construction  materials,  and  labour,  but  excluding  interest  during 
construction. 

•  Interest  during  construction  (IDC),  i.e.  investors’  opportunity  cost  of  providing 
capital during the construction period. It depends on the time to build the plant and 
the cost of capital. 

The construction period for a new build project stretches over several years. Project 
developers incur capital expenditures during the entire construction period already. 
To accommodate this, the ‘base case’ scenario takes assumptions on the overnight 
costs,  the  construction  period,  and  the  appropriate  discount  rate  to  calculate  the 
“present value equivalent” cost figure. Present value equivalent means that if project 
developers incur this one-off cost at the end of the construction period, the present 
value of this one-off cost is identical to the present value of spreading the overnight 
costs uniformly over the construction period. 

Table 1 below summaries the assumptions on the discount rate, construction period 
and overnight cost for a new build project, and construction period and overnight cost 
for a lifetime extension in the ‘base case’ scenario. 

Table 1 – Key assumptions for 'base case' scenario 

Item 
Discount rate 
Construction period for new build 
Overnight construction cost for new build 
Present value equivalent for new build 
Construction period for LTO 
Overnight construction cost for LTO 
Present value equivalent for LTO 

value 

unit 

7.5  % p.a. 
years 
EUR/kWe 
EUR/kWe 
years 
EUR/kWe 
EUR/kWe 

9 
8,000 
10,871 
2 
790 
820 

Source:  Discount rate: E                  : D          -                    A       D          -
            E       D          -            Mobility                D  V     A.          P. 
      .   E                              –  E                         H              –            
       P                                  ://    .      .  /   /  .    /  7                    . 
  9. 

Construction periods for new build and LTO, overnight construction cost for new build and 
LTO:  Investment  notifications  submitted  to  the  Commission  pursuant  to  Art.  41  of  the 
Euratom Treaty and IEA (    )  P  j                          E                 IEA  P     
     ://   .   .   /       /   j     -     -  -          -           -             :    BY 
 . . 

Notes: 

Present  value  equivalents  are  mathematical  functions  of  the  discount  rate,  construction 
period, and overnight costs (12). 
“ . .”                . 

(12)   Let r denote the discount rate, t the start year of construction, T the construction period in years, and 
O the overnight construction cost. Then c = O/T is the annual construction cost, assuming a uniform 
profile.  Assuming  construction  costs  occur  in  the  middle  of  a  calendar  year,  the  present  value  of 

construction costs is given by 𝑐 ∑
costs’, 

)
the  hypothetical  one-off  construction  cost  X  with 

. The analysis considers the ‘present value equivalent 
identical  present  value:  

1+𝑟

(

𝑡+𝑇
𝑘=𝑡

𝑘−0.5

1

= 𝑐 ∑

𝑡+𝑇
𝑘=𝑡

(

1

1+𝑟

)

𝑘−0.5

. For r > 0, as can be assumed, there is an analytical solution to 

11 

i.e. 
𝑡+𝑇−0.5

𝑋 (

1

1+𝑟

)

 
 
  
 
 
 
The discount rate reflects the weighted average cost of capital (WACC) of the project. 
The  base  case  assumption  of  7.5  %  p.a.  reflects  the  EU  Reference  Scenario  2020 
assumption  for  energy  supply  investments  under  contracts  for  differences.  The 
analysis considers constant construction costs in real terms and the discount rate is 
also a real discount rate. Pursuant to Article 41 of the Euratom Treaty, investors in 
the  nuclear  sector  are  obliged  to  notify  the  Commission  of  their  investment  plans 
under certain conditions (13). The Commission uses the information gathered through 
these notifications, together with other sources, to inform its cost assumptions. The 
‘base  case’  assumptions  for  the  construction  period  of  9  years  and  the  overnight 
construction costs for new build of 8,000 EUR/kWe reflect the expectations project 
developers expressed in recent investment notifications. 

For LTOs, the ‘base case’ assumptions for the construction period of 2 years and for 
the  overnight  construction  costs  of  790 EUR/kWe  reflect  expectations  project 
developers expressed in recent investment notifications pursuant to Article 41 of the 
Euratom Treaty (14). 

Multiplying  the  flow  of  LTOs  and  new  build  capacities  with  the  present  value 
equivalents  for  construction  costs  generates  the  cash  flow  of  capital  expenditures. 
Applying  the  discount  rate  gives  the  present  value  of  capital  expenditures,  i.e.  the 
investment  needs.  Nuclear  capacities  anticipated  in  the  ‘base case’  scenario  will 
require investments of around EUR 241 billion in present value terms (15). Lifetime 
extensions account for EUR 36 billion of those investments. Thus, while the actual 
achievement of LTOs can have a large impact on the installed capacity by 2050 (see 

X. The assumption of uniformly distributed construction costs may overstate the present value costs, 
as project developers have an incentive to back-load construction capital expenditures where possible, 
as this shortens the gap between expenditures and earnings from operations, which in turn increases 
the value of the project.  

(13)   The Commission received a total 44 investment notifications between January 2018 and February 

2025.  

(14)   The  analysis  considers  a  uniform  LTO  overnight  cost  case  independent  of  the  LTO  duration,  i.e. 
whether  it  is  a  life-extension  for  10  or  for  20  years.  This  reflects  that  the  key  cost  driver  for  life 
extensions are the components that need replacement, not the duration of the life extension. This also 
becomes evident from investment notifications pursuant to Article 41 of the Euratom Treaty, where 
the  Commission  has  observed  notifications  for  a  life  extension  for  20  years  with  a  lower  unit 
construction cost than seen in other notifications for a life extension for only 10 years.  

(15)   The Commission Staff Working Document accompanying the PINC adopted in 2017 reported a range 
of EUR 349 to 455 billion for new build and EUR 47 billion for LTOs until 2050. This is significantly 
higher than the present figures of EUR 205 billion for new build and EUR 36 billion for LTOs. There 
are multiple factors accounting for this difference: (i) the 2017 figures included new build and LTOs 
in the UK, which has a significant nuclear programme, but has since left the Union  – this reduces 
investment needs all else equal; (ii) compared to the 2017 projection, the current projection reflects 
less new build and more LTOs – this reduces investment needs all else equal; (iii) the forecast window 
shortened from 2015 – 2050 to 2024 – 2050 – this reduces reported investment needs all else equal; 
(iv) the 2017 figures recognised interest during construction, but they did not reflect a present value, 
whereas the currently reported figures reflect a present value – this reduces the reported investment 
needs all else equal; and finally (v) unit cost assumptions increased significantly between 2017 and 
today – this increases investment needs all else equal. A cross-check of figures addressing (i) and (iv), 
i.e. correcting for the UK’s exit from the Union, and disregarding discounting leads to current figures 
that are significantly higher than 2017 figures. This result is likely driven by the significant increase 
in unit costs for new build and LTOs.  

12 

 
 
Figure 3 above), they account only for a minor share of investment needs (16). New-
build large-scale reactors account for EUR 205 billion (17). 

To ease comparison with studies which may report undiscounted investment needs, 
Figure  6  shows  the  undiscounted  average  annual  investment  needs  to  deliver  the 
capacities in the ‘base case’ scenario until 2050. Average annual investment needs 
peak in the 2030s at more than EUR 30 billion per year. In the 2020s and 2040s, they 
will be more than EUR 12 billion per year. Investment needs for new-builds dominate 
throughout. Investment needs for LTOs are highest in the 2020s, at more than EUR 3 
billion per year. 

Figure 6 – Undiscounted annual investment needs, 2023 – 2050  

Source:  European Commission 

As for the capacity scenario, there is also uncertainty around the key assumptions for 
investments. A sensitivity analysis to discount rates, actual construction time for new 
builds, and overnight costs follows. 

Sensitivity to discount rates 

If the discount rate increases, future capital expenditures get discounted stronger and 
the investment needs decrease in present value terms. However, it is important to keep 
in mind the analysis of investment needs in this section considers capital expenditures 
in  isolation,  whereas  project  developers  consider  and  discount  all  cash  flows 
associated with a candidate investment project. This includes capital expenditures for 
construction,  but  also  earnings  from  operations,  and  decommissioning  costs.  As 
earnings  necessarily  arrive  after  construction  expenditures,  a  lower  discount  rate 
increases the value of a candidate project to the investor, all else equal. Policymakers 
aiming  to  stimulate  private  sector  investments  in  nuclear  energy  should  aim  at 
improving  the  risk  allocation  between  stakeholders  with  a  view  to  reduce  the 

(16)   The Commission supports several research projects on extending the operating life of nuclear power 
plants, possibly up to 100 years. Examples include, but are not necessarily limited to:  STRUMAT-
LTO (Structural Materials for LTO), DELISA- LTO (LTO VVER Ageing components), FIND (LTO 
ISIR AGE Structural Health piping).  

(17)   An  attempt  to  quantify  the  monetary  investment  needs  for  the  deployment  of  SMRs,  AMRs,  and 
microreactors is outside the scope of this Staff Working Document, because there is more uncertainty 
around the costs for these innovative reactor types than there is for large-scale reactors.  

13 

051015202530352023 - 20302031 - 20402041 - 2050Avg. undiscounted investment    d   . .       € b    o  LTONew build 
 
 
 
appropriate discount  rate (see Section 7). Figure  7 shows sensitivity of investment 
needs to the discount rate (18). 

Figure 7 – Investment needs for large-scale reactors until 2050 for a range of discount rates 

between 5% and 10%  

Source:  European Commission. 

Notes: 

‘B        ’                                      .  
Investment needs cover capital expenditures only and therefore decrease with the discount 
rate. However, project developers consider all subsequent cash flows, including earnings 
from operations and decommissioning costs. When incentivising private sector investment 
in nuclear energy, policymakers should aim at lowering discount rates through improving 
the risk allocation between stakeholders. 

Sensitivity to actual construction time for new builds 

The success of new-build construction projects is an important driver for investment 
needs. If new-build projects get delayed by 5 years, and constructions costs increase 
proportionally with construction time, installed capacity in 2050 decreases by almost 
9 GWe, while the  required investments  increase  by more than EUR 45 billion, i.e. 
society has to spend more for less capacity. The sensitivity analysis to delays shows 
that  capacity  added  until  2050  can  decrease  significantly,  while  investment  needs 
until 2050 stay in the same ballpark range and may even increase. This underlines 
again the importance for the nuclear industry to deliver new build projects on time 
and  within  budget.  Figure  8  below  shows  sensitivity  of  investment  needs  to  the 
construction period for new build projects (19). 

(18)   The analysis assumes constant overnight construction costs in real terms until 2050. The sensitivity 
to the discount rate can simultaneously be interpreted as a sensitivity to the assumption of constant 
real overnight construction costs: The ‘base case’ discount rate r is 7.5%. If one wanted to assume 
that real construction costs decrease  by a  rate  of  g = 0.5% per annum, the annual discount factor 
would be 
 Thus, the 8.0% discount rate sensitivity can also be interpreted 
as the ‘base case’ discount rate of 7.5% and an annual reduction of real overnight construction costs 
of 0.5%. Generally, higher discount rate sensitivities can be interpreted as ‘base case’ discount rate 
and decreasing real overnight construction costs, and lower discount rate sensitivities as ‘base case’ 
discount rate and increasing real overnight construction costs. 

≈ 0.926 ≈

1+8%

1.075

0.995

1−𝑔

1+𝑟

=

1

(19)   The analysis does not consider a sensitivity to the construction time for LTOs, as their construction 
time is generally short relative to the construction time for new builds, and reasonable sensitivities to 
LTO construction time would only have a minor impact on investment needs.  

14 

                                                                             .   .   .   .  7.  7.   .   .  9.  9.    .  I                                D             ( A  )                    -      
 
 
 
Figure  8  –  Investment  needs  for  new  build  capacity  until  2050  for  delayed  new-build 

deployment scenarios 

Source:  European Commission. 

Sensitivity to overnight cost assumptions 

Next to the ‘base case’ scenario, the figure presents two alternative cost  scenarios, 
one with lower overnight constructions costs for LTOs and new build, one with higher 
costs. These alternative cost assumptions reflect the lower and higher parts of the cost 
range investors have reported to the Commission in recent years pursuant to Article 
41 of the Euratom Treaty. Investment needs range between EUR 199 billion to EUR 
282 billion. This wide range further reinforces the importance for the industry to strive 
for cost reductions and to avoid overruns. Figure 9 shows sensitivity to overnight cost 
assumptions. 

Figure 9 – Investment needs for new build capacity until 2050 across different overnight cost 

scenarios 

Source:  European Commission. 

Notes: 

I      ‘                     ’                                  /k                 7   
 /k           ‘         ’                           /k       79   /k               ‘       
               ’                     9      /k            /k                . 

15 

 
 
 
2.2. 

Power system effects 

Nuclear energy provides clean, reliable and flexible power. It is flexible in the sense 
that a nuclear power plant’s output can respond to market signals.  

Section  2.2.1  covers  nuclear  energy  from  a  total  system  perspective.  When 
considering the cost-optimal energy mix for reaching decarbonisation, security and 
stability of supply, and industrial policy objectives while ensuring affordable energy 
for households and industry, Member States must consider market uncertainty and 
total costs. Member States with an existing nuclear fleet may conclude that lifetime 
extension  of current  nuclear reactors can be economically attractive, as part of the 
overall power generation portfolio. The cost-effectiveness of new build nuclear power 
is more uncertain and depends on the Member State’s and EU power  portfolio, its 
interconnectivity, and available flexibility. 

Section  2.2.2  considers  nuclear  energy’s  potential  to  provide  flexibility  to  the 
electricity  system.  As  a  dispatchable  power  source,  nuclear  energy  contributes  to 
balancing demand and supply, in particular at longer timescales such as weekly and 
monthly. This way, nuclear energy may facilitate further deployment of renewables, 
the phase-out of fossil generation assets, and it may contribute to dampening short-
term price volatility (20). 

In addition, section 2.2.3 reflects on needs for EU-wide coordination. 

2.2.1. 

System integration 

A  common  set  of  challenges  arises  linked  to  the  rapid  decarbonisation  and 
electrification of the economy, economy combined with an increased decentralisation 
of production, such as grid and system integration, flexibility, storage, and congestion 
management.  These  issues  will  impact  the  overall  system  associated  with  the 
decarbonisation, and significant investments are needed in networks and flexibility to 
accommodate an efficient integration in power systems.  

Nuclear  energy  comes  at  high  upfront  capital  costs.  However,  deploying  nuclear 
energy may allow for savings in the system elsewhere, i.e. through lower investment 
needs  for  transmission,  distribution,  and  storage  infrastructure.  Integrating  nuclear 
energy may provide complementary means for flexible and decarbonised generation, 
enabling system  integration, as studies have shown for the EU (21) and for France 
specifically  (22).  Power  system  integration,  technological  progress,  speed  of 
deployment,  and  costs  improvements  along  the  deployment  of  different  clean 
technologies will determine the relative competitiveness of nuclear energy.  

An illustration is shown in Figure 10, from a study on the Polish case of power system 
expansion (23). The study’s base scenario considers introducing nuclear energy to the 
Polish power system. The study compares the resulting total system costs in the base 

(20)   Nuclear energy may contribute to frequency control. However, this aspect is outside of the scope of 

this section’s analysis.  

(21)   Compass Lexecon Report, 2024. Pathways to 2050 - the role of nuclear in a low-carbon Europe.  

(22)   RTE, 2021. Futurs énergétiques 2050 – Energy Pathways to 2050. 

(23)   Quantified Carbon for Clean Air Task Force, 2023. Power System Expansion Poland.  

16 

 
 
scenario  with  several  alternative  scenarios  (24).  Scenarios  including  nuclear 
deployment  are  generally  at  the  lower  end  of  the  total  system  cost  distribution. 
However, the least-cost scenario is one without nuclear deployment. In this scenario, 
the Polish energy system relies more on imports and experiences higher electricity 
prices than in the base scenario (25).  

Figure 10 – Total cumulative system costs for 2030 to 2050 in selected scenarios in Poland, 

by technology 

Source:  Quantified Carbon for Clean Air Task Force, 2023. Power System Expansion Poland, Figure 

26, p. 64, cf. footnote (20) 

Notes: 

CC = combined cycle; CCS = carbon capture and storage; OC = open cycle; VRE = variable 
renewable energy. 

Figure 11 shows findings from a study by the French electricity transmission system 
operator RTE of the potential evolution of the French electricity system until 2060. 
RTE’s  “study  concludes  with  a  fair  degree  of  confidence  that  the  scenarios  that 
include a nuclear fleet of at least 40 GW (N2 and N03) may, over the long term, result 
in  lower  costs  for  society  than  one  based  on  100%  renewables  and  large  energy 
farms. This is true even if “gross” production costs are higher on average for new 
nuclear plants than for large renewable energy farms. Indeed, the integration of large 
quantities of wind turbines or solar panels creates a very significant need for flexible 
resources (storage, demand side management and new backup plants) to offset their 
variability,  as  well  as  for  grid  strengthening  (connection,  transmission  and 

(24)   See Quantified Carbon for Clean Air Task Force, 2023. Power System Expansion Poland, pp.15-16 

for scenario descriptions.   

(25)   Quantified Carbon for Clean Air Task Force, 2023. Power System Expansion Poland, pp.64-65 

17 

 
 
 
distribution).  Once  all  these  costs  are  factored  in,  the  scenarios  that  include  new 
nuclear reactors appear more competitive.” (26) 

Figure 11 – Annualised full costs in France per scenario in 2060 

Source:  RTE, 2021. Futurs énergétiques 2050 – Energy Pathways to 2050, p. 31. 

Notes: 

The scenarios N2 and N03 include a nuclear fleet of at least 40 GW. 

2.2.2. 

Flexibility 

One  important  factor  contributing  to  lower  power  system  costs  is  the  increase  of 
flexibility and storage solutions. In the EU, flexibility requirements are expected to 
increase  across  all  timescales  (daily,  weekly,  and  seasonal),  with  flexibility  needs 
estimated to equal 30% of total electrical EU demand in 2050, up from 24% in 2030 
and 11% in 2021 (27). A range of solutions, such as interconnectors, storage (mostly 
batteries),  dispatchable  generation,  and  demand-side  flexibility  may  supply 
flexibility.  

In principle, the economics of nuclear power investments favour the use for baseload 
generation.  Nevertheless,  in  the  EU,  nuclear  power  plants  often  allow  for  load 
following (28) (29). Indeed, according to the current version of the European Utility 
Requirements (EUR) (30) nuclear power plants must be capable of daily load cycling 
operation, from 100% nominal power (Pr) down to the minimum operating level of 

(26)   RTE, 2021. Futurs énergétiques 2050 – Energy Pathways to 2050, p. 30.  

(27)   Koolen, D., De Felice, M. and Busch, S., 2023.  Flexibility requirements and the role of storage in 

future European power systems, JRC130519. 

(28)   Non-Baseload Operation in Nuclear Power Plants, IAEA Nuclear Energy Series No.  NP-T-3.23, © 

IAEA, 2018. 

(29)   Grünwald et Caviezel, 2017. Lastfolgefähigkeit Deutscher Kernkraftwerke, Büro für Technikfolgen-

Abschätzung des deutschen Bundestags (TAB). 

(30)   European Utility Requirements, Document REV E Volume 2 – Chapter 2 – performance requirement 

section 2.2. 

18 

 
 
 
the Unit (31), with a rate of change of electric output of 3-5 % of Pr/min (32). Moreover, 
they  provide  frequency  control  services  to  the  transmission  grid  operator (33).  To 
quantify the potential flexibility  contribution  of nuclear, the METIS power system 
model is applied here, modelling flexibility needs in energy volume in the year 2030. 
Figure  12  indicates  that  in  Member  States  with  a  significant  amount  of  nuclear 
capacity installed, nuclear energy will play a considerable role in providing flexibility. 
While the exact importance of nuclear depends on the availability and cost of other 
flexibility  solutions  in  the  system,  nuclear  may  primarily  address  the  weekly 
flexibility  needs,  for  instance  in  view  of  adapting  to  meteorological  forecasts  and 
longer-term monthly flexibility needs, as these are costly to address by current clean 
storage and flexibility solutions such as batteries and demand side response. 

Figure 12 – Contribution of nuclear energy to daily, weekly and monthly flexibility needs in 

energy volume in the EU and selected Member States in 2030 

Source:  Commission analysis based on METIS energy model. 

Notes: 

The  methodology is  further  explained  in  Koolen,  D.,  De  Felice,  M. and  Busch,  S.,  2023. 
Flexibility  requirements  and  the  role  of  storage  in  future  European  power  systems, 
JRC130519. It follows a generalised approach of the proposed methodology for estimating 
"RES integration needs", as submitted by the European Network of Transmission System 
Operators for Electricity (ENTSO-E) and the European Distribution System Operators Entity 
(EU DSO Entity) to ACER, looking at both positive and negative needs. 

Already today, nuclear reactors provide considerable flexible capacity. As shown in 
Figure 13, the French nuclear electricity generation fleet provides for modulation on 

(31) 

Light water reactors are capable of continuous operation between 50% and 100% of their rated power 
Pr. Some designs can be operated at a lower ratio of the rated power (typically down to 20%) during 
certain phases of the fuel irradiation cycle.  

(32)   The Unit* should be capable to go through the following number of load scheduled variations, each 
variation being defined as a transient from full power to minimum load and back to full power: (a) 2 
per day; (b) 5 per week; and (c) cumulatively 200 per year.  

(33)   Sustainable  Nuclear  Energy  Technology  Platform,  2020.  Load  following  capabilities  of  Nuclear 

Power Plants. Nuclear Energy Factsheets. 

19 

 
 
 
the  short  and  long-term  timescale (34).  The  French  nuclear  fleet’s  contribution  to 
flexibility  at  the  daily  timescale  has  increased  in  recent  years.  Factors  such  as 
relatively  low  demand,  strong  hydro  and  ample  solar  generation  (incl.  from 
neighbouring countries) caused a strong modulation of the nuclear fleet in 2024 (35). 
The French transmission system operator RTE estimates that there is a clear inverse 
correlation between the degree to which France will need additional flexible capacity 
in the future and the share of nuclear energy generation in the system (36).  

Figure 13 – Normalised nuclear electricity generation in France, daily (left) and monthly 

(right) timescale 

Source:  Commission analysis based on ENTSO-E. 

Notes: 

2022 excluded due to exceptional outages. 

Finally,  the  integration  of  nuclear  capacity  may  provide  benefits  in  terms  of  price 
volatility. While the effect of nuclear power on energy spot prices may be relatively 
limited, as nuclear energy is seldom the marginal producer setting the price, there is 
a  correlation  between  decreased  supply  and  increased  demand  pushing  up  energy 
prices.  

2.2.3. 

Need for EU-wide coordination 

Deploying  nuclear  energy  can  reduce  total  system  costs  domestically,  as  RTE’s 
analyses show for France (section 2.2.1), but there can also be cross-border effects. 

(34)   P. Morilhat et al., 2019. Nuclear Power Plant flexibility at EDF, HAL open science. The study notes 
that French nuclear power plants (PWR 900 and 1,300) use “grey” control rods, which are specially 
adapted  for  plant  flexibility.  Whereas  most  nuclear  reactors  are  still  fitted  with  standard  “black” 
control rods, “grey” control rods are designed to have lower neutron absorption, allowing adjustment 
to local power patterns. 

(35)   For example, average daily ramping capacity of the nuclear French fleet  was around 4 GW in July 

2024, mainly corresponding to an increase in solar generation (based on ENTSO-E). 

(36)   RTE, 2021. Futurs énergétiques 2050 – Energy Pathways to 2050. 

20 

 
 
 
Figure 14 below groups EU Member States into four categories: nuclear versus non-
nuclear  Member  States  and  net  exporters  versus  net  importers.  Among  the  net 
exporters the nuclear countries outnumber the non-nuclear ones almost consistently, 
in  particular  in  recent  years.  Among  the  net  importers,  the  non-nuclear  countries 
outnumber the nuclear ones. While a more granular analysis of electricity trade flows 
may provide  further  insights,  the fact  that net  exporters are predominantly nuclear 
countries suggests that deploying nuclear energy may contribute to system integration 
in adjacent countries, and possibly yield further system benefits there, too.  

Figure 14 – Net exporters and importers of electricity, 1990 – 2023 

Source:  European Commission analysis based on Eurostat data. 

Notes:  The figure considers all 27 EU Member States; however, Ireland was not trading electricity 
before  1995,  and  Malta  not  before  2015.  Cyprus  is  not  yet  connected  to  the  European 
mainland. The figure considers the electricity trade balance with all interconnected markets, 
including non-E  M      S     . I                                                    “       ” 
if  there  is installed nuclear  power  generation capacity.  The net  exporters  are  blue,  the net 
importers yellow. The nuclear countries are the darker shades at the edges (top and bottom), 
the non-nuclear countries are the lighter shades in the middle. 

Cross-border effects on total system costs call for EU-wide coordination of the further 
development of the European energy system with a view to keep total system costs as 
low as possible, while achieving decarbonisation and energy security. 

21 

0510152025301990199119921993199419951996199719981999200020012002200320042005200620072008200920102011201220132014201520162017201820192020202120222023Number of countriesnuclear net exportersnon-nuclear net exportersnon-nuclear net importersnuclear net importers 
 
 
3.  BEYOND ELECTRICITY GENERATION 

The role of nuclear technology extends beyond pure electricity generation, both for 
energy supply and non-energy day-to-day applications. In the energy system, nuclear 
energy  plays  a  role  in  providing  heat  to  households  and  to  the  industry  –  this  is 
developed in section 3.1. In the medical field, nuclear technology is indispensable for 
diagnostics  and  treatments  –  this  is  developed  in  section  3.2  with  a  focus  on 
radioisotopes.  

Furthermore, there exist concepts for innovative spacecraft propulsion systems using 
nuclear energy. The European Space Agency (ESA) commissioned a project, which 
aims to harness the potential of Nuclear Electric Propulsion for space missions with 
a view to strengthen European autonomy in this sector (37). The anticipated benefits 
of nuclear propulsion systems include a much faster travel speed, which will allow 
humanity to explore deeper into space. 

3.1.  Heat supply 

3.1.1. 

Present and future role of nuclear in the energy system 

The transition to a green-house gas (GHG) neutral economy by 2050 is characterised 
by a shift away from carbon-intensive technologies and a significant electrification of 
key demand sectors (38). In the EU, the share of electricity in final energy demand is 
projected to increase from currently 22% to 57% in 2050 (39). The total  electricity 
generation is projected to more than double during the same time (40). The existing 
nuclear fleet as well as new projected investments, both on EU level and globally aim 
predominantly  at  supplying  electricity  (41).  Yet,  nuclear  energy-based  solutions 
providing heat to end users in the industry and household sectors already exist today 
(42) (43). 

(37)   Concepts  for  nuclear  energy-based  spacecraft  propulsion  systems  may  include  fission  or  fusion 
technology (cf. Section 5.2). As part of the ESA-commissioned “RocketRoll”-project, a consortium 
led  by  Tractebel  that  includes  the  French  Alternative  Energies  and  Atomic  Energy  Commission 
(CEA), ArianeGroup, Airbus and Frazer Nash defined a comprehensive technology roadmap to equip 
Europe with advanced propulsion systems capable of undertaking long-duration missions, including 
manned expeditions to Mars. Several start-ups explore the spacecraft propulsion use case for fusion 
energy, see CNN (April 3, 2025): Nuclear-powered rocket concept could cut journey time to Mars in 
half.  

(38)   Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic and Social Committee and the Committee of the Regions: Securing our future, Europe’s 
2040 climate target and path to climate neutrality by 2050 building a sustainable, just and prosperous 
society, COM(2024) 63 final.  

(39)   SWD(2024) 63, Figure 32 

(40)   SWD(2024) 61, Figure 19 

(41)  

IEA (2024), World Energy Outlook 2024, IEA, Paris, World Energy Outlook 2024. 

(42)   NEA (2022). Beyond Electricity: The Economics of Nuclear Cogeneration, NEA Report No. 7363, 

Paris. 

(43)   Leurent et al. 2017. Driving forces and obstacles to nuclear cogeneration in Europe: Lessons learnt 

from Finland, Energy Policy, Vol. 107, pp. 138–150. 

22 

 
 
 
3.1.2. 

Nuclear heat use cases 

The European Industrial Alliance on SMRs aims at decarbonising sectors with hard-
to-abate  emissions  (44).  This  includes  heat  for  industry  and  households,  delivered 
though heat networks or in the form of hydrogen, cf. also section 5.1.  

Many  industrial  processes  rely  on  the  availability  of  high  temperature  heat  which 
today is largely generated from fossil fuels. The demand for industrial process heat in 
the EU is around 1900 TWh (see Figure 15), of which 960 TWh on temperature levels 
of 500°C – 1000°C (45) (46) (47). Options exist to directly electrify most industrial heat 
applications  except  for  steel  production  from  iron  ore,  which  could  make  use  of 
hydrogen as a chemical reduction agent. In line with the projected electrification of 
demand sectors, studies see the demand of high temperature heat dropping by 40% to 
about  620 TWh  in  2050.  Hydrogen  will  be  key  for  decarbonising  this  remaining 
demand for high temperature heat and feedstock in industry with a total production 
projected to reach 2000 TWh in 2050 (48). In the considered scenario, about 40% of 
the hydrogen produced in 2050 will be further transformed into renewable fuels of 
non-biological  origin. About  11% (213 TWh) of the hydrogen produced  would be 
used in industry.  

(44)   European Industrial Alliance on Small Modular Reactors – European Commission. 

(45)   Agora, 2024. Direct electrification of industrial process heat. 

(46)   Rehfeldt et al., 2018. A bottom-up estimation of the heating and cooling demand in European industry, 

Energy Efficiency 11, pp. 1057–1082. 

(47)   European Commission, 2023. METIS 3, Study S5, The impact of industry transition on a CO2-neutral 

European energy system.  

(48)   SWD (2024) 63, Figure 31. 

23 

 
 
Figure  15  –  Projected  total  energy  demand  in  industry  in  2018  and  2050  by  end-use 

(EU27+UK, 2018 and 2050) 

Source:  METIS 3 project description. 

Notes: 

Feedstock = energy carriers used as raw materials in the chemical industry. 

Use cases  for nuclear heat  can be categorised by the temperature level  of the heat 
provided. Heat from nuclear power plants has already been used or considered for 
district heating, the chemical industry or water desalination (49) (50). Nuclear designs 
capable  of  producing  high  temperature  heat  could  be  deployed  in  the  chemical 
industry or to produce hydrogen via high-temperature electrolysis (51), reducing both 
the electricity and the overall energy requirements of the process as compared to low-
temperature electrolysis of water. Specifically designed nuclear cogeneration plants 
could provide both heat and electricity for industrial sites. Optimising the utilisation 
of both electricity and heat to produce different shares of hydrogen and electricity or 
by storing high temperature heat in molten salt could allow running a fleet of high 
temperature  reactors  at  high  load  factors  in  a  system  largely  based  on  renewable 
sources (52).  

Reactor concepts capable of providing high temperature heat already exist (53) and 
have been demonstrated. The potential rollout of a fleet of advanced reactors to supply 
high  temperature  heat  for  certain  industrial  sectors  or  low  temperature  heat  for 
industry or district heating is addressed in section 5.1. How much of this potential 
could materialise will depend on the relative competitiveness, government support, 
location  of  heat  supply  and  demand,  and  the  availability  of  other  competing 

(49)   Nuclear-Renewable Hybrid Energy Systems, Nuclear Energy Series, NR-T-1.24, © IAEA, 2023. 

(50)   Small Modular Reactors, Advances in SMR Developments, IAEA International Conference on Small 

Modular Reactors and their Applications, 21-25 October 2024, IAEA, Vienna, Austria. 

(51)  

Industrial Applications of Nuclear Energy, Nuclear Energy Series No. NP-T-4.3, © IAEA, 2017. 

(52)   Matthews et al. 2024, The Road to Net Zero, Renewables and Nuclear Working Together, Manchester 

University Dalton Institute 

(53)   HTGR development in JAEA: HTTR, accessed on 16 March 2025. 

24 

                                                   b           b   o         d   o      oo                  o                     o                                   d o                        d  o         b           b   o         d   o      oo                  o                     o                                   d o                        d  o                                                                 d                   d o           ood  d       d  ob   o  o    d       o      o          o                     od           o          d        d         
 
 
technologies  to  generate  electricity  and  hydrogen.  In  this  context,  several  research 
projects  on  nuclear  heating  and  cogeneration  have  been  supported  through  the 
Euratom Research and Training Programme (54).  

3.2.  Radioisotopes 

Radioisotopes,  as  well  as  stable  isotopes  (55),  play  an  important  role  in  various 
industrial applications and in healthcare. 

3.2.1. 

The use of medical radioisotopes 

Radioisotopes  are  indispensable  for  diagnosis  of  cancer,  cardiac,  pulmonary, 
neurological and other diseases, and are increasingly important for cancer therapy. It 
is  therefore  important  to  strategically  secure  long-term  supply  of  medical 
radioisotopes in the EU, maintaining the sectoral EU competitiveness and ensuring 
patients’ access to vital medical procedures. 

In 2021, cancer was the second leading cause of death in the EU, with 1.1 million 
deaths,  which  equated  to  21.6  %  of  the  total  number  of  deaths  in  the  EU  (56).  In 
Europe, the economic burden of cancer is estimated at EUR 100 billion, and without 
decisive action cancer cases are expected to increase by 19% until 2040 and cancer 
deaths by 27% (57).  

In  the  EU,  more  than  1,500  nuclear  medicine  centers  perform  about  10  million 
procedures each year, with about 100 different radioisotopes (58). Diagnostic imaging 
is  most  of  these  procedures (59).  However,  the  strong  increase  in  the  therapeutic 
procedures  observed  in  the  past  few  years  is  expected  to  continue  in  the  coming 
years (60). Moreover, modern targeted therapies (also known as ‘radioligand therapy’) 
are particularly intended for refractory cancer where patients do not respond to other 
treatments and can be combined with a nuclear diagnostic test in a novel ‘theranostics’ 
approach.  Figure  16  shows 
for 
radiopharmaceutical/radioligand  therapies  in  the  EU-27  trends  to  triple  in  the  next 
decade (around 130,000 in 2025 against 400,000 in 2035). 

the  number  of  eligible  patients 

that 

(54)   TANDEM  (Small Modular ReacTor for a  European sAfe aNd Decarbonized Energy Mix),  SANE 
(Safety Assessment of Non-Electric Uses of Nuclear Energy), and EASI-SMR (Ensuring Assessment 
of Safety Innovations for Small Modular Reactors). 

(55)   A  radioisotope  is  an  unstable  form  of  a  chemical  element  which  emits  radiation until  it  reaches a 

stable status (stable isotope). 

(56)   A cancer plan for Europe; Cancer statistics - Statistics Explained - Eurostat 

(57)   ECIS - European Cancer Information System  

(58)   European  Commission:  Joint  Research  Centre,  Mario,  N.,  Kolmayer,  A.,  Turquet,  G.,  Goulart  De 
Medeiros, M. et al., Study on sustainable and resilient supply of medical radioisotopes in the EU, 
Goulart De Medeiros, M.(editor) and Joerger, A.(editor), Publications Office of the European Union, 
2022, https://data.europa.eu/doi/10.2760/911131 

(59)   MedRaysIntell, Nuclear Medicine Report & Directory Edition 2024 

(60)   As shown in Figure 16, the number of patients eligible for radioligand therapy is expected to triple 
from 2022 to 2035. Source:  JRC own research (not published), reproduced with permission of the 
author 

25 

 
 
Figure 16 – Estimated evolution of the number of eligible patients for radiopharmaceutical / 

radioligand therapies in the EU-27 until 2035 by cancer type 

Source: 

JRC own research (not published), reproduced with permission of the author. 

Notes: 

For each year, the left columns present the lower and the right columns the upper estimate. 

3.2.2. 

The global radioisotopes market and supply chain 

Radioisotopes are mainly produced by irradiation in research reactors, where target 
material  is  bombarded  with  particles  such  as  neutrons  or  protons,  then  chemically 
processed into the required chemical form. As shown in Figure 17 below, Europe is 
a global leader in that market, consistently providing more than 65% of the global 
irradiation services (61), with strong export position. The main European producers of 
radioisotopes  for  the  global  market  are  research  reactors  and  associated  facilities 
located in the Netherlands, Belgium, Poland, and Czechia.  

Radioisotopes are also produced for local use  – utilising smaller research reactors, 
particle accelerators and medical cyclotrons – in most EU Member States. Production 
in nuclear power reactors has started in Canada and is also being considered in the 
EU (62). 

(61)  

JRC,  “Study  on  sustainable  and  resilient  supply  of  medical  radioisotopes  in  the  EU  –  Diagnostic 
Radionuclides” (2021), updated by NucAdvisor (2024). 

(62)   The  future  production  of  Lutetium-177  in  a  Romanian  reactor  has  been  recently  announced: 
Framatome  and  Nuclearelectrica  take  the  next  step  in  producing  cancer-fighting  Lutetium-177  in 
Romania - Framatome 

26 

 
 
 
Figure 17 – Share of the global market for irradiation services for radioisotope production 

Source: 

JR    “S                                                                                    E   – 
D          R            ” (    )                A       (    ). 

The transport of medical radioisotopes is a key element within the supply chain. Their 
production is concentrated in few Member States and their short half-lives impose 
tight  schedules  that  may  be  impacted  by  disruptions  and  delays.  Despite  a  well-
established regulatory framework at international level, its practical implementation 
often poses challenges, in particular for the mutual recognition of shipment containers 
and licensed carriers among countries. The transport sector should also adapt to the 
increasing demand for these specialised services in the coming years.  

Despite its leadership position in production and supply of medical radioisotopes, the 
EU is dependent on foreign supply of source materials and suffers from supply chain 
fragility due to ageing of its indigenous irradiation facilities. 

Russia is the sole supplier of certain stable isotopes, which are indispensable as source 
material to produce key radioisotopes for cancer therapy (63). Existing stocks held by 
radioisotope  producers  have  so  far  averted  severe  supply  disruptions,  and  recently 
announced projects in the US, Canada, South Africa and elsewhere are expected to 
improve the global security of supply of these isotopes. However, there is a significant 
potential  to  leverage  existing  (pre-production)  technology  and  experience (64)  to 
develop indigenous production in the EU. 

High-assay  low-enriched  uranium  (HALEU)  is  used  in  research  reactors  as  fuel 
and/or as irradiation targets for production of the most significant radioisotopes in use 

(63)   This mostly concerns Yterbium-176 used to produce Lutetium-177, but other needs that cannot be 

met by the current European industrial technology and capacity may arise in the future. 

(64)   The main player is Orano, France. 

27 

 
 
 
today (65). Without homegrown production, HALEU is obtained from existing stocks 
in  the  US  which  should  run  out  by  mid/late-2030s (66).  The  US  and  the  UK  have 
important  projects  for  HALEU  production  underway (67)  (see  box  on  HALEU  in 
section 4.2.4), with first deliveries expected before 2030. In the EU, the sole needs of 
research reactors and radioisotopes production make it hard to justify an investment 
in a full HALEU fuel supply chain. Nevertheless, a limited investment in part of the 
supply chain – such as a small-scale metallisation facility of about 1 ton/year – could 
be economically viable and supportive to increasing the EU strategic economy. 

Moreover, the EU research reactors are ageing and will need major refurbishments to 
be gradually upgraded and partially replaced by about 2030.  

Production capabilities and new production technologies should be developed and put 
in place to diversify production means and increase the system resilience. 

3.2.3. 

Changes in the European Union nuclear infrastructures supporting 
the supply of medical radioisotopes 

Since  the  last  PINC  report  in  2017,  the  construction  of  new  research  reactors  has 
started or continued as shown in Figure 18 (68). 

Figure  18  –  Estimated  landscape  of  EU  research  reactors  for  medical  radioisotopes 

production 

Source: 

JR    “S                                                                                    E   – 
                         ” (    )                A       (    ) 

The European fleet of research reactors for radioisotopes production remains largely 
unchanged. At the time of the previous PINC, research reactors in the Netherlands 
(HFR),  Poland  (Maria),  and  Czechia  (LVR-15)  had  already  switched  to  HALEU 
fuels. Research reactors in Belgium (BR2), France (ILL), and Germany (FRM II) are 
yet undergoing the process of conversion to HALEU fuel. Several of these reactors 

(65)   Sections 4.3 on the Supply chain for nuclear installations life-cycle and 5.1 on SMRs address further 

this topic. 

(66)   ESA report on “Securing the European Supply of 19.75% Enriched Uranium Fuel”, May 2022,  

(67)   As part of the US and UK respective programmes to develop advanced nuclear power reactors and 

(re)develop their fuel cycle supply chains. 

(68)  

JRC, “Study on sustainable and resilient supply of medical radioisotopes in the EU  – Therapeutic 
radionuclides” (2022), updated by NucAdvisor (2024) 

28 

 
 
 
also  underwent,  or  are  undergoing  or  preparing  for,  Periodic  Safety  Reviews, 
modernisation and lifetime extension projects, and license extensions. 

Several  new  installations  are  under  construction.  The  PALLAS  reactor  in  the 
Netherlands,  which  is  estimated  to  be  operational  around  2030,  is  a  complete 
infrastructure  for  production  of  medical  radioisotopes  with  a  capacity  to  supply  to 
more than 30,000 patients per day. (69) The Jules Horowitz Reactor (RJH) in France 
is expected to bring additional radioisotope supply capacity on the market, although 
it is a multi-functional facility with no precise date for market entry.  

The MYRRHA (Multi-purpose hYbrid Research Reactor for High-tech Applications) 
facility in Belgium has launched the construction of its ‘Phase 1 / MINERVA’ particle 
accelerator. MYRRHA is intended for the production of “theranostic” radioisotopes. 
The Accelerator Driven System (ADS) consists in a subcritical nuclear reactor and a 
high-power linear accelerator, which is expected to deliver radioisotopes for medical 
applications as of 2027. 

3.2.4. 

Findings and recommendations 

The security of supply of radioisotopes for medical applications is key to  maintain 
and protect our European social model. Therefore, it requires that the EU strategic 
independence is pursued. 

Member States and, potentially, EU investment is needed to secure source materials 
industrial  capacity  reducing  foreign  dependencies.  The 
and  develop  new 
diversification and renewal  of the radioisotopes production facilities would further 
increase  the  resilience  of  the  supply  chain.  Dedicated  support  for  research, 
development and innovation is key for developing innovative treatments for cancer 
and bolstering the EU competitiveness in this area. A broader monitoring system on 
the demand and supply of medical radioisotopes is also deemed important to better 
inform the market and foster investments (70). 

In  2021,  the  Commission  published  the  SAMIRA  Action  Plan  (71)  as  part  of  the 
outcomes of Europe’s Beating Cancer Plan. This plan set in motion actions to support 
the safe and high-quality use of radiological  and  nuclear technology  in  healthcare, 
with  the  security  of  supply  of  radioisotopes  being  one  of  its  priority  areas.  Under 
SAMIRA,  the  Commission  started  a  process  towards  establishing  the  “European 
Radioisotope  Valley  Initiative”  (ERVI),  for  implementation  in  the  next  EU 
Multiannual Financial Framework.  

By the end of 2025, the Commission plans to adopt a Communication on ERVI as an 
EU  structure  aiming  to  increase  the  EU’s  domestic  production  of  medical 
radioisotopes, reduce EU dependency on foreign suppliers, in particular Russia, and 
improve  the  resilience  of  the  European  supply  chain,  taking  into  account  different 
needs  of  Member  States.  The  Commission  will  evaluate  the  infrastructure  and 

(69)   PALLAS 

(70)   Building  upon  the  European  Observatory  on  the  Supply  of  Medical  Radioisotopes,  which  is  co-

chaired by the Euratom Supply Agency (ESA) and industry. 

(71)   Commission  Staff  Working  Document  on  a  Strategic  Agenda  for  Medical  Ionising  Radiation 

Applications (SAMIRA), SWD(2021) 14 final. 

29 

 
 
financial needs of the European supply chain and make specific proposals on how to 
ensure better co-ordination and secure investment in this area (72). 

Member States have continuously supported and guided the Commission efforts to 
address  radioisotopes  supply  issues.  The  Council  of  the  European  Union  issued 
several sets of conclusions on this subject, most recently in June 2024 (73). Likewise, 
in May 2024, the European Economic and Social Committee issued their opinion (74). 

(72)  Roadmap  towards  ending  Russian  energy  imports,  COM/2025/440  final/2,  supports  also  these 

objectives.  

(73)   The security of supply of radioisotopes for medical use, Council conclusions, 17 June 2024.  

(74)   Europe’s  Beating  Cancer  Plan:  Driving  forces  for  the  security  of  medical  radioisotopes  supply, 

Opinion of the European Economic and Social Committee, C/2024/4661. 

30 

 
 
 
4.  ANALYSIS OF THE SUPPLY CHAIN 

To fulfil its potential, nuclear energy requires a robust and reliable supply chain that 
covers its entire life cycle. This section presents an analysis of the supply chain over 
the  whole  nuclear  energy  life  cycle.  The  analysis  focuses  on  two  main  areas:  the 
‘nuclear fuel cycle’ (discussed in Section 4.2), and the ‘nuclear installation life cycle’ 
(covered in Section 4.3). Both sections aim at providing an overview of the necessary 
components for an effective nuclear energy supply chain. 

4.1.  Overview 

The  ‘nuclear  fuel  cycle’  is  the  series  of  industrial  processes  that  involve  the 
production of energy from uranium in nuclear power reactors, see Figure 19. 

Figure 19 – Nuclear fuel cycle 

Source:  European Commission. 

Uranium is a relatively common element which is mined in a number of countries. 
Uranium must be processed (i.e. converted and enriched) before it can be used for 
manufacturing  nuclear  fuel  assemblies  to  be  exploited  in  a  nuclear  reactor.  Fuel 
assemblies removed from a reactor, after they have reached the end of their useful 
life, can be either reprocessed and recycled for new fuel or disposed of as nuclear 
waste, possibly after transmutation. These two options are commonly referred to as 
closed and open nuclear fuel cycle, respectively. 

design,  manufacturing, 

The ‘nuclear installation life-cycle’ is the series of industrial processes that involve 
and 
construction, 
the 
decommissioning  of  any  nuclear  installations  (i.e.  power  reactors  as  well  as  other 
nuclear fuel cycle facilities) or associated equipment, see Figure 20. 

operation,  maintenance, 

31 

                                                                                                                                                                                            
 
 
 
 
Figure 20 – Nuclear installation life-cycle 

Source:  European Commission. 

The nuclear industry in the EU covers to varying extents all stages of both the ‘nuclear 
fuel cycle’ and the ‘nuclear installation life-cycle’. The EU industrial capacity in the 
nuclear energy sector has a crucial role to play in security of supply provided that 
adequate diversification of supplies is guaranteed. 

The  extent  to  which  scenarios  described  in  section  2.1  will  realise,  eventually,  is 
essentially bound to a robust, reliable and interlinked EU supply chain. This has to be 
achieved in  a context when the EU nuclear industry faces a complex landscape of 
risks.  Politically, acceptance of nuclear power remains mixed, with  some Member 
States  opposing  nuclear  expansion.  Geopolitical  risks  also  affect  the  supply  chain 
industry,  particularly  in  relation  to  dependencies  on  non-EU  suppliers  for  critical 
materials or components. 

The analysis in sections 4.2 and 4.3 aims at identifying gaps and areas to focus on and 
where Member States should consider further investments to accomplish their plans 
(75). 

4.2. 

Supply chain for the nuclear fuel cycle 

This section analyses the several steps of the ‘nuclear fuel cycle’ with a view on the 
status quo (compared to the status quo at the time of the previous PINC) and future 
projections of the nuclear fuel market. Information and data underpinning the analysis 
are mainly  derived from the Euratom Supply  Agency (ESA) (76). Other sources of 
data are specifically indicated when used. 

ESA performed analyses of conversion and enrichment markets based on information 
Euratom  utilities  reported  directly  to  the  agency  in  2023  as  part  of  ESA’s  annual 
survey, and based on the generation capacity forecast presented in section 2.1. ESA 
also relied on data published by the World Nuclear Association (WNA) and industry 
data. 

(75)   Addressing  investment  needs  will  require  further  discussion  and  alignment  with  several  Member 

States. 

(76)   Euratom Supply Agency - European Commission 

32 

                                                                                                                       
 
 
Demand  projections  for  EU  Member  States  are  based  on  generation  capacity 
projections, which include currently operating reactors, LTO plans, and new builds 
indicated by Member States in their National Energy and Climate Plans (NECPs), see 
section 2.1. Other region’s projections are based on industry reports. 

Current capacity of service providers is based on data available in industry reports 
and  industry  consultations,  as  well  as  public  announcements  concerning  the 
investments plans in capacity extension (77). 

Most nuclear reactors use fuel made from low-enriched uranium (LEU), where the 
share of the fissile U-235 isotope has been enriched to between 3% to 5% (78). Fuel 
for  some  advanced  reactor  designs  (see  Section  5.1)  or  the  production  of  some 
medical radioisotopes (see Section 3.2) requires a higher concentration of U-235. In 
high-assay low-enriched uranium (HALEU), the U-235 isotope has been enriched to 
greater than 5% and less than 20% (79). Some other new reactor designs in particular 
Advanced Modular Reactors (AMRs) which are based on fast reactor technologies 
e.g. Sodium Fast Reactors (SFR) or Lead Fast Reactors (LFR) also use different types 
of higher enriched fuel such as Mixed Oxide (MOX) which is composed of uranium 
oxide  (UO₂)  and  plutonium  oxide  (PuO₂).  Some  AMRs  based  on  Molten  Salt 
Technology (MSR) can use low-enriched uranium (U-235 or U-233) fuels dissolved 
in the molten salt mixture or can incorporate plutonium as fissile material, either alone 
or in combination with uranium. Some MSR designs propose using Thorium as a fuel 
source. This section focusses on the supply chain for the LEU fuel cycle and provides 
information on HALEU in a dedicated box. 

4.2.1. 

Mining and milling 

Uranium is mined and milled across the globe in several regions and countries, such 
as Australia, Canada, Africa, and Asia. Kazakhstan accounts for more than 40% of 
the world’s uranium production, see Table 2. Uranium mining within the European 
Union has significantly declined over the past few decades (80), leading to a heavy 
reliance on imports to meet the regional demand. 

(77)   This analysis does not reflect investment notifications submitted to the Commission pursuant to Art. 

41 of the Euratom Treaty.  

(78)   Uranium found in nature consists largely of two isotopes, U-235 and U-238. The production of energy 
in  nuclear  reactors  is  from  the  ‘fission’  or  splitting  of  the  U-235  atoms,  a  process  which  releases 
energy in the form of heat. U-235 is the main fissile isotope of uranium. Natural uranium contains 
0.7%  of  the  U-235  isotope.  The  remaining  99.3%  is  mostly  the  U-238  isotope,  which  does  not 
contribute  directly  to  the  fission  process  (though  it  does  so  indirectly  by  the  formation  of  fissile 
isotopes of plutonium). Isotope separation is a physical process to concentrate (‘enrich’) one isotope 
relative to others. Most reactors require uranium to be enriched from 0.7% to between 3% to 5% U-
235 in their fuel. This is normal low-enriched uranium (LEU). Source: Uranium Enrichment - World 
Nuclear Association 

(79)   High-Assay Low-Enriched Uranium (HALEU) - World Nuclear Association 

(80)   Whenever uranium mining and milling is pursued it “[…] produces large amounts of very low-level 
waste due to formation of waste rock dumps and/or tailings. These dumps and tailings are located 
close  to  the  uranium  mines  and  the  related  ore  processing  plants  and  their  environmentally  safe 
management  can  be  ensured  by  the  application  of  standard  tailings  and  waste  rock  handling 
measures.”, cf, the related JRC study. Another aspect of this challenge is ensuring adequate working 
conditions  for  uranium  mine  and  mill  workers,  including  compensation,  safety,  and  responsible 
management of radiological exposure. 

33 

 
 
Table 2 – Production of natural uranium (in tonnes of uranium equivalent) 

Country 
Kazakhstan 
Canada 
Namibia 
Australia 
Uzbekistan 
Russia 
Niger 
China 
Others 
South Africa 
Ukraine 
USA 
Total  
% of world demand 

2016 
24,689 
14,039 
3,654 
6,315 
3,325 
3,004 
3,479 
1,616 
662 
490 
808 
1,125 
63,206 
96% 

2017 
23,321 
13,116 
4,224 
5,882 
3,400 
2,917 
3,449 
1,692 
506 
308 
707 
940 
60,462 
93% 

2021 
21,819 
4,693 
5,753 
4,192 
3,520 
2,635 
2,248 
1,600 
695 
192 
455 
8 
47,810 
76% 

2022 
21,227 
7,351 
5,613 
4,553 
3,300 
2,508 
2,020 
1,700 
708 
200 
100 
75 
49,355 
74% 

Source:  Data from the WNA and specialised publications. 

Notes: 

Because of rounding, totals may not add up.   
2023 data not available at the date of publication of the report. 

Global primary uranium production, i.e. uranium sourced through mining instead of 
e.g. recycling, accounted for about 49,355 tU in 2022. The 2023 production estimate 
is at the same level. This figure satisfies approximately 75%-80% of global demand. 
The remainer is satisfied from secondary sources, e.g. inventory drawdowns (81).  

A  joint  report  by  the  OECD’s  NEA  and  the  IAEA  estimates  global  uranium 
production  capacities  from  existing  and  committed  production  centres  at  69,675 
tU for 2025 (82). Uranium output has remained significantly below full capacity due 
to temporary mining suspensions in key producing countries, and higher production 
rates in the near term appear unlikely. 

ESA  reported  that  in  2023,  demand  for  natural  uranium  in  the  EU  accounted  for 
approximately 22% of global uranium requirements. In 2023, EU utilities purchased 
a total of 14,578 tU. 93% of these purchases took place under multiannual contracts, 
while spot contracts accounted for the remaining part. 

(81)   As with other energy minerals, imbalances between demand for uranium and primary production are 
traditionally bridged through inventory drawdowns, which can include commercial or government-
held  inventories.  In  the  case  of  uranium,  such  secondary  sources  may  –  depending  on  economic 
factors – also include depleted uranium upgrades, or natural uranium saved by uranium enrichers by 
means of underfeeding. 

(82)   NEA  (2023),  Uranium  2022:  Resources,  Production  and  Demand,  OECD  Publishing,  Paris. 
https://www.oecd-nea.org/jcms/pl_79960/uranium-2022-resources-production-and-demand  

34 

 
 
Table 3 – Origins of uranium delivered to EU utilities (in tonnes of uranium) 

2022 

Country 
Canada 
Russia 
Kazakhstan 
Niger 
South Africa, Namibia 
Australia 
Uzbekistan 
United States 
EU 
Total  
Source:  Euratom Supply Agency, Annual Report 2023. 

2,578 
1,980 
3,145 
2,975 
262 
327 
441 
0 
17 
11,724 

2023 

4,802 
3,419 
3,061 
2,089 
562 
372 
271 
4 
0 
14,578 

Notes: 

Because of rounding, totals may not add up. 

Figure 21 – Supply of uranium to EU utilities by origin (tU) 

Source:  Euratom Supply Agency, Annual Report 2023. 

In the past decade, until 2021, EU utilities received natural uranium supplies mainly 
from five countries: Canada, Russia, Kazakhstan, Niger, and Australia. In 2022 and 
2023, supplies from Australia decreased, and the other four countries supplied more 
than 94% of uranium to the EU, see Table 3 and Figure 21. A preliminary analysis of 
available  data  indicates  that  in  2024,  supply  from  Niger  and  Russia  decreased 

35 

 
 
substantially, while supplies from  Australia went  back to  2020 levels  and supplies 
from China appeared for the first time (83). 

Only  a  portion  of  the  recoverable  uranium  resource  base  can  be  extracted 
economically, as resources with mining costs above current market prices cannot be 
mined profitably. ESA monitors the market under its market observatory role (84).  

In  2023,  the  global  uranium  market  continued  to  face  challenges  due  to  Russia’s 
unjustified military aggression against Ukraine, the coup d’état in Niger, production 
issues, difficulties in transportation, and stronger demand, which influenced supply 
and demand and put upwards pressure on uranium prices, see Figure 22. 

Figure 22 – ESA average prices for natural uranium (EUR/kgU) 

Source:  Euratom Supply Agency - Annual Report 2023. 

Significant  portions  of  identified  resources  have  historically  remained  unextracted 
due  to  governments  not  granting  licenses  (for  example  in  Sweden).  The  rise  in 
uranium prices in the past four years spurred exploration and the reopening of several 
mines worldwide, increasing production capacity. In its forward-looking analysis of 
the  uranium  market,  the  World  Nuclear  Association  considers  several  factors, 
including decisions to extend the life of nuclear power plants, revisions of previous 
retirements, and non-power applications, as drivers to open new mines and to make 
new investments (85). 

The EU’s future demand for uranium will depend on the evolution of reactor capacity. 
If Member States’ plans materialise and the installed generation capacity increases 
until 2050, demand for uranium is likely to increase as well. This trend may be further 
reinforced by the potential deployment by SMRs and AMRs in the EU. The global 
demand  for  uranium  may  increase  more  steeply  until  2050,  given  the  nuclear 
programmes  in  emerging  economies,  e.g.  China  and  India.  All  else  equal,  these 
developments  will  put  upwards  pressure  on  uranium  prices,  and  thereby  create  an 

(83)   Source: Euratom Supply Agency. 

(84)   Market Observatory - European Commission 

(85)   WNA, Global Scenarios for Demand and Supply Availability 2023-2040 

36 

 
 
 
incentive  to  further  draw  down  inventories,  increase  production  rates  at  existing 
mines,  and possibly  explore further resources. Given that  existing  mines  produced 
below capacity in recent years, a potential supply inadequacy seems unlikely in the 
near term. As outlined in the REPowerEU Roadmap (86), the Commission intends to 
restrict new supply contracts co-signed by the Euratom Supply Agency for uranium 
as well as enriched uranium and other nuclear materials with Russian suppliers as of 
a certain date. Deliveries based on existing contracts will continue but prolongations 
as well as new supply contracts would no longer be approved by the Euratom Supply 
Agency.  In  addition,  the  Commission  intends  to  make,  in  June  2025,  a  legislative 
proposal with specific targets for Member States to: (i) replace Russian nuclear fuels 
with alternative fuels by accelerating the contracting and licensing of such fuels and 
developing further fully European alternatives; (ii) phase out reliance on Russia for 
uranium,  enriched  uranium  and  other  nuclear  materials;  and  (iii)  increase 
transparency on dependencies and encourage diversification of Russian supplies of 
spare parts and maintenance services. As part of this effort, Member States will also 
be required to develop and implement national plans that outline their specific actions 
and timelines. 

4.2.2. 

Conversion 

Uranium  conversion  is  a  crucial  step  in  the  nuclear  fuel  cycle,  which  transforms 
processed  uranium  ore  (uranium  oxide,  U₃O₈,  commonly  known  as  “yellowcake”) 
into a chemical form (most prominently UF6) suitable for enrichment and eventual 
use in nuclear reactors. 

There  is  a  small  number  of  uranium  conversion  facilities  worldwide,  see  Table  4. 
While the uranium conversion market underwent significant changes in the past, there 
was  no  previous  case  as  striking  as  the  recent  surge  in  prices.  In  the  period  from 
February 2022 until December 2023, the long-term unit price almost doubled, and the 
spot  unit  price  tripled.  This  trend  reflected  increasing  demand  from  western 
suppliers. (87)  

Table 4 – Commercial facilities for uranium conversion to UF6 (tonnes of Uranium as UF6) 

Company 

Country 

Nameplate 
capacity 

Planned additional 
capacity 

Orano 
CNNC 
ConverDyn 
Rosatom 
Cameco 
Cameco 
Total 

France 
China 
USA 
Russia 
Canada 
UK 

15,000 
15,000 
15,000 
12,500 
12,500 
0 
70,000 

21,000  (2025-2040) 

5,000  (2032-2034) 

26,000 

Source:  Euratom Supply Agency, https://converdyn.com/facility/. 

Notes: 

Information on conversion capacity in China is uncertain. ConverDyn suspended activities 
in 2017 and restarted in July 2023. 

(86)  Roadmap towards ending Russian energy imports, COM/2025/440 final/2. 

(87)   ESA - ESA Annual Report 2023 

37 

 
 
 
 
 
 
 
 
 
 
 
 
The only conversion plant in the EU – Orano’s “Philippe Coste” – has a nameplate 
capacity of 15,000 tU as UF6 annually. The actual production rate is not yet at the 
nameplate capacity; however, the production rate was ramped up over the past years 
and  the  current  output  estimate  is  at  around  75%  of  the  nameplate  capacity.  The 
company plans to ramp up the production to 90% of the nameplate capacity by 2029. 

The US-based firm ConverDyn current production estimates are at 9,000 tU per year 
at its Metropolis plant. ConverDyn’s declared a nameplate capacity of 15,000 tU in 
2007,  however  they  were  in  temporary  shutdown  from  2017  to  2023  due  to  poor 
market conditions.  

Based on available information,  conversion capacity in  China may have reached a 
total of 10,500 tU (evidence is limited as to actual output). It is sound to assume that 
China will develop indigenous conversion capacity to support an ambitious nuclear 
power development plan in the next decade and beyond. According to the Nuclear 
Fuel  Report  (2023),  uranium  demand  is  projected  to  reach  almost  50,000  tU  by 
2050 (62). This leads to the conclusion that conversion capacity will need to nearly 
triple by that time.  

Russian  (Rosatom)  capacity  has  varied  in  recent  years  due  to  upgrades  and 
refurbishments  at  Seversk,  but  capacity  is  supplemented  by  upgrading  tails  and 
underfeeding in order to generate UF6 (see the Box in Section 4.2.3 on underfeeding). 
Existing  nameplate capacity could  be 16,000 tU  per year, but  a more conservative 
estimate (based on limited refinement capacity) is 12,500 tU per year. 

Table 5 – Provision of conversion services to EU utilities in 2023 (tonnes of Uranium as UF6) 

Source:  Euratom Supply Agency Annual Report 2023. 

Notes: 

Because of rounding, totals may not add up. 

The backward analysis and the assessment of the present state of the global market of 
conversion services highlight the need for higher strategic independency at EU level 
to support the competitiveness of EU industry, see Table 5. A preliminary analysis of 
available data indicates that in 2024 the share of conversion services provided to EU 
utilities  from  Russia  decreased  from  27%  to  23%,  and  the  equivalent  share  was 
covered from Chinese supply. The forward analysis presented here below (see Figure 
23)  provides  an  assessment  of  potential  vulnerabilities  in  the  supply  vs  demand 
balance until 2050 on a global scale. 

Based on current plans, the domestic conversion capacity will be barely sufficient to 
meet EU demand through to 2050, with no margin against the ‘base case’ scenario 
presented in Section 2.1. Moreover, there are two main elements to consider which 
may  importantly  reduce  the  domestic  supply  actually  available  to  EU  utilities:  (i) 
realisation of the ‘high-capacity’ scenario whereby the EU conversion capacity will 

38 

ConverterQuantityShareOrano3,83429%Rosatom3,54327%Cameco2,52519%ConverDyn2,44818%Unspecified 1,0138%Total 13,364 
 
be definitely  insufficient; and (ii) commercial commitments undertaken by the EU 
producers with customers outside the EU. 

Extending the analysis to Western Europe, Ukraine, North America, Japan and South 
Korea the gap analysis shows that missing supply capacity exceeds 10,000 tU as UF6 
annually.  Taking  planned  expansions  of  conversion  capacity  into  account,  the  gap 
may decrease to a bit more than 1,500 tU annually by 2034. However, in absence of 
further  investments  in  expanding  conversion  capacity  in  the  ‘West’,  the  gap  will 
increase again and may reach more than 10,000 tU annually by 2050. 

The  capacity  gap  can  be  mitigated  by  secondary  sources  of  UF6,  particularly 
inventories held by utilities. Nevertheless, in the long run, there will be insufficient 
capacity  to  convert  enough  uranium  to  meet  the  demand  from  Western  reactors. 
Inventories held by EU utilities — primarily in the form of already converted uranium 
(UF6), enriched UF6, and fresh fuel — can sustain EU reactors for approximately two 
years. 

The remaining demand is currently satisfied by other suppliers, such as those from 
Russia,  and  by  secondary  sources.  It  is  important  to  underline  that  if  there  was  a 
sudden supply interruption, alternative sources such as reprocessing and MOX fuel 
would be insufficient to cover the gap, given the limited inventories. This underscores 
the need to expand further conversion capacity in the West and in the EU, also with a 
view to achieve the REPowerEU objective of diversifying energy supplies. 

The  gap  analysis  on  the  global  scale  shows  a  strong  deficit  to  supply  all  existing 
nuclear reactors. That deficit is set to increase, if no further investments in conversion 
capacities are pursued at global level.  

Investments for expansion of existing conversion facilities ranges around EUR 600 
million per additional capacity of 1,000 tU as UF6 annually. Beside the critical need 
for strategic autonomy, there are also market opportunities for EU industrial operators 
to seize justifying further investments. 

39 

 
Figure 23 – Global demand for conversion services vs supply capacity projections. (tU as 

UF6 per year) 

Source:  Euratom Supply Agency.  

Notes: 

The stacked areas representing demand are additive, i.e. global demand is given by the 
blue, green, and red areas 

4.2.3. 

Enrichment 

Uranium enrichment is a vital step in the nuclear fuel cycle. The enrichment process 
separates a uranium gaseous flow into two streams,  one being  enriched in  ‘fissile’ 
isotope  uranium-235  (U-235)  to  the  required  level;  the  other  being  progressively 
depleted  of  ‘fissile’  isotope  and  called  ‘tails’,  or  simply  depleted  uranium.  This  is 
essential  because  natural  uranium  contains  only  about  0.7%  U-235,  which  is  not 
enough for most nuclear reactors in the EU (88).  

Being  proliferation-sensitive,  enrichment  technology  is  available  only  to  a  limited 
number  of  governments,  who  entrust  it  to  an  even  smaller  number  of  commercial 
operators,  see  Table  6.  Amid  the  current  geopolitical  tensions  and  other  shocks  to 
global energy markets, it is therefore noteworthy that such a sensitive market segment 
seems to have embarked on significant change due to governmental steers towards 
higher strategic independency and market opportunities for commercial operators. 

(88)   With few exceptions, such as CANDU type reactors in Romania, the fleet of light water reactors in 

the EU requires low-enriched uranium (LEU) to operate.  

40 

                                                               D      E     D      E            D      E     A   H  JP   A       SD           S               E S               E     A       SS                     
 
 
Since  2016,  prices  of  enrichment  were  relatively  stable  until  February  2022. 
Afterwards, both spot and long-term prices increased substantially and in December 
2023 they had multiplied by 2.5 times both. (89)  

Table 6 – Commercial and domestic facilities for uranium enrichment (million SWU per year) 

Company 

Country 

Nameplat
e capacity 

Planned additional 
capacity 

China 

CNNC 
Global Laser  United States 
Orano 
Orano 
Rosatom 
Urenco 
Urenco 
Urenco 
Urenco 
Other 
Total 

France 
United States 
Russia 
United States 
Netherlands 
United Kingdom 
Germany 
Brazil/ Japan 

10.0 
0 
7.5 

21.0  (2025-40) 
6.0  (2030) 
2.9  (2030) 

0  Unspecified  (2031-35) 

27.1 
4.3 
5.0 
4.5 
3.5 
0.2 
62.1 

0.7  (2025) 
0.8  (2028) 

0.3 

31.4 

Source:  European Commission, Euratom Supply Agency, WNA, https://www.orano.group/en, 

https://www.urenco.com/, https://www.nrc.gov/materials/fuel-cycle-fac/laser.html. 

Notes: 

Separative work unit, abbreviated as SWU, is the standard measure of the effort required 
to separate isotopes of uranium (U235 and U238) during an enrichment process in nuclear 
facilities. 1 SWU is equivalent to 1 kg of separative work. 

Urenco has two enrichment plants operating in the EU (NL, DE). The Urenco Group 
announced expansion of enrichment capacity at LES/Eunice (US) and in Almelo (NL) 
by adding centrifuge technology to meet greater customer demands. (90) 

Orano  reported  that  its  facility  ‘Georges  Besse  2’  in  southern  France  reached  full 
production capacity of 7,500 tSWU per year in 2016. Recently Orano  approved an 
investment of EUR 1.7 billion to increase the facility’s capacity by 30% or more. In 
the  US,  Orano  has  embarked  in  a  multibillion  project  (project  IKE)  to  realise  an 
enrichment  facility  at  Oak  Ridge,  TN  with  an  ambition  to  cope  with  increasing 
demand from US facilities. (91) 

Global Laser Enrichment (US) reported that it is considering advancing construction 
at  the  Paducah  Laser  Enrichment  Facility  from  2030  in  order  to  meet  LEU  and 
HALEU requirements. (92) 

CNEIC  (China)  enrichment  capacity  reached  a  nameplate  figure  of  6,500-7,000 
tSWU per year in 2018 and consecutively ramped up its production capacities, which 
is  estimated  to  reach  the  level  of  10,500  tSWU  per  year  now.  Similarly  to  the 

(89)   ESA, Annual report 2023 

(90)  

(91)  

(92)  

https://www.urenco.com/ 

https://www.orano.group/en 

https://www.nrc.gov/materials/fuel-cycle-fac/laser.html 

41 

 
 
 
 
 
 
 
 
  
 
 
anticipated development scenario of the conversion capacity it is anticipated that the 
enrichment capacity should achieve approximately 31,500 tSWU per year after 2040.  

Rosatom/TVEL  (Russia)  is  the  largest  global  enricher  with  an  overall  capacity  of 
27,100 tSWU per year at four sites. (93) 

INB  (Brazil)  and  JNFL  (Japan)  have  capacity  of  less  than  200  tSWU  per  year 
combined.  The  plant  at  Rokkasho-mura  (Japan)  is  currently  at  a  standstill.  Both 
countries have plans for modest capacity increase before 2030. 

In 2023, enrichment service deliveries to EU utilities (see Table 7) were 12% higher 
than in 2022. Over the period since 2016 enrichment service deliveries to EU utilities 
ranged between 10,290 and 12,912 tSWU per year, and there were no clear trends of 
increasing demand. As in the past, the enrichment services were acquired from three 
global  service  providers:  Orano  (FR),  Urenco  (DE,  NL,  UK,  US)  and  TVEL 
(RU). (94) 

Table 7 – Origin of enrichment services to EU utilities in 2023 (million SWU) 

Source:  Euratom Supply Agency Annual Report 2023. 

Notes: 

Because of rounding, totals may not add up. 

The backward analysis and the assessment of the present state of global market of 
enrichment services highlight the need for higher strategic independency at EU level 
to support the competitiveness of EU industry. A preliminary analysis of available 
data indicates that in 2024 the share of enrichment services provided to EU utilities 
from Russia decreased from 38% to 30%. The forward analysis presented here below 
(see Figure 24) provides an assessment of potential vulnerabilities in the supply vs 
demand balance until 2050 in a global scale.  

Based on current plans, the domestic enrichment plants’ aggregated capacity will be 
sufficient  to  meet  EU  demand  through  to  2050,  with  a  surplus  of  supply  capacity 
around 80% against the ‘base case’ scenario presented in section 2.1. However, there 
are two main elements to consider which may importantly reduce the domestic supply 
actually  available  to  EU  utilities:  (i)  realisation  of  the  ‘high-capacity’  scenario 
whereby  the  surplus  would  be  reduced  to  less  than  30%;  and  (ii)  commercial 
commitments undertaken by the EU producers with customers outside the EU. 

Extending the analysis to Western Europe, Ukraine, North America, Japan and South 
Korea the gap analysis shows that missing supply capacity exceeds 9,000 tSWU per 
year. The gap will possibly decrease towards the end of the decade and be at around 

(93)   World Nuclear Association,   

https://world-nuclear.org/information-library/nuclear-fuel-cycle/conversion-enrichment-and-
fabrication/uranium-enrichment#enrichment-capacity  

(94)   Euratom Supply Agency - Annual Report 2023, Annual Report 2021. Annual Report 2019. Annual 

Report 2017. 

42 

OriginQuantityShareEU6.72855%Russia4.64738%Other0.8857%Total12.260 
 
 
1,100 tSWU in 2034, based on announced investments in France, the Netherlands, 
the United Kingdom and in the US. However, even when accounting for emerging 
technologies,  e.g.  the  planned  ‘Global  Laser’  project,  the  available  capacity  will 
barely  suffice to  satisfy  demand from Western  reactors. Such gap will be wider if 
ambitious LTOs and new builds plan will materialise (for example in the US). An 
upward pressure to the demand will be also given by the market uptake of HALEU 
related to modular reactors and research reactors. 

Similarly to the conversion services market, secondary sources of UF6 can partially 
bridge the enrichment services gap in the short-term. Inventories held by utilities may 
contribute to serving the demand, too. Nevertheless, in the long run, new capacity is 
needed. 

Currently, other suppliers, such as those from Russia, and secondary sources satisfy 
the remaining demand. It is important to underline that if there was a sudden supply 
interruption,  other  secondary  sources  like  reprocessing  and  MOX  fuel  would  be 
insufficient to cover the gap, given the limited inventories. 

The gap analysis on the global scale shows that while presently the supply capacity is 
abundant compared to the demand, development scenarios indicate that plans for new 
enrichment capacity do not match plans for new power production which will lead 
the demand. Also in this case, the analysis provides likely an under-estimate of the 
gap due to the uptake of HALEU.  

Investments for expansion of existing enrichment facilities ranges around EUR 600 
million per additional capacity of 1,000 tSWU/y (95). 

(95) 

France: EIB and Orano sign a loan agreement for €400 million relating to the project to extend the 
Georges Besse 2 uranium enrichment plant, accessed on 23 May 2025. 

43 

 
 
Figure 24 – Demand for enrichment services vs supply capacity projections. (tSWU per year) 

Source:  Euratom Supply Agency. 

Notes: 

Separative work unit, abbreviated as SWU, is the standard measure of the effort required 
to separate isotopes of uranium (U235 and U238) during an enrichment process in nuclear 
facilities.  1  SWU  is  equivalent  to  1  kg  of  separative  work.  As  a  larger  unit,  1  tonne  of 
separative  work  units  or  tSWU  equals  1,000  kg  of  separative  work.  The  stacked  areas 
representing demand are additive, i.e. global demand is given by the blue, green, and red 
areas. 

4.2.4. 

Fuel fabrication 

Fuel fabrication is a manufacturing service that requires preparing fuel assemblies to 
the  exact  requirements  of  the  customer  reactor  unit (96).  While  some  degree  of 
competition is theoretically possible, vendors consolidation over the years has led to 
a high degree of concentration. Moreover, for vendors to develop new designs and 
supply fuel assemblies to reactor operators, long lead times are necessary due to safety 
implications  and  licensing  processes.  As  a  consequence,  utilities  should  secure 
supplies by maintaining at least two alternative suppliers.  

Most  EU  utilities  can  purchase  fuel  from  at  least  two  alternative  suppliers.  As  an 
exception, dependence on a single design and supplier of fuel was the case for water-
water energy reactors (VVER) and became a vulnerability for the security of supply 
(97).  Fuel  to  those  reactors  has  been  originally  delivered  from  TVEL  (RU),  a 

(96)   Reactor fuel typically consists of ceramic pellets made from uranium dioxide, pressed and heated at 
high temperatures. These pellets are sealed in metal tubes, usually a zirconium alloy, to create fuel 
rods. The rods are grouped into a fuel assembly for use in the reactor. 

(97)   Euratom Supply Agency, Annual Report 2023. 

44 

                                                               D      E     D      E            D      E     A   H  JP   A       SD           S               E S               E    JP       SS                     
 
 
subsidiary  of  Rosatom,  within  bundled  contracts  offering  uranium  and  all  related 
services including production of fuel assemblies. 

VVER  reactors,  a  type  of  pressurized  water  reactor  developed  in  Russia,  play  a 
significant role in the nuclear energy landscapes in some eastern EU Member States. 
VVER-440 reactors are generally used in smaller power plants in the Czech Republic, 
Finland, Hungary and Slovakia. VVER-1000 reactors are found in larger, more recent 
facilities in the Czech Republic and Bulgaria.  

As of 2022, almost all concerned EU operators have taken action to diversify nuclear 
fuel  supply.  Some  are  already  well  advanced  in  licensing  alternative  supplies. 
Besides, some utilities rose fresh fuel stocks to cover the period until alternative fuels 
– including related plant adaptations – will be completed and licensed. 

As part of VVER fuel diversification, two projects (98) were established following a 
call by the European Commission and co-funded by the EU. Those projects involve 
fuel  fabricators  Westinghouse  (US/CAN)  and  Framatome  (FR),  the  latter  in  joint 
venture with TVEL (RU). 

Alternative  VVER  fuel  supplies  are  expected  to  become  fully  available  by  2027, 
pending regulatory approval. Framatome’s independently developed European design 
for VVER fuel is anticipated to be ready not earlier than 2030. 

(98)   The three-year Accelerated Programme for Implementation of Secure Nuclear Fuel Supply (APIS), 
launched in January 2023 and coordinated by Westinghouse, aims at developing and delivering safe, 
fully European nuclear fuel for nuclear power reactors without involving Russian capital, technology, 
or expertise. https://apis-project.eu/  

The  second  project  (SAVE)  is  led  by  Framatome  and  brings  together  17  partners  from seven  EU 
Member States as well as Ukraine, to contribute to the swift and secure development and deployment 
of a European fuel solution for VVER reactors. It is important to note that for the Framatome-TVEL 
collaboration,  only  the  final  stage  of  fuel  fabrication  will  occur  in  Germany  or  France,  while  all 
components required for production will be sourced from Russia. 

45 

 
 
Box - Supply of High-assay low-enriched uranium (HALEU) 

Traditionally,  fuels  for  the  EU  research  reactors  and  radioisotope  production 
targets used highly enriched uranium (HEU), supplied mainly from the US and 
Russia (up to 25%). Under global nuclear security commitments, EU Member 
States  engaged  in  converting  to  use  of  HALEU  for  research  reactors  and 
radioisotope production targets. 

European  research  reactors  with  low  to  medium  power  density  cores  and 
medical  radioisotopes  producers  transitioned  to  HALEU.  The  remaining 
European high performance research reactors are going to use HALEU as soon 
as technically and economically feasible (2026 onwards). 

Currently,  metallic  HALEU  is  obtained  either  by  down-blending  US  HEU 
stocks or from Russia. There is a very limited enrichment capacity for HALEU 
and no civil facilities for production of metal HALEU in the Western world.  

Domestic commercial HALEU production, required mainly by many advanced 
reactor designs, has become a strategic objective for security of supply. 

The US Department of Energy (DoE) estimates that the US will require more 
than  40  tonnes  of  HALEU  before  2030,  deemed  to  continue  to  increase 
afterwards.  Accordingly,  DoE  established  the  HALEU  Availability  Program 
under  the  Energy  Act  of  2020,  and  the  Inflation  Reduction  Act  included  a 
USD 700 million support package. Additional USD 500 million was earmarked 
for HALEU in the Emergency National Security Supplemental Appropriations 
Act providing USD 2.72 billion to support domestic uranium enrichment. 

In 2024, the UK government announced investments up to GBP 300 million to 
launch  a  HALEU  programme,  under  which  the  UK  government  awarded 
already GBP 196 million to Urenco to build a uranium enrichment facility in 
Capenhurst, with the capacity to produce up to 10 tonnes of HALEU per year 
by 2031. In addition, the UK government set out the Nuclear Fuel Fund (GBP 
50  million)  to  support  the  UK’s  nuclear  fuel  supply  chain  in  the  UK  and 
globally. Eight projects have so far been awarded a total of GBP 22.3 million, 
including: (i) GBP 10.5 million to Westinghouse to enable its Springfields plant 
in Preston, Lancashire, to manufacture a broader range of nuclear fuel types for 
large  reactors,  SMRs  and  AMRs  in  the  UK  and  overseas;  and  (ii)  GBP  9.5 
million to Urenco to develop LEU+ and HALEU enrichment capability at its 
Capenhurst site in Cheshire. 

Besides  production,  uptake  of  HALEU  will  require  developing  dedicated 
transport  solutions,  because  there  is  no  licensed  transportation  method  for 
HALEU aside from using existing HEU casks, allowing only small shipments 
in a costly way. US DoE earmarked up to USD 16 million to develop licensed 
transportation packages for HALEU. In the UK the Nuclear Decommissioning 
Authority’s  subsidiary  Nuclear  Transport  Solutions  (NTS)  has  been  awarded 
funding  up  to  GBP 11.5 million  to  spearhead  the  development  of  transport 
capabilities for the UK's future use of HALEU. 

46 

 
 
4.2.5. 

Reprocessing 

Spent nuclear fuel retains about 96% of its original uranium, 3% waste products, and 
1%  plutonium  generated  in  the  reactor  but  not  consumed  during  operation. 
Reprocessing is a process to separate uranium and plutonium from waste products, so 
that they can be recycled into fresh fuel, such as Mixed Oxides (MOX). This process 
significantly reduces the overall volume of long-lived, high-level radioactive waste. 

Strategies to ensure a safe and cost-effective overall management of spent fuel differ 
from one country to another and can be described as follows: (i) the ‘open cycle’ or 
‘once  through’  or  ‘direct  disposal’  strategy  in  which  spent  fuel  is  considered  as 
waste; (ii) the ‘closed cycle’ (including the ‘partially closed cycle’) strategy, in which 
spent  fuel  is  considered  as  a  potential  future  energy  resource  and  reprocessed  to 
recycle uranium and plutonium in new fuel assemblies. During the reprocessing high-
level waste is produced. An overview is provided in Table 8. 

Table 8 – Nuclear power fuel cycle strategies 

 ommercial 
scale 
reprocessing 
facility 

 pent fuel 
currently in 
another 
country for 
reprocessing 

 arlier 
reprocessing, 
but practice 
currently 
ceased 

 lanning 
direct 
placement of 
spent fuel in 
a repository 

Keeping 
options open 

✔ 

✔ 

✔ 

✔ 

BE (•) 
B  (•) 
 Z (•) 
 I 
 R 
DE 
H  (•)(†) 
I  

R  
S  
SI 
ES 
SE (‡) 

✔ 

✔ 
✔ 

✔ 
✔ 

✔ 

✔ 
✔ 

✔ 

✔ 
✔ 

✔ 
✔ 

✔ 

✔ 
✔ 
✔ 
✔ 
✔ 

✔ 

✔ 
✔ 

Source:  S                        S                 R                   M            IAEA          

E      S        .   - - .   (R  .  ). 

Notes: 

(•) Mixed policy: some fuel has been or will be reprocessed other fuel will or may be direct 
disposed. 
(†) Earlier fuel returns to the Russian Federation, but no requirement to return waste from 
reprocessing to Hungary. 
(‡) E                                   . 

The EU’s approach to spent fuel management is guided by the Radioactive Waste and 
Spent  Fuel  Management  Directive  (2011/70/Euratom) (99),  which  requires  all  EU 
countries  to  have  national  policies  and  programmes  for  the  management  of  these 
materials. Currently, the majority of Member States have chosen direct disposal of 
spent  fuel  in  deep  geological  repositories  as  the  preferred  long-term  solution  for 

(99)   Council  Directive 2011/70/Euratom of 19 July 2011 establishing a Community framework for the 
responsible and safe management of spent fuel and radioactive waste, OJ L 199, 2.8.2011 p. 48–56. 

47 

 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
managing  high-level  radioactive  waste.  France  and  the  Netherlands  currently 
continue to perform reprocessing. France uses its reprocessed fuel as MOX in several 
of its  operating nuclear  power plants. Research in  transmutation  is  relevant  with  a 
view to reduce storage needs for high-level radioactive waste. 

4.2.6. 

Findings and conclusions on nuclear fuel supply chain 

The geopolitical developments, having impacted our continent, affected profoundly 
the functioning of the nuclear market. Russia’s unjustified military aggression against 
Ukraine has, inter alia, disrupted the global supply system for all sources of energy. 
It has jeopardised the trust to a major nuclear energy partner until then, undermining 
the Community’s security of supply of nuclear materials and services and aggravating 
dependence issues. 

In  response,  the  EU  adopted  far-reaching  restrictive  measures (100),  targeting  legal 
entities, natural persons, and a number of activities, but also affecting transport and 
trade. In the follow-up to the REPowerEU Plan (101), the Commission has published 
on 6 May 2025 the Roadmap towards ending Russian energy imports where several 
security  of  supply  related  measures  were  announced.  (102).  This  includes  trade 
measures on the import of enriched uranium, and restrictions on contracts co-signed 
by  the  Euratom  Supply  Agency  for  uranium,  enriched  uranium  and  other  nuclear 
materials with Russian suppliers as of a certain date. The Commission will also in 
June  2025  make  a  legislative  proposal  with  specific  targets  for  Member  States  to 
replace Russian nuclear fuels with alternative fuels, phase out reliance on Russia for 
uranium, enriched uranium and other nuclear materials, and increase transparency on 
dependencies  and  encourage  diversification  of  Russian  supplies  of  spare  parts  and 
maintenance services. 

Meanwhile, various challenges emerged to transportation routes from Russia and via 
Ukraine, and to the logistics of nuclear fuels. Also, the air transportation route - that 
some countries opted for as replacement of the railway route through Ukraine – may 
be unavailable and exceptional. Fuel delivery through the Black Sea needs additional 
risk  assessment  as  it  is  affected  by  the  war.  Planned  deliveries  of  Russian  nuclear 
material  and  fuel  may  be  further  hindered  in  the  evolving  situation  and  due  to 
emerging concerns of carriers refusing to transport, refusal to harbour or to deal with 
Russian goods amid public sensitivity and/or reputational risks. 

Looking to future scenarios, demand in nuclear fuel cycle supplies and services is set 
to  grow globally.  At EU level,  the ‘high-capacity’ scenario set  out  on the basis of 
Member States plans will also lead to increase demand in such supplies and services. 
Therefore, ensuring strategic autonomy and security of supply from  ore to  nuclear 
fuel  should  remain  a  critical  objective  of  Member  States  with  nuclear  energy 
programmes.  Moreover,  all  Member  States  should  also  consider  the  strategic 
importance  of  security  of  supply  for  nuclear  technologies  related  to  supply  of 

(100)   Council Regulation (EU) No 833/2014 of 31 July 2014  concerning restrictive measures in view of 
Russia's  actions  destabilising  the  situation  in  Ukraine,  as  amended  many  times  (the  current 
consolidated version as of 13.4.2022). 

(101)  REPowerEU Plan: Communication from the Commission to the European Parliament, the European 
Council, the Council, the European Economic and Social Committee and the Committee of Regions, 
adopted on 18.5.2022 – COM(2022) 230 final. 

(102)   Roadmap towards ending Russian energy imports, COM/2025/440 final/2.  

48 

 
 
radioisotopes. ESA provides support in monitoring developments in the nuclear fuel 
market  and  in  relevant  technological  fields  in  order  to  identify  market  trends  that 
could  affect  security  of  the  European  Union’s  supply  of  nuclear  materials  and 
services (103).  

The EU industry has sufficient access to supplies today and, in the short term, can 
tactically satisfy possible supply gaps via existing inventories. Yet only investments 
into new capacities, in particular for conversion services, will strategically resolve the 
issue. The market  is  already sensing the possible scarcity of low-risk supplies and 
prices have seen extraordinary increases in a short time. 

As a first line of action, to ensure that uranium resources are available when needed 
on the global market, future supply would benefit from timely research and innovation 
aimed  at  enhancing  uranium  exploration  and  developing  new,  more  cost-effective 
extraction techniques. 

Most importantly, in the medium and long term, EU utilities’ demand for conversion 
and enrichment services face a starkened risk of shortages which Member States need 
to address with stimulus to adequate investments, bearing in mind that to make up for 
the  additional  conversion  and  enrichment  capacity  will  take  several  years.  Such 
investments may also be driven by increasing market opportunities. 

Phasing out supplies from unreliable partners is a necessity. Against this background, 
increased cooperation between the EU and reliable international partners (see section 
6.4)  as  regards  uranium  supply  and  nuclear  fuel  services  will  be  beneficial  to  all 
parties. Recognising the need to find long term solutions, the EU and several states 
should coordinate to ensure genuine security of supply. 

4.3. 

Supply chain for nuclear installations life cycle 

In this section an analysis is provided of the supply chain for the ‘nuclear installation 
life cycle’. The supply chain network must ensure delivery of materials, components, 
and  services  essential  for  constructing,  operating,  maintaining,  and  dismantling 
nuclear installations within the EU. With a focus on installations such as reactors, this 
section covers front-end (new builds), operation and maintenance (including LTOs), 
and backend (decommissioning and waste management). 

Over  the  past  two  decades,  the  EU’s  nuclear  supply  chain  reoriented  towards 
maintenance and safety upgrades in the frame of plant outages and periodic safety 
reviews  rather  than  new  constructions.  Moreover,  an  important  number  of 
installations  shifted  to  decommissioning,  with  a  consequent  ramping  up  of  waste 
production.  

As a matter of fact, in this century, the rate of newly commissioned nuclear power 
plants  was  starkly  lower  than  before.  Since  2000  new  nuclear  power  plants 
commissioned in Europe have been three European Pressurised Reactor (EPR), which 
were built or are still under construction in Finland, France, and the UK, two VVER-
440, which had been in construction since the 1980’s in Slovakia, and one CANDU 
reactor in Romania. 

(103)   https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32008D0114&from=EN  

49 

 
 
In the same period, the EU’s supply chain has continuously and adequately provided 
services to operating plants, as demonstrated by implementation of 10-year Periodic 
Safety Reviews, of long-term operations, and of post-Fukushima safety upgrades at 
all nuclear power plants in Europe (104). 

4.3.1. 

Supply of key materials for construction and operation 

Nuclear industry makes use of a wide range of materials from those that are relatively 
common in  other industries too  (e.g. concrete, steel,  copper) to  specialty  ones that 
enable functionality within a nuclear project (e.g. certain rare earth elements, boron, 
zirconium, and particular alloys). Concrete and steel account for the bulk of material 
requirements  for  a  nuclear  plant,  see  Table  9. (105)  The  table  below  provides  an 
example of the range of materials need for a Pressurized Water Reactor. 

Table 9 – Materials input requirements per kW for a Pressurised Water Reactor 

Material  
Concrete  
Carbon steel  
Wood  
Stainless steel  
Galvanised iron  
Polyvinyl chloride (PVC)  
Insulation  
Copper  
Uranium  
Manganese  
Zirconium  
Chromium  
Nickel  
Inconel  
Brass / bronze  
Lead  
Aluminium 
Silver  
Cadmium  
Boron  
Indium  
Total  

kg / kW 

180 – 560 
10 – 65 
4,7 – 5,6 
1.56 – 2.10 
1.26 
0.80 – 1.27 
0.70 – 0.92 
0.69 – 2.00 
0.40 – 0.62 
0.33 – 0.70 
0.20 – 0.40 
0.15 – 0.55 
0.10 – 0.50 
0.10 – 0.12 
0.04 
0.03 – 0.05 
0.02 – 0.24 
0.01 
0.01 
0.01 
0.01 
195 – 635 

Source:  Materials and the Environment. Michael F. Ashby, 2013, ISBN 978-0-12-385971-6. 

Rare earth elements are used in nuclear reactor applications, predominantly in reactor 
control  rods,  for  example:  (i)  Samarium-149  as  strong  neutron  absorber  in  control 
rods; (ii) Europium due to its very low melting point and neutron absorption features; 
(iii)  Gadolinium  being  very  effective  for  use  with  neutron  radiography  and  in 

(104)   See  PINC  2017  SWD  pages  21-22  Box  4  and  Follow-up  of  the  peer  review  of  the  stress  tests 

performed on European nuclear power plants | ENSREG 

(105)   WNA report “The World Nuclear Supply Chain 2023 report” page 75-78 

50 

 
 
shielding  of  nuclear  reactors,  providing  greater  durability  of  alloys. However,  the 
dependency of nuclear reactors on rare earth is considered limited compared to other 
clean energy technologies, see Figure 25. (106) 

There  are  no  clear  signals  that  key  materials  used  within  the  nuclear  supply  chain 
would not be accessible in the near-term. Nonetheless challenges may rise to access 
some materials in a cost-competitive and timely manner at the volumes required due 
to geopolitical and other factors, especially in case of stark demand for other types of 
clean energy technologies. 

Figure 25 – Minerals used in selected energy technologies 

Source:  The Role of Critical Minerals in Clean Energy Transitions, World Energy Outlook Special 

Report, International Energy Agency, March 2022 (revised version), page 6. 

4.3.2. 

Construction of new nuclear power plants 

According to the WNA (107) there are currently 12 vendors of large-scale reactors (108) 
among which one is from the EU (Framatome).  

The analysis of the relevant supply chain may be split into two segments: (i) primary 
circuit including the reactor, steam generator, main coolant pumps and pressuriser; 
and (ii) secondary circuit including the turbine, generator, condenser and in general 
the balancing of plant, see Figure 26. 

(106)   Report  on  the  European  nuclear  ecosystem,  prepared  by  Deloitte  for  DG  ENER,  2023  [yet 

unpublished]. 

(107)   The World Nuclear Supply Chain, 2023 Edition, World Nuclear Association, 2023. 

(108)   SNC-Lavalin, China National Nuclear Corporation (CNNC), China General Nuclear Power Group 
(CGN),  Framatome,  GE  Hitachi,  Korea  Electric  Power  Corporation  (KEPCO),  Mitsubishi  Heavy 
Industries  (MHI),  Nuclear  Power  Corporation  of  India  Ltd  (NPCIL),  Rosatom,  State  Power 
Investment Corporation (SPIC), Toshiba and Westinghouse Electric Company 

51 

 
 
 
Figure 26 – Main components of a Pressurised Water Reactor (PWR) 

Source:  Todd Allen et al., Materials challenges for nuclear systems, Materials Today, Volume 13, 

Issue 12, December 2010. 

A representative “overnight” cost breakdown for nuclear new build is presented in 
the following Figure 27. A critical part of the construction phase is the manufacturing 
of large components such as pressure vessels or steam generators. It is estimated that 
equipment cost can make up 48% (109) of the overall overnight costs. 

(109)   Nuclear island equipment  – 12%, Electrical and generating equipment – 12%, Mechanical – 16%, 

I&C system – 8%. 

52 

 
 
 
Figure 27 – “Overnight” cost breakdown for nuclear new-build 

Source:  Nuclear new build: Insight info financing and project management. OECD-NEA, 2015. 

Notes: 

I&C = Instrumentation and Control. 

The  projected  scenarios  of  new  builds  in  the  EU  (see  section  2.1)  imply  that  the 
nuclear supply chain will have to ramp up to larger capacities and widen their scope 
of work to produce all needed components for a nuclear power plant (not only the 
replaceable ones). To achieve constructing 60 GWe of new nuclear power capacity 
by 2050, Member States and industry may need to start building approximately 20 
GWe of nuclear capacity simultaneously (if constructions begin today, assuming 
an average construction time of about nine years). This would necessitate that about 
15 large nuclear reactors are built concurrently in the EU over the next 25 years. 
However,  the  analysis  of  Member  States’  NECP  in  Section  2  shows  that  the 
anticipated investment in large reactors is concentrated in the 2030s. In that decade, 
an even greater number of large-scale reactors will have to be built simultaneously to 
meet Member States’ plans. 

Notwithstanding  the  work  and  initiatives  taken  by  the  EU  industry  to  maintain 
manufacturing  capacities  over  the  last  two  decades,  there  are  still  areas  where 
capabilities  have  declined  or  disappeared  in  the  EU,  and  which  would  need  to  be 
redeveloped to allow swift development of new units and regain EU sovereignty. This 
is in particular the case for the forging of heavy components (see Box below).  

53 

 
 
Box - Needs for heavy forging 

Heavy  forging  is  a  critical  component  of  the  supply  chain  for  new  reactors 
building.  Some  reactor  components  are  manufactured  specifically  for  a 
particular  reactor  design,  and  there  is  accordingly  a  dedicated  supply  chain 
associated  with  each  reactor  vendor.  Heavy  forging  capacity  may  become  a 
limiting factor to the roll-out of plans for large scale nuclear power plants. 

As reported by WNA (•), complemented by other sources of information (**), 
main large components of Generation III/III+ plants, such as reactor pressure 
vessels, are made from nearly 200 forgings, amounting to over 4000 tonnes of 
steel, some weighing around 500 tonnes each.  

Member States with plans for new large nuclear reactors (e.g. Czechia, France, 
Poland)  target  currently  the  following  models:  EDF EPR2,  Westinghouse 
AP1000, and KHNP APR1000. For these models, single ingot weight may well 
exceed 350 tonnes up to 500 tonnes. 

The  chart  below  shows  how  existing  heavy  forging  companies  are  located 
geographically and what kind of reactors they may serve in particular for reactor 
pressure vessels forging. It appears that capacity for homegrown large reactors’ 
components  requires  attention  to  sustain  Member  States  plans,  especially  in 
relation to France. 

(•) The World Nuclear Supply Chain, 2023 Edition, World Nuclear Association, 2023. 

(**) Le Creusot - Framatome 

54 

                  7       I    J    R     S    A     S            SAE M                  (      )EPR AP    APR     
 
 
4.3.3. 

Long term operations 

As  indicated  by  the  WNA  (110),  long  term  operations  involve  the  maintenance  or 
replacement of a number of systems and components, such as: 

•  mechanical equipment for reactor vessel heads, steam generators, turbines, pumps, 

motors, valves; 

•  fluid systems piping replacement with corrosion-resistant materials, independent 
core cooling system, large diameter piping, buried piping replacement with high 
density polyethylene; 

•  electrical  equipment  alternators,  transformers,  high  voltage  posts,  electrical 

boards; 

•  instrumentation and control (I&C) control room, cables, sensors; 

•  civil works cooling towers; 

•  post-Fukushima  safety  measures  filter  vents,  emergency  diesel  generators, 

additional ultimate cooling systems; 

•  fire protection. 

Consequently,  many  EU  businesses  thrived  in  the  market  of  LTOs  on  EU  nuclear 
power  plants.  This  helped  maintaining  knowledge  and  activities.  For  example,  in 
France the “Grand Carénage” (111) plan for the whole EDF fleet has been budgeted 
around EUR 65 billion (112) for the period 2014-2028, providing scope for work on 
most items mentioned above.  

Another important element driving the availability of the supply chain is that not all 
components used in nuclear facilities must proceed from a unique “nuclear design”. 
High quality components used in other industrial sectors (such as chemical, or oil & 
gas) can often be procured for use in safety-classified applications in nuclear power 
plants. These products are referred to as “commercial grade products”. The nuclear 
industry made an effort to  use such kind of products  and to  adapt  them to nuclear 
requirements  to  compensate  some  shortage  of  specific  nuclear  components  on  the 
market. This evolutionary change started 40 years ago by the Electric Power Research 
Institute (EPRI) in the US, and later spread to international nuclear fleets  in South 
Korea and Spain. In 2020, the European Commission Joint Research Centre published 
a comprehensive report about the current challenges of the European nuclear supply 
chain (113).  This  report  highlighted  the  effort  ongoing  to  address  the  concern  of 
nuclear component obsolescence by replacing them with commercial grade products. 
Since then, utilities in Finland and Sweden also progressed in the frame of the KELPO 
project (114).  In  2022,  nucleareurope  published  an  international  guideline  on  this 

(110)   The World Nuclear Supply Chain, 2023 Edition, World Nuclear Association, 2023. 

(111)   La R&D et le Grand Carénage - 28/05/2020 | EDF FR 

(112)   Éclairer l'avenir : l'électricité aux horizons 2035 et 2050 - Rapport - Sénat 

(113)   JRC Publications Repository - Current Challenges of the European Nuclear Supply Chain 2020. 

(114)   KELPO – Development of the licensing and qualification processes for the systems and equipment 

of nuclear facilities in Finland - Finnish Energy 

55 

 
 
topic (115).  In  2023  the  IAEA  published  detailed  report  about  the  “Suitability 
Evaluation  of  Commercial  Grade  Products  for  Use  in  Nuclear  Power  Plant  Safety 
Systems” (116). All  these  elements  show the challenges that the nuclear industry is 
facing with its supply chain and the replacement on certain components on its existing 
fleet. 

With  an  ageing  reactor  fleet,  over  80%  of  existing  reactors  will  require  extended 
maintenance,  specialised  component  replacement,  and  regular  upgrades  to  ensure 
safety and functionality. This will require large production capacities just to cope with 
replacements.  

4.3.4. 

Distinctive features of Small Modular Reactors (SMRs) 

SMRs (117) present both opportunities and challenges for the EU nuclear supply chain. 
In the framework of the European SMR pre-partnership (118), data were collected on 
the European supply chain via a questionnaire distributed to nucleareurope’s member 
associations and through the analysis of publicly available information.  Altogether 
the data originated from 200 companies. 

The questionnaire was answered by 91 suppliers located in 10 European countries. 
Despite  the  non-comprehensive  geographical  coverage (119),  gathered  information 
provide a sample picture of the availability of suppliers in several EU countries and 
product sectors (see Figures 28–29). 

The analysis showed that more than 60% of suppliers have pertinent know-how for 
more than one reactor technology, and about 30% of them have worked on more than 
two  different  reactor  technologies.  This  is  important  in  relation  to  the  variety  of 
technologies under development for SMRs and advanced modular reactors (AMRs). 
The analysis highlighted as well that many companies have track-records in working 
with  different  code  &  standards,  including  international  standards  (such  as 

(115)   Quality Assurance Guideline for Procuring High-Quality Industrial Grade Items Aimed at Supporting 
Safety  Functions  in  Nuclear  Facilities,  Volume  1:  Methodology  and  Volume  2:  User’s  Guide, 
Foratom, March 2022 

(116)   Suitability Evaluation of Commercial Grade Products for Use in Nuclear Power Plant Safety Systems 

| IAEA 2023. 

(117)  Advanced Modular Reactors (AMRs) are a sub-category of SMRs. They typically use novel coolants 
(e.g.,  gas,  liquid  metal,  molten  salt)  and  advanced  fuels.  They  often  aim  to  achieve  higher 
temperatures and efficiencies than current technologies. 

(118)   European SMR pre-Partnership, Workstream 4 – Supply Chain Adaptation, Technical Report, 2023. 

European SMR pre-Partnership - nucleareurope 

(119)   Among these 10 countries there was potential to gather more responses, particularly from Spain, the 
UK, and the Czech Republic. Additionally, no responses were obtained from certain countries with 
potential companies for the SMR supply chain, such as Germany and Belgium. 

56 

 
 
IEC (120)/IEEE (121)/ISO (122)),  and  for  nuclear  pressure  vessel  codes  (such  as 
AFCEN (123) or ASME (124)). 

Figure 28 – Suppliers by country of origin (based on questionnaires) 

Source:  European  SMR  pre-Partnership,  Workstream  4  –  Supply  Chain  Adaptation,  Technical 

Report, 2023. 

(120)  

International Electrotechnical Commission 

(121)  

IEEE SA - Standards 

(122)  

ISO - Standards 

(123)   Association française pour les règles de conception, de construction et de surveillance en exploitation 
des  matériels  des  chaudières  électro-nucléaires  Shaping  the  Rules  for  a  Sustainable  Nuclear 
Technology 

(124)   The American Society of Mechanical Engineers - ASME 

57 

 
 
 
 
Figure 29 – Company product sectors indicated by the respondents 

Source:  European  SMR  pre-Partnership,  Workstream  4  –  Supply  Chain  Adaptation,  Technical 

Report, 2023. 

4.3.5. 

Decommissioning and waste management 

The back-end of the nuclear energy life cycle involves the safe management of spent 
fuel and radioactive waste (including disposal), as well as the safe decommissioning 
of the nuclear facilities. 

In lay terms, decommissioning (125) means all activities to be carried out after the final 
shut-down  of  a  nuclear  installation  to  remove  and  dismantle  equipment  and  to 
demolish the buildings, if need be, until the release of its site for other uses or re-use 
for a new nuclear installation. Decommissioning is highly interconnected to the spent 
fuel and radioactive waste management. 

Radioactive  waste  (126)  is  classified  under  national  programmes  according  to  its 
hazards  and  the  available  or  planned  management  routes.  In  general,  radioactive 
waste  can  be  classified  as  high-level  (HLW),  intermediate-level  (ILW),  low-level 
(LLW)  and  very-low-level  waste  (VLLW).  This  classification  together  with  the 
suitable disposal concepts are presented in Figure 30.  

(125)  

(126)  

‘Decommissioning’ refers to “administrative and technical actions taken to allow the removal of some 
or all of the regulatory controls from a facility” - IAEA Nuclear Safety and Security Glossary. 

‘Radioactive waste’ means radioactive material in gaseous, liquid or solid form for which no further 
use is foreseen or considered by the Member State or by a legal or natural person whose decision is 
accepted by the Member State, and which is regulated as radioactive waste by a competent regulatory 
authority under the legislative and regulatory framework of the Member State – Council Directive 
2011/70/Euratom. 

58 

 
 
 
 
Figure 30 – Waste classification and disposal concepts 

Source:  Classification  of  Radioactive  Waste,  IAEA  Safety  Standards  Series  No.  GSG-1,  General 

Safety Guide. 
Status  and  Trends  in  Spent  Fuel  and  Radioactive  Waste  Management,  IAEA  Nuclear 
Energy Series No. NW-T-1.14 (Rev. 1). 

The vast majority of radioactive waste is classified as low-level waste or very-low-
level waste and originates from day-to-day activities at nuclear power plants and other 
nuclear installations, as well as during their decommissioning. This kind of waste is 
also  the  main  waste  stream  from  the  use  of  radioisotopes,  including  in  medical 
applications. 

59 

 
 
 
Council Directive 2011/70/Euratom provides the requirements for the management 
of spent fuel and radioactive waste from generation to disposal. The Directive states 
that  radioactive  waste  shall  be  disposed  of  in  the  Member  State  in  which  it  was 
generated,  unless  there  are  appropriate  agreements  with  other  countries.  Each 
Member State has their national programme for management of radioactive waste and 
spent fuel. The Directive requires that Member States ensure the implementation of 
their respective national programmes, covering all types of spent fuel and radioactive 
waste  under  their  jurisdiction  and  all  stages  of  spent  fuel  and  radioactive  waste 
management from generation to disposal. National policies shall ensure that the costs 
for the management of spent fuel and radioactive waste, from their generation through 
the final disposal, are borne by those who generated the materials (127). 

The  Commission  publishes  periodically  the  radioactive  waste  and  spent  fuel 
inventory in the EU (128) under the Community framework for the responsible and 
safe management of spent fuel and radioactive waste (129). In the EU, about 40,000 m3 
of radioactive waste and around 1,000 tonnes of heavy metal (130) of spent nuclear 
fuel are generated each year against a supply of 620 TWh of electricity taking year 
2023 as reference  (131). More than 90% of radioactive waste is classified either as 
very-low-level  or  as  low-level,  while  high-level  waste  accounts  for  0.2%,  the  rest 
being intermediate-level waste. 

Looking at the geographical distribution of radioactive waste in the countries with 
past  or  present  nuclear  power  programmes,  most  of  waste  was  produced  in  the 
Member States with larger fleets of nuclear power plants (see Figure 31). 

(127)   Council Directive 2011/70/EURATOM 

(128)   COM(2024) 197 final - Report from the Commission to the Council and the European Parliament on 
progress  of  implementation  of  Council  Directive  2011/70/EURATOM  and  an  inventory  of 
radioactive  waste  and  spent  fuel  present  in  the  Community's  territory  and  the  future  prospects  - 
THIRD REPORT 

(129)   Council Directive 2011/70/Euratom. 

(130)   Tonnes of heavy metal, abbreviated as tHM, is a unit of mass used to quantify uranium, plutonium, 

thorium and mixtures of these elements. 

(131)   Shedding light on energy in Europe – 2025 edition, ESTAT, ISBN 978-92-68-22424-3 

60 

 
 
Figure 31 – Distribution of total volumes of radioactive waste in Member States with nuclear 

power programme (end of 2019) 

Source:  Report from the Commission to the Council and the European Parliament on progress of 
implementation  of  Council  Directive  2011/70/EURATOM  and  an  inventory  of  radioactive 
waste and spent fuel present in the Community's territory and the future prospects - THIRD 
REPORT. 

In the EU, generally there has been significant progress in the disposing of very-low-
level or low-level waste. Further efforts are required for intermediate-level waste.  

In  relation  to  high-level  waste,  concerned  Member  States  need  to  put  in  place  the 
infrastructure to dispose of it. There is an international consensus that the safest option 
is  to  dispose  of  high-level  waste  in  stable  geological  formations  usually  several 
hundred metres or more below the surface. Finland is close to operating the national 
deep geological repository for spent fuel; this is a first-of-a-kind facility worldwide. 
The construction licence for a similar facility in Sweden was issued lately. France is 
advancing with the underground preparations and the authorisations. These examples 
demonstrate EU leadership in the sector; that leadership needs be followed by other 
concerned Member States that should possibly accelerate their plans (see Figure 32). 
Effective  decommissioning  and  responsible  management  of  radioactive  waste  and 
spent fuel are key to continued public support to the use of nuclear energy in Member 
States (132), and a fundamental pre-requisite for classifying certain nuclear activities 

(132)   The responsible management of radioactive waste and spent fuel continues to attract interest from a 
broad  range  of  civil  society  stakeholders.  A  recent  example  is  an  art  installation  addressing  the 
longevity  of  deep  geological  repositories,  which  was  presented  at  the  Luxembourgish  centre  for 
contemporary art, Casino Luxembourg, in the summer of 2024.  

61 

 
 
 
as  sustainable,  as  established  by  the  Commission  under  the  Taxonomy  regulation 
(133). 

Figure 32 – Planned start-up of operation of deep geological repositories 

Source:  Adapted from Report from the Commission to the Council and the European Parliament on 
progress  of  implementation  of  Council  Directive  2011/70/EURATOM  and  an inventory  of 
radioactive  waste  and  spent  fuel  present  in  the  Community's  territory  and  the  future 
prospects - THIRD REPORT 

Directive  2011/70/Euratom  requires  each  Member  State  to  estimate  national 
programme  costs  and  put  in  place  financing  schemes  for  the  safe  and  responsible 
management of radioactive waste. Member States’ estimates vary widely in terms of 
methodology, assumptions, completeness of data, scope and time frames. In the latest 
report  published  by  the  Commission  (134),  the  overall  EU  cost  estimate  for  the 
management  of  all  radioactive  waste,  i.e.  including  waste  generated  from  past 
future  activities,  and 
activities,  all  waste  expected 
decommissioning  of  operational  activities,  was  around  EUR  300  billion  (135). 
Preliminary analysis of national updates provided in 2024 shows that, while Member 
States have somewhat improved the quality of assessments, the overall cost estimate 
is relatively stable. The Commission will publish such updates as per the requirements 
of the Radioactive Waste Directive. 

from  ongoing  and 

Decommissioning of nuclear reactors and management of decommissioning waste is 
becoming more and more important, as a large number of nuclear power reactors were 
shut down, and the current global fleet of operating power reactors is ageing.  

On the one hand, as of end 2023, 74 nuclear power reactors were at different stages 
of decommissioning in the EU and plans were reported for those installations which 
are  still  operating.  In  the  last  decade,  decommissioning  activities  progressed 
significantly on several sites, supported by the EU supply chain which proved to be 
capable and knowledgeable. Yet only 3 reactors were declared fully decommissioned 
to date, and the time lapse from shut-down date is steadily increasing (see Figure 33). 

(133)   Regulation (EU) 2020/852, OJ L 198, 22.6.2020, p. 13–43; Commission Delegated Regulation (EU) 
2022/1214,  OJ  L  188,  15.7.2022,  p.  1–45,  EU  taxonomy  for  sustainable  activities  -  European 
Commission 

(134)   COM(2024) 197 final - Report from the Commission to the Council and the European Parliament on 
progress  of  implementation  of  Council  Directive  2011/70/EURATOM  and  an  inventory  of 
radioactive  waste  and  spent  fuel  present  in  the  Community's  territory  and  the  future  prospects  - 
THIRD REPORT 

(135)   This figure represents the sum of Member States’ individual estimates. Member States’ estimates vary 
widely in terms of methodology, assumptions, completeness of data, scope and time frames.   

62 

 
 
 
Figure 33 – Number of power reactors in decommissioning by time elapsed since shut-down 

(as of 31 December 2023) 

Source:  E                  ’              IAEA PRIS     IAEA RDS-2. 

On the other hand, as of end 2023, more than one third of power reactors had been in 
operation for longer than 40 years worldwide; in the EU that amount rises beyond 
40% (see Figure 34).  

Figure 34 – Number of operational reactors by age (as of 31 December 2023) 

Source:  E                  ’              IAEA PRIS     IAEA RDS-2. 

Decommissioning  of  shutdown  nuclear  power  plants  generates  large  amounts  of 
materials,  and  this  means  that  in  the  next  decades,  the  amounts  of  waste  from 
decommissioning will grow. A very large share of those materials is typically released 
from regulatory control as non-radioactive and recycled or reused in line with circular 
economy principles. However, the rest is managed as radioactive waste and mostly 
belongs to the categories very-low-level and low-level waste (see box for a concrete 
case). 

63 

 
 
 
A topical study on the market for decommissioning nuclear facilities in the EU (136) 
provided an estimate of the budgets for decommissioning and dismantling activities 
of nuclear power plants over the coming century: about EUR2016 80 billion (137). That 
study  provided  also  a  projection  over  time  of  expenditures  over  time:  between 
EUR 1.4 billion and EUR 2.2 billion per year until 2035; up to about EUR 3.0 billion 
per  year  in  2045.  Besides  several  other  factors,  actual  expenditures  will  clearly 
depend on lifetime extensions (see section 2), however those figures represent valid 
proxies of the order of magnitude of the decommissioning market value. 

in  April  2021 

The  Commission  set  up  the  Nuclear  Backend  Financial  Aspects  expert  group 
(NuBaFA) 
to  help  analyse  financial  aspects  of  nuclear 
decommissioning,  spent  fuel  and  radioactive  waste  management,  such  as  cost 
estimations, financing mechanisms, securing of required funds and their management. 
NuBaFA took over from the former Decommissioning Funding Group (DFG), which 
was  introduced  by  Commission  Recommendation  2006/851/Euratom  (138)  and  is 
composed of representatives appointed by EU countries, with a high level of expertise 
in the financial aspects of nuclear decommissioning and spent fuel and radioactive 
waste management. 

To  further  support  Member  States,  the  Commission  published  studies  on  the  risk 
profile of the funds  allocated to  finance the back-end activities of the nuclear  fuel 
cycle in the EU (139) and on methodologies of cost assessment for radioactive waste 
and spent fuel management (140). 

(136)   European  Commission:  Directorate-General  for  Energy, Study  on  market  for  decommissioning 
2019, 

Publications 

European 

Office, 

Union, 

nuclear 
https://data.europa.eu/doi/10.2833/20237. 

facilities 

the 

in 

(137)   The budgets needed for decommissioning and dismantling may evolve over time if Member States 

change nuclear provision requirements.  

(138)   Commission Recommendation on the management of financial resources for the decommissioning of 
nuclear installations, spent fuel and radioactive waste, OJ L 330, 28.11.2006, p. 31–35, EUR-Lex - 
32006H0851 - EN - EUR-Lex 

(139)   European Commission: Directorate-General for Energy, Briedyte, A., Lau, J., Bauer, G., Koenig, R. 
W. et al., Study on the risk profile of the funds allocated to finance the back-end activities of the 
nuclear fuel cycle in the EU, Publications Office, 2019, https://data.europa.eu/doi/10.2833/882170 

(140)   European  Commission:  Directorate-General  for  Energy,  Deloitte,  NucAdvisor  and  VVA, 
Methodologies of cost assessment for radioactive waste and spent fuel management – An overview 
of  the  practices  adopted  in  the  EU,  Publications  Office  of  the  European  Union,  2020, 
https://data.europa.eu/doi/10.2833/476584 

64 

 
 
 
Box - Decommissioning Bohunice V1 nuclear power plant in Slovakia 

The European Union has co-financed the decommissioning programme of the 
Bohunice V1 nuclear power plant in Slovakia. This is a meaningful case for a 
brief technoeconomic evaluation, as the programme is close to completion. 

The  Bohunice  V1  nuclear  power  plant  consisted  of  two  VVER-440  reactors 
which operated from 1980 until 2006 and from 1981 until 2008, respectively, 
generating 148.53 TWh of electricity altogether. These reactors were shut down 
prior to their design lifetime. 

The decommissioning programme set a budget of EUR 1.237 billion to carry 
out all decommissioning and waste management activities including disposal of 
very-low-level and low-level waste, and interim storage of intermediate-level 
waste and spent fuel. Accordingly, the budget covered all the back end for this 
installation, except the geological disposal facility. 

As  of  end  2024,  the  reactors  had  been  fully  dismantled,  and  the  clean-up  of 
reactors’ building was close to completion. At the same time the contract was 
kicked-off for the execution of the last stage of decommissioning, consisting of 
demolishing of the reactors’ building.  Therefore, the level  of maturity of the 
programme is  high  and the set  budget  will eventually  differ marginally  from 
incurred final costs. 

On this basis, the unit cost for decommissioning of Bohunice V1 nuclear power 
plant may be estimated at EUR 8.33 per supplied MWh. While it is not possible 
to  generalise  the  estimate  for  other  decommissioning  projects,  it  is  a  valid 
approximation  of  the  relative  magnitude  of  decommissioning  costs  to  be 
compared with  LCOE (•) for new large-scale reactors (†).  It  is  expected that 
decommissioning  unit  costs  per  supplied  MWh  will  be  sensibly  lower  for 
reactors that operated for the whole design lifetime or beyond that.  

The Bohunice V1 decommissioning programme has been also a concrete case 
of application of circular economy principles. Up to 99% of the total amount of 
materials (metals, concrete) resulting from dismantling/demolishing operations, 
including the actual reactors’ components, were decontaminated for release and 
recycling. (‡) 

(•)  Levelised  Cost  Of  Electricity  (LCOE)  =  average  cost  of  electricity  generation  over  the  economic 
including  capital,  operation  and  maintenance,  fuel,  and 

lifetime  of  a  production  asset, 
decommissioning. 

(†)  For  new  large-scale  nuclear  reactors,  the  projected  LCOE  in  2040  in  the  European  Union  ranges 
between EUR 69/MWh (USD 75/MWh) and EUR 101/MWh (USD 110/MWh). Source: IEA - The 
Path to a New Era for Nuclear Energy, January 2025. 

(‡) COM(2024) 181 final - Report from the Commission to the European Parliament and the Council on 
the implementation of the work under the nuclear decommissioning assistance programme to Bulgaria, 
Slovakia and Lithuania and JRC programme in 2022 and previous years. 

65 

 
 
4.3.6. 

Findings and conclusions on nuclear installations supply chain 

The EU’s nuclear industry is facing significant challenges in responding to current 
and future nuclear development trends across the segments including new builds and 
lifetime extensions, (as well as decommissioning and waste management). Therefore, 
the  industry  has  to  undergo  a  substantial  transformation  to  increase  its  capacity, 
effectiveness,  and competitiveness.  At the same time, the supply chain must make 
efforts to become sufficiently resilient and agile to be prepared for potential future 
disruptions  that  might  arise  from  geopolitical  shocks,  (un)availability  of  raw 
materials, or climate change. At the same time, the supply chain must make efforts to 
address the diversification of nuclear technologies: a new generation of large-scale 
power plants, SMRs and AMRs, which need different technologies and components.  

To address current and future needs, the EU nuclear supply chain will have to adapt 
via avenues such as standardisation and enhanced cooperation, as there are challenges 
such  as  reattracting  suppliers  who  have  left  the  sector,  modernising  existing 
infrastructure,  and  enhancing  efficiencies  to  meet  increased  demand.  The  main 
prerequisite to drive supply chain capacities at scale is that Member States planning 
to use nuclear energy hold long-term policy commitments, for market conditions to 
stabilise under consistent plans for construction of new reactors. 

While there are efforts to standardisation and harmonisation in technical codes and 
safety practices, varying requirements which continue to exist between EU countries 
can delay construction and add to costs. Socio-economically, the EU nuclear sector 
needs  substantial  investment  to  revitalise  its  workforce,  infrastructure,  and 
manufacturing  capabilities.  The  sector’s  competitiveness  could  also  be  enhanced 
through coordinated policies and public engagement to address concerns about safety, 
environmental impact, and long-term waste management. 

and  manufacturing 

Specifically,  the  challenges  associated  with  supply  chain  development  for  SMRs 
remain substantial, because the supply chain has to flexibly cope with many different 
emphasises 
designs 
standardisation at all levels, from system design to component fabrication, calling for 
a  higher  degree  of  standardisation  and  regulatory  harmonisation  across  the  EU  to 
avoid design modifications when deploying SMRs in various countries. Additionally, 
AMRs,  which  incorporate  innovative  designs,  pose  challenges  in  terms  of 
development of supply chain for new components using advanced materials, requiring 
also specialised workforce training (141). 

requirements.  SMR  production 

The Net-Zero Industry Act (NZIA) aims to enhance European manufacturing capacity 
for net-zero technologies and their key components, addressing barriers to scaling up 
production in Europe. The Regulation aims at increasing the competitiveness of the 
net-zero technology sector, attracting investments, and improving market access for 
clean tech in the EU. Following the adoption of NZIA, secondary legislation and a 
Communication  address  which  components  qualify  as  primarily  used  for  net-zero 
technologies  under  the  NZIA,  rules  on  non-price  criteria  in  renewable  energy 
auctions, main specific components relevant for the NZIA access to markets chapter, 
information  on  where  the  EU’s  supply  of  net-zero  technologies  comes  from,  and 
common criteria on strategic project selection. 

(141)   Proceedings of the EDF European Supplier Workshop, Paris, 4 June 2024. 

66 

 
 
5. 

INNOVATION 

The competitiveness of the nuclear industry will also depend on its ability to introduce 
innovations.  Within  the EU, there is  sufficient experience, know-how, technology, 
and resources to make progress in this area.  

This  chapter  discusses  two  major  subjects  for  innovation  where  EU  industry  is 
involved, and expectations are high: Small Modular Reactors (covered in Section 5.1) 
and Fusion (discussed in Section 5.2). 

5.1. 

Small Modular Reactors 

Small Modular Reactors (SMRs’) (142)present both opportunities and challenges for 
the EU nuclear sector. These reactors, which are smaller and could be built in modular 
units, are set to offer flexibility in addressing diverse energy needs, including district 
heating, industrial power, and hydrogen production. The scalability of these reactors, 
both, Generation III+ and Generation IV designs, aligns well with EU decarbonisation 
goals and could serve as a complement to renewable energy, addressing gaps in power 
supply due to renewables’ variability. 

Besides  small  reactors  (with  power  output  up  to  300  MW),  the  development  of 
microreactors  holds  an  important  market  potential.  Microreactors  could  fit  into 
shipping containers and can be delivered in remote sites to provide up to 20 MW, so 
to compete with electric batteries as a source of zero-carbon energy, and to replace 
diesel and gas generators. 

These innovative reactors promise to offer shorter construction times and potential 
for cost efficiencies through modularisation and series effect. 

Several EU Member States consider the use of nuclear energy in combination with 
renewable and other low-carbon sources. Most envisage the technology of SMRs as 
a complement to large scale nuclear reactors, contributing to delivering at least 90% 
carbon  emission  reduction  by  2040,  while  increasing  the  strategic  autonomy  and 
resilience of the European economy.  

In  line  with  the  EU’s  climate  neutrality  objective  strategy,  the  Commission  has 
considered  the  role  of  low-carbon  energy  sources  in  the  context  of  the 
Communication  “Securing  our  future.  Europe’s  2040  climate  target  and  path  to 
climate neutrality by 2050 building a sustainable, just and prosperous society” which 
was  adopted  in  February  2024 (143).  In  parallel,  the  Commission  launched  “an 
Industrial  Alliance  to  facilitate  stakeholder’s  cooperation  at  EU  level  and  to 
accelerate the deployment of Small Modular Reactors (SMRs)” (see section 5.1.5).  

5.1.1. 

Technology of modular reactors  

Modular  reactors  may  bring  notable  innovation  to  the  nuclear  industry,  offering 
several  advantages  over  traditional  large  scale  nuclear  power  plants.  As  per  the 
definition  set  by  IAEA  “SMRs  are  advanced  reactors  with  a  power  capacity  of 

(142)  Advanced Modular Reactors (AMRs) are a sub-category of SMRs. They typically use novel coolants 
(e.g.,  gas,  liquid  metal,  molten  salt)  and  advanced  fuels.  They  often  aim  to  achieve  higher 
temperatures and efficiencies than current technologies. 

(143)   COM(2024) 63 final 

67 

 
 
 
typically up to 300 MW(e) per unit” (144), i.e. significantly smaller than current large 
size  operating  nuclear  reactors  which  normally  have  power  outputs  between 
900 MWe and 1,700 MWe. The front runner SMRs are based on Light Water Reactor 
(LWR)  technology,  like  most  large  reactors  currently  operating  around  the  world. 
SMRs  comprise  also  the  so-called  Advanced  Modular  Reactors  (AMRs),  whose 
designs  are  comparable  to  Generation  IV  reactors  (such  as  High  Temperature 
Reactors – HTRs, Molten Salt Reactors – MSRs, and Liquid Metal Fast Reactors – 
LMFRs) (145), see Table 10. 

Table 10 – Examples of SMRs (non-exhaustive list) 

Reactor type  Description 
Light Water 
Reactors 
(LWRs) 

LWRs are similar to most existing 
nuclear power plants but on a 
smaller scale. They use water as 
both a coolant and a neutron 
moderator. 

Examples  
•  Nuward (EDF) 
•    S     V Y R™ 

SMR 

•  GE-Hitachi BWRX-300 
•  Rolls-Royce SMR 
•  CityHeat project 

(Calogena, Steady 
Energy) 
• 
Jimmy Energy 
•  Blue Capsule 

High-
Temperature 
Gas Reactors 
(HTRs) 

Molten Salt 
Reactors 
(MSRs) 

Liquid Metal 
Fast Reactors 
(LMFR) 

These reactors typically use helium 
as coolant and graphite as a 
moderator. They can achieve higher 
temperatures than LWRs, allowing 
for more efficient power generation 
and for high-temperature heat use in 
industrial applications. 

MSRs use a mixture of salts, 
typically as both the coolant and 
fuel, allowing for operation at higher 
temperatures and near to 
atmospheric pressure. 

•  Thorizon 
•  NAAREA  
•  STELLARIA  

These reactors use a metal or metal 
alloy (such as sodium or lead) as 
coolant and can operate at high 
temperatures without high pressure. 
They are targeting to close the 
nuclear fuel cycle, burning high level 
radioactive waste and plutonium 
originating from other reactors, 
producing, at the same time, 
electricity and/or heat. 

•  EU-SMR-LFR project 
(Ansaldo Nucleare, 
S  • E   E EA  
RATEN) 

•  European LFR AS 
Project (newcleo) 
•  HEXANA, OTRERA 

Source:  European Commission. 

In  the  field  of  AMRs  several  companies  are  now  also  developing  microreactors, 
which are typically based on the Generation-IV technology and a power output up to 
20 MW. Microreactors are conceived to operate like large batteries with no control 
rooms  or  workers  on-site.  A  recent  technoeconomic  analysis  performed  by  Idaho 
National  Laboratory  in  the  frame  of  US  Department  of  Energy  –  Microreactor 

(144)   Advances in Small Modular Reactor Technology Developments, A Supplement to: IAEA Advanced 

Reactors Information System (ARIS), 2022 Edition, © IAEA, 2022. 

(145)   Generation IV International Forum | GIF Portal 

68 

 
 
Program (146)  indicated  that  a  levelised  cost  of  energy  around  140  USD/MWh  is 
achievable. Such cost level would make microreactors not competitive to serve the 
electricity grid, however their use in difficult to access markets, where energy costs 
are  high,  such  as  remote  mining  sites,  oil  and  gas  industry  both  on  and  offshore. 
Several companies are also currently envisaging such type of designs to power ships 
for  maritime  transport.  Moreover,  the  defence  industry  has  showed  interest  for 
transportable nuclear reactors (including via air).  

Several companies are also currently envisaging such type of designs to power ships 
for maritime transport. From a technological point of view, SMRs could significantly 
reduce the environmental footprint of shipping by replacing heavy fuel oil and marine 
diesel  with  nuclear  fission-based  energy.  However,  apart  from  specific  technical 
challenges  linked  to  having  a  nuclear  propelled  ship,  there  are  several  regulatory 
barriers which would need to be overcome, the economic viability would need to be 
demonstrated, and attaining public acceptance could be even more difficult than for a 
land-based SMR. 

Envisaged advantages of modular reactors are production as factory-built  modules 
(enabling  efficiency  of  production 
in-series 
manufacturing), a smaller land footprint and reduced cooling water usage, as well as 
reduced construction and operational costs, potentially making them a more appealing 
choice for private investors.  

the  scale  effects  of 

through 

SMR have the potential to supply electricity and can serve as a reliable source of heat 
for  specific  industries  and  urban  districts  as  well  as  for  low-carbon  hydrogen 
production.  Additional  potential  applications  include  power  generation  for  grid 
balancing  or  for  power  supply  of  data  centres,  mining  operations  currently  using 
diesel  generators,  and  desalination.  Ongoing  feasibility  studies  like  the  Euratom 
Research  and  Training  Programme  project  TANDEM (147)  are  investigating  the 
utilisation of SMRs for integration into hybrid energy systems, generation of off-the-
grid electricity for industrial clusters and as power sources for hydrogen production 
hubs (148). The Sustainable Nuclear Energy Technology Platform (SNETP) works on 
the  European  Nuclear  Cogeneration  Industrial  Initiative  (NC2I),  which  aims  at 
demonstrating  innovative  and  competitive  energy  solutions  for  the  low-carbon 
cogeneration  of  heat  and  electricity,  and  hydrogen  production  based  on  nuclear 
energy (149). The Generation IV International Forum (GIF) was created in 2001 as a 
co-operative international endeavour seeking to develop the research necessary to test 
the  feasibility  and  performance  of  fourth  generation  nuclear  systems  (Gen-IV 

(146)   Botros  N.  Hanna  et  al.  Technoeconomic  Evaluation  of  Microreactor  Using  Detailed  Bottom-up 

Estimate, INL/RPT-24-80433, Revision 1, 2024. 

(147)   TANDEM 

(148)  The Euratom Research and Training Programme addressed the growing interest in SMRs by funding 
research  with  a  particular  focus  on  their  safety features  and  passive  safety  systems.  Five  research 
projects, as well as research at the JRC, aim to verify potential advantages of SMRs in terms of design 
simplification and inherent safety features. They also address new challenges with regard to safety, 
security and safeguards. By supporting design improvements, Euratom funded research facilitates the 
work of the European Industrial Alliance on SMRs, see Interim evaluation of the 2021-2025 Euratom 
research and training programme.   

(149)   SNETP, NC2I  

69 

 
 
systems), and to make them available for industrial deployment by 2030 (150). Thus, 
some of GIF’s work may also support the development and deployment of AMRs.  

5.1.2. 

Hybrid energy systems 

Numerous analyses (151) consistently substantiate that SMRs will complement, rather 
than compete with large-scale nuclear plants and renewable energy sources. Instead, 
SMRs  may  help  achieve  an  integrated,  secure,  stable,  high-efficient  and  resilient 
energy  system.  SMRs  could  be  instrumental  in  future  hybrid  energy  systems, 
contributing  to  clean  hydrogen  production,  and  to  significant  reductions  in 
greenhouse gas emissions. 

For instance, SMRs  could provide power supply  that can quickly  adjust balancing 
energy needs of the grid, thus contributing to overall grid resilience. 

Furthermore, SMRs can be deployed in a wider variety of locations than large-size 
nuclear power plants for efficient utilisation of existing infrastructure and integration 
of diverse and complementary energy sources within a given region. 

Modular  reactors  could  also  play  a  dual  role  in  low-carbon  hydrogen  production. 
Besides  directly  supplying  electricity  for  conventional  electrolysers,  AMRs  could 
also serve as providers of heat for high-temperature steam electrolysers, yielding a 
significant reduction in electricity consumption per kilogram of hydrogen produced. 
If these dual advantages turn out implementable and scalable, SMRs could emerge as 
potential  catalysts  for  supporting  the  expansion  of  the  clean  hydrogen  market  in 
Europe.  

5.1.3. 

Potential development of modular reactors in the EU 

There is a potential market for modular reactors in the EU, yet no SMRs have so far 
been put in operation in Europe. It is anticipated that the first SMRs will be operating 
in  Europe  in  the  early  2030s.  As  part  of  the  European  SMRs  pre-Partnership  (see 
section  5.1.5),  a  group  of  European  experts  from  sector  organisations  conducted  a 
detailed  analysis  of  the  potential  development  of  SMRs  and  AMRs  in  the  EU, 
exploring  their  various  applications  such  as  electricity  generation,  industrial  heat, 
district heating, and hydrogen production. These studies led to the creation of three 
scenarios and projections for SMR development between 2030 and 2050, which were 
published  in  a  report  in  July  2023.  The  projections  for  the  two  main  scenarios (a 
“current  projection”  scenario  (152)  and  a  “boosted  development”  scenario (153) 
estimate SMR capacity to range from 17 GWe to 53 GWe by 2050, with half of this 
capacity dedicated to heat and hydrogen production, see Figure 35. Additionally, all 
three  scenarios  project  a  significant  acceleration  in  development  by  2040,  aligned 
with the larger-scale deployment of AMRs. 

(150)   GIF 

(151)  

IEA (2025), The Path to a New Era for Nuclear Energy, IEA, Paris; NEA (2021), Small Modular 
Reactors: Challenges and Opportunities. 

(152)   Scenario based on the SMRs/AMRs projects announced in 2023 with an assumption that half of these 

projects would reach completion. 

(153)   Scenario  including  in  addition:  successful  deployment  of  the  necessary  supply  chain  in  the  EU, 
success in licensing harmonisation and new projects starting following success of the first ones. 

70 

 
 
Figure 35 – SMR deployment scenarios 

Source:  European SMR pre-Partnership Report, Workstream 1 – Market Analysis, 2023. 

Notes: 

In GWe for electricity and hydrogen; in GWth for industrial heat and district heat. 

Recently, several other reports were published on the subject. While some of them 
like the IAEA “Energy, Electricity and Nuclear Power Estimates for the Period up to 
2050” (154) or the NEA “Small Modular reactor Dashboard, 2nd edition” (155) do not 
detail precisely the capacity of SMRs development in Europe, they still emphasise the 
high potential for SMRs development in the World. 

Other reports like the IEA “Path to a new era for nuclear energy” (156) or the Compass 
Lexecon for nucleareurope “Pathways to 2050: the role of nuclear in a low-carbon 
Europe” (157) provide more detailed information about potential scenarios for SMRs 
development in Europe. These different projections confirmed the projections made 
in the frame of the European SMRs pre-Partnership and range from 10 GWe to round 
50  GWe  of  SMRs  capacity  installed  by  2050  in  Europe.  This  development  is 
conditioned by the existence of a well-functioning nuclear supply chain in Europe, a 
highly skilled workforce, large-scale investments of public and private resources and 
broad research capabilities.  

(154)   Energy, Electricity and Nuclear Power Estimates for the Period up to 2050, Reference Data Series 

No. 1, 2024 Edition, © IAEA, 2024. 

(155)   NEA (2024), The NEA Small Modular Reactor Dashboard: Second Edition. 

(156)  

IEA (2025), The Path to a New Era for Nuclear Energy, IEA, Paris https://www.iea.org/reports/the-
path-to-a-new-era-for-nuclear-energy, Licence: CC BY 4.0 

(157)   Pathways to 2050 - nucleareurope 

71 

                                                             P  j      B       D         I                      E          H                                                  D                
 
 
Box – Data centres and Artificial Intelligence may drive the SMRs’ roll out 

Data  centres  have  become  a  major  electricity  consumer  and  are  set  to  increase 
their  energy  demand  with  Artificial  Intelligence  (AI)  steadily  ramping  up  the 
digitalisation of the global economy.  

Based  on  US  Energy  Information  Administration  database,  in  2020  only  22 
countries  worldwide  had  a  bigger  annual  electricity  demand  than  the  global 
portfolio of Data Centres. The total global energy demand for data centres now 
exceeds the consumption of most economies, and they account for around 2% to 
4%  of  global  greenhouse  gas  emissions.  In  2020,  the  global  portfolio  of  Data 
Centres consumed 250 TWh of electricity (†); for comparison, in the same year 
the EU consumed 2,463 TWh, with Italy at 283 TWh and Spain at 223 TWh (‡). 

The “2024 United States Data Center Energy Usage Report” (*) revealed that from 
2016  to  2023  electricity  consumption  from  data  centres  tripled  in  the  US  and 
projected  a  possible  further  triplication  in  2028.  As  a  result  the  report  also 
estimated a total power demand for data centres between 74 GW and 132 GW. 

In  response  to  environmental  regulations  the  industry  is  facing  increasing 
demands  for  sustainability  reporting,  with  existing  policies  already  directly 
targeting  data  centre  sector.  Nuclear  technology  as  a  solution  to  access  a  low-
emission, abundant, dense and continuous energy source fit well the growing need 
to  reduce  data  centres  carbon  footprint  combined  with  their  24/7  high  energy 
demand (•). 

Several ‘Big Tech’ companies have made moves to support development of small 
reactors  or  even  revive  shut-down  reactors.  In  Autumn  2024  several 
announcements confirmed this new dynamism. 

•  Microsoft announced a 20-year power purchase agreement with Constellation 

that will see Three Mile Island unit 1 restarted. 

•  Google announced a deal to purchase energy from Kairos Power supporting 
the first commercial deployment of its fluoride salt-cooled high-temperature 
AMRs by 2030 and a subsequent fleet totalling 500 MW by 2035. 

•  Amazon announced a series of agreements to take a stake in advanced nuclear 
reactor developer X-energy and rolling out its Xe-100 advanced small modular 
reactor. For this project Amazon will fund the initial feasibility phase at a site 
near 'Energy Northwest' Columbia Generating Station. 

(†)  Powering data centres with advanced nuclear technologies, White paper on Data centres, Tractebel, 2024. 

(‡)  ESTAT, Energy statistics. 

(*)  2024  United  States  Data  Center  Energy  Usage  Report,  LBNL-2001637,  Lawrence  Berkeley  National 

Laboratory, December 2024. 

(•)  Small  Modular  Nuclear  Reactors  Suitability  for  Data  Centers  |  Schneider  Electric  White  Paper  186  – 

Schneider Electric – September 2024. 
Revitalising Nuclear: The UK Can Power AI and Lead the Clean-Energy Transition - Tony Blair Institute 
for global change - December 2024. 

72 

 
 
 
The development and deployment of modular reactors will not be without challenges, 
as most technologies are at a low technological readiness level. While first projects 
were  completed  in  Russia  and  China (158)  and  some  more  reactors  are  under 
construction,  in  the  EU  the  technology  still  has  to  demonstrate  that  it  will  meet 
expectations  in  terms  of  cost,  time  to  market,  nuclear  safety,  and  water  usage. 
Moreover, the supply chain needs to ramp up should a large number of SMRs be built, 
and  key  components  for  Gen  IV  AMRs  would  require  specific  manufacturing 
capabilities and capacities in the EU.  

Although  SMR  projects  are  expected  to  attract  private  investors  due  to  the  lower 
upfront capital required their operating costs per MWh produced are foreseen to be 
higher than the ones for large nuclear plant (159). It is expected that public intervention 
could continue to play a role, particularly in the context of the decarbonisation agenda 
of  national  and  regional  governments,  by  incentivising  and  crowding  in  private 
investments in SMRs and AMRs. 

Despite aiming to be cheaper than traditional reactors, SMRs still require hundreds of 
millions of euros to build, which, combined especially with the fact that these are new 
technologies, could hinder their financing. The modular design of SMRs promises to 
simplify and shorten the construction phase, potentially reducing the magnitude of 
risk for lenders. Some governments are providing incentives to lower financial risks 
and encourage SMR development (see Table 11). 

As an example, the European Commission has approved, under EU State aid rules, a 
EUR 300 million French measure to support Electricité de France’s (EDF) subsidiary 
Nuward for research and development of SMRs (160). Under the measure, the aid takes 
the form of a direct grant of up to EUR 300 million that will cover the R&D project 
until  early  2027.  This  EUR  300  million  grant  follows  a  previous  EUR  50  million 
French measure approved by the Commission in December 2022 to support an earlier 
phase of the Nuward project, cf. also further discussion on costs and benefits market 
participants do not fully take into account for SMRs/AMRs in section 7.1.4. 

A number of countries are already engaged in developing and deploying SMRs in the 
next  decade,  allocating  significant  funding  to  support  projects  or  industry  on  their 
territories, see Table 11. 

Table 11 – Public funding for SMRs (non-exhaustive list) 

EU Member States 

       (•) 

Allocated EUR 500 million for the development of light water SMR 
technologies (2021-2030) and additional EUR 500 million for AMRs 
(2023-2030) 

(158)   Small Modular Reactors Catalogue 2024, IAEA, 2024. Of the two operational SMRs, the Russian 
KLT-40S is a floating pressurised water reactor, while the Chinese HTR-10 is a high-temperature gas 
cooled reactor, which may be considered as an advanced modular reactor and a prototype towards the 
development of Generation-IV reactors.  

(159)   Small Modular Reactors: Nuclear Energy Market Potential for Near-term Deployment – NEA. 

(160)   EUR 300 million French State aid 

73 

 
 
Netherlands 
(†) 

Foresees EUR 65 million in 2024 for the preparation of SMR 
deployment and the province of Noord-Brabant announced it will invest 
EUR 4 million in further development of molten salt reactors in March 
2025 

B       (‡) 

Announced financial support of EUR 25 million annually (2023-2030) 

Sweden (*) 

Plans around EUR 9 million for construction of lead-cooled fast reactor 
(AMR demonstrator) 

Third countries  

 SA (••) 

On 16 October 2024, the U.S. Department of Energy (DOE) opened 
applications for up to USD 900 million to support the initial US 
deployments of Generation III+ SMR technologies. DOE has already 
granted regular funding to many US SMR projects, e.g.      P    ’  
Natrium, X-E     ’  X -100, NuScale, etc. 

UK (**) 

Established Advanced Nuclear Fund of GBP 385 million (GBP 215 
million for SMRs and GBP 170 for AMRs) 

       (††) 

Launched Enabling Small Modular Reactors Program funded with CAD 
29.6 million over four years to fund research on safe SMR waste 
management solutions and to develop supply chain for SMR 
manufacturing and fuel supply to support the crucial elements 
                    ’  SMR          

Source: 

(•)     é               :                é                  « Ré            é      
          »                |     .    .   
(•)             :                              é               | M     è       ’É        
                      S          é                    é  q   
(†) D                                                        -                    
(†) D                                   MSR             -                      
(‡) B                                        SMR          -                    
(*) B  k               k       -                  SMR -                    
(••)               :            III  S     M       R       P       | D             
E      
(••) I          A A        | D             E      
(**) A                             -   V.   
(††)                     S     M       R               P       -       .   

5.1.4. 

Safety and licensing 

All SMRs designs under development will have to ensure the highest standards of 
safety,  environmental  protection  as  well  as  radiation  protection  for  workers  and 
citizens, responsible management of radioactive waste and spent fuel, and a reliable 
non-proliferation regime, which ensures that nuclear material is not diverted from its 
intended use. An important driver for their deployment will also be transparency and 
public acceptance. SMRs have advanced engineered features, are deployable either 
as a single or multi-module plant and are designed to be built in factories and shipped 
to utilities for installation. Their industrial standardisation could contribute to lower 
construction cost, but this is highly dependent on scale effect (deployment of fleet). 
Therefore, licensing will be a key issue for the rollout of SMRs.  

SMRs using LWR technology are likely to have a shorter licensing process, as the 
technology  is  already  proven,  and  existing  regulatory  requirements  are  applicable. 
However, several SMR designs are novel with features that have not been deployed 
before, even in the case of LWR-designs. 

74 

 
 
 
 
 
Licensing will be more complex for AMRs with other Gen IV technologies, such as 
MSR and LMFR, where much more development work, testing and demonstration of 
safety systems will be needed. 

In the EU, licensing is a national responsibility. The deployment of advanced reactors 
incorporating emerging technologies needs a predictable regulatory framework and 
regulatory authorities that have the capabilities to independently analyse the safety 
implications of the new technologies. In other words, regulators “need to be flexible, 
accessible, enabling, and willing to work in a collaborative manner both domestically 
and internationally.” (161). 

As  explained  in  an  OECD/NEA  publication,  those  “countries  with  a  technology-
neutral  licensing  framework,  performance-based  regulatory  systems  and  a  widely 
used graded approach will likely find their system easier to adapt to SMRs than those 
countries with a technology-specific licensing framework or a prescriptive regulatory 
system.” (162). 

As part of the workstream on SMR safety within the European SMRs pre-Partnership, 
20 experts from 15 EU nuclear safety regulators collaborated for two years on SMR 
pre-licensing. The conclusions of this work clearly highlight: 

• 

• 

• 

the  need  to  engage  in  early  dialogues  between  designers-licensees  and 
regulators on main elements of the SMR design options;  

the willingness to promote cooperation of interested regulators to carry out a 
joint  safety  pre-assessment  on  a  mature  design  and  its  dissemination  with 
other regulators; and  

the importance to identify in an early phase potential blocking points in the 
safety 
for 
convergence. (163)  

licensing  processes  and  arrangements 

requirements  or 

At  the  level  of  the  cooperation  among  several  regulatory  authorities  on  a  SMR 
specific  design,  the  main  example  in  the  EU  is  the  Joint  Early  Review  (JER) (164) 
which started in June 2022 originally by three EU regulators: the French Authorité de 
Sûreté Nucléaire et de Radioprotection (ASNR) with the participation of the Czech 
Republic’s  State  Office  for  Nuclear  Safety  (SÚJB),  and  Finland’s  Radiation  and 
Nuclear Safety Authority (STUK) on the NUWARD SMR design. This cooperation 
now  also  includes  three  additional  nuclear  safety  regulators  from  Sweden  (SSM), 
Poland (PAA) and the Netherlands (ANVS).  

In  this  context  many  aspects  are  under  examination  in  the  EU,  but  primarily  the 
development of harmonised standards and regulatory approaches for SMR licensing 
in order to enable a more streamlined deployment of SMRs in different EU countries. 
The  Commission’s  role  is  to  support  a  harmonisation  of  the  processes  among 
interested regulators in the frame of the European Nuclear Safety Regulators Group 

(161)   NEA (2022), Harmonising the Nuclear Licensing Process for Emerging Technologies: A Global Path 

Forward, OECD Publishing, Paris. 

(162)   NEA (2021), Small Modular Reactors: Challenges and Opportunities, OECD Publishing, Paris. 

(163)   European SMR pre-Partnership report, WS2 - licensing - revision June 2024 | ENSREG 

(164)   Joint Early Review (JER) | Nuward 

75 

 
 
(ENSREG) to ensure the safest possible development of SMRs in the next decade and 
beyond. In that frame an SMR Task Force has been created in the beginning of 2025 
within ENSREG to continue the work started in the frame of the European SMRs pre-
Partnership  and  to  interact  closely  with  the  Technical  Working  Group  on  nuclear 
safety and safeguards created in the frame of the European SMR Industrial Alliance. 

5.1.5. 

The European SMRs pre-Partnership and Industrial Alliance 

In 2021, the Commission initiated the process toward a European SMR initiative by 
hosting a workshop on SMRs which brought together policymakers, industry leaders, 
regulatory bodies, and financial stakeholders. In early 2022, building on the outcomes 
of this event, European stakeholders formed of a European pre-Partnership with the 
primary objective of identifying the enabling conditions for the operation of the first 
SMRs in Europe by the early 2030s. The pre-Partnership work that was conducted by 
more  than  120  EU  experts  was  divided  in  five  workstreams:  market  analysis, 
licensing, financing, supply chain adaptation, and research & innovation. The work 
resulted  in  five  reports  published  in  July  2023 (165)  and  it  was  followed  by  a 
stakeholders’ consultation from 17 July to 29 September 2023. 

Then  building  on  the  work  of  the  European  SMR  pre-Partnership,  the  support 
expressed by several Member States and by industry stakeholders at the occasion of 
the  European  Nuclear  Energy  Forum  of  October  2023,  as  well  as  on  the  report 
adopted (166)  by  the  European  Parliament  in  December  2023,  the  European 
Commission established in February 2024 the European Industrial Alliance in Small 
Modular Reactors. 

The general objective of the European Industrial Alliance on SMRs is to facilitate and 
accelerate  the  development,  demonstration,  and  deployment  of  the  first  SMRs 
projects in Europe in the early 2030s, by assisting emerging SMRs projects to reach 
the demonstration and deployment phase. 

In this perspective, the Alliance pursues the following specific objectives according 
to its Terms of References (167): 

1)  Facilitate and accelerate the safe and cost-effective development and deployment 
through  supporting  relevant  stakeholders’  (including 
of  SMRs  projects 
established  and  emerging  European  companies)  collaboration  to  structure, 
advance and deploy their products in the European market and beyond. 

2)  Strengthen  the  enabling  conditions  for  SMR  development  by  mapping  and 
assessing,  the  performance  and  completeness  of  the  European  nuclear  supply 
chain, including raw materials availability, fuel cycle supply, waste management, 
research  &  innovation,  skills  development  as  well  as  identifying  relevant 
regulatory and non-regulatory solutions, in full respect of the EU acquis.  

3)  Provide feedback and recommendations to the Commission and Member States 
on relevant policies to ensure the highest safety and environmental standards for 
the development and deployment of SMRs, including through collaboration with 

(165)   European SMR pre-Partnership - nucleareurope 

(166)   REPORT on small modular reactors | A9-0408/2023 | European Parliament  

(167)   Terms of Reference - European Industrial Alliance on SMRs 

76 

 
 
nuclear  regulatory  authorities,  the  European  Nuclear  Safety  Regulators  Group 
(ENSREG) and other public authorities. 

4)  Provide  guidance  and  recommendations  on  relevant  policies  to  raise  public 
awareness about SMRs’ benefits and challenges and launch an open, transparent, 
and  inclusive  debate  with  social  partners,  stakeholders  and  the  civil  society, 
particularly  on  topics  such  as  siting  process,  social  acceptance,  public 
engagement, radioactive waste management and decommissioning of SMRs. 

5)  Identify and prioritise the future needs for qualified and trained workforce and of 
training provision, building on the already existing programmes and instruments. 

6)  Foster  nuclear  research  and  development  activities  with  a  special  focus  on 
developing and deploying innovative nuclear fuels required for AMRs operation.  

7)  Promote  collaboration  with  trusted  international  partners  and  expand  the  EU 

potential to export SMRs technologies to global markets. 

Following  the  establishment  of  the  Alliance,  the  initial  membership  call  elicited 
responses  from  over  300  stakeholders,  encompassing  SMR  technology  designers, 
utilities, energy-intensive users, supply chain companies, research institutes, financial 
institutions, and civil society organisations. The Alliance members and its Governing 
Board were formally confirmed at the inaugural General Assembly in Brussels on 29-
30 May 2024.  

So far, the Alliance has already launched 8 Technical Working Groups which will 
allow  to  address  in  details  key  topics  like  supply  chain,  skills  and  industrial 
competence, licensing, financing, management of spent fuel and radioactive waste, 
public acceptance which are key towards the development of SMRs in Europe.  

In pursuit of tangible project outcomes, the Alliance launched in June 2024 a call for 
SMR projects wishing to be considered for the Alliance’s Project Working Groups. 
Following the 2nd Governing Board meeting, held on 7 October 2024 the first batch 
of SMR projects that would constitute the Project-Working Groups (PWGs) under the 
Alliance  have  been  identified (168).  Building  on  this  the  Alliance  is  developing  its 
Strategic Action Plan by mid-2025 to provide direct support to the identified SMRs 
projects. As announced in the Action Plan for Affordable Energy, the Commission 
will adopt an SMR Communication in 2026.  

To support these activities the Commission, on top of being directly engaged in the 
European  SMR  Industrial  Alliance  as  a  facilitator,  is  also  supporting  research  on 
SMRs’  safety  via  research  projects  co-funded  under  the  Euratom  Research  and 
Training Programme, with focus on safety and licencing aspects. Moreover, the Joint 
Research Centre contributes since many years with research and policy support to the 
operation of nuclear power plants in accordance with the highest safety principles and 
safeguards.  The  safety,  security  and  safeguards  related  research  activities  of  JRC 
address also innovative and new reactors, fuels and fuel cycles with a special focus 
on SMRs and AMRs. The work includes research on new fuel types, new waste forms, 
and innovative materials, also in support to licensing and standardisation. 

(168)   European SMRs Industrial Alliance - PWGs  

77 

 
 
 
5.2.  Nuclear fusion 

Nuclear  fusion  involves  combining  light  atomic  nuclei  to  form  a  heavier  nucleus, 
releasing energy. Unlike nuclear fission, which splits atoms and generates long-lived 
radioactive  waste,  fusion  does  not  produce  long-lived  radioactive  waste  and  is 
inherently  safer  than  nuclear  fission  due  to  the  absence  of  chain  reactions.  The 
primary fuel for fusion — deuterium and tritium — can be sourced from water and 
lithium, ensuring security of supply. As for nuclear fission, fusion reactions do not 
produce  greenhouse  gases,  making  it  a  promising  solution  for  addressing  climate 
change in the long term (169) (170). The energy yield from fusion is significantly higher 
than chemical/combustion reactions, and continuous progress in plasma confinement 
methods (magnetic or inertial) contribute to bring commercial fusion energy nearer. 

On  21  January  2025,  Commission  President  von  der  Leyen  stated  at  the  World 
Economic  Forum  in  Davos  the  need  to  invest  in  “next-generation  clean  energy 
technologies, like fusion”. A recommendation for further support into nuclear fusion 
as a future source of energy is included in the Draghi report (171).  

The momentum is also favourable outside the EU, with a general recognition of the 
potential of fusion energy in future energy mixes, and an acceleration of research and 
demonstration,  with  increased  support  for  the  development  of  innovative  private 
companies. The creation of the world fusion energy group in November 2024 (172), 
following  the 28th  Conference of the Parties to  the UN Framework Convention on 
Climate Change (COP 28) was a clear sign in this sense. 

This  trend is  also  clear,  e.g., in  the US,  the UK, China, Japan, and South-Korea  – 
countries  which  have  all  unveiled  ambitious  roadmaps  and  commitments  for  the 
development  and  commercialisation  of  fusion  energy (173).  These  countries  show 
good  technological  progresses  and  significant  contributions  to  lift  the  fusion 
challenges (174). While approaches for achieving this goal vary from one country to 
another,  a  stronger  cooperation  between  publicly  funded  science  and  the  private 
sector (notably, innovative start-ups), is generally considered as a key enabler. 

Several  approaches  to  achieve  controlled  nuclear  fusion  exist,  each  with  its  own 
advantages and challenges and different level of maturity. The most widely studied 
methods include. 

•  Magnetic Confinement Fusion (MCF): Utilised in devices like tokamaks (ITER, 
Joint European Torus or JET) and stellarators (Wendelstein 7-X), where powerful 

(169)  

IAEA World Fusion Outlook 2024, Non-serial Publications, © IAEA, 2024.  

(170)   Fusion - Frequently asked questions | IAEA 

(171)   “Develop an overarching EU innovation strategy for nuclear fusion energy and support the  creation 
of a public-private partnership to promote its rapid, economically viable commercialisation. […]. The 
deployment of fusion energy will require public and private investment to act in synergy.” 

(172)  

Inaugural Ministerial Meeting of the IAEA World Fusion Energy Group, 6 November 2024, Rome, 
Italy 

(173)   As illustrated, for instance, by the US Department of Energy’s 2024 Fusion Energy Strategy, or recent 
announcements (GPB 410 million investment to accelerate development of fusion energy) from the 
UK government 

(174)  

IAEA World Fusion Outlook 2024, Non-serial Publications, © IAEA, 2024. 

78 

 
 
magnetic fields confine hot plasma to achieve fusion conditions. Superconducting 
magnets permit to improve efficiency. 

•  Inertial  Confinement  Fusion  (ICF):  Uses  high-energy  lasers  or  ion  beams  to 
compress fuel pellets, as demonstrated in the National Ignition Facility (NIF) in 
the US, which achieved net energy gain in 2022. 

•  Hybrid  and  Alternative  Concepts:  Including  magnetised  target  fusion,  field-
reversed  configurations,  and  stellarator-tokamak  hybrids,  aiming  to  optimise 
plasma stability and energy efficiency. 

Despite  recent  advancements,  several  key  challenges  must  still  be  solved  before 
fusion energy can become a commercially viable power source, cf. notably (175). 

•  Energy  Break-even:  Achieving  and  sustaining  net  energy  gain  remains  a 
fundamental  hurdle, requiring more efficient plasma confinement  and advanced 
reactor designs. 

•  Material  Durability:  Developing  materials  capable  of  withstanding  extreme 
temperatures,  radiation,  and neutron irradiation  over extended periods is crucial 
for the longevity and safety of fusion reactors. 

•  Tritium Breeding and Handling: Establishing a sustainable, closed-loop tritium 
breeding cycle to fuel reactors while ensuring safe storage and handling of tritium 
remains a significant engineering challenge. 

•  Regulatory and Public Acceptance: Developing clear, fusion-specific regulatory 
frameworks  and  fostering  public  trust  through  transparent  safety  standards  and 
environmental impact assessments is essential for widespread adoption. 

•  Economic Viability: Reducing the costs of reactor construction, maintenance, and 
fuel  production  to  make  fusion  energy  competitive  with  other  energy  sources 
remains a priority. 

•  Scalability and Grid Integration: Addressing how fusion plants can be integrated 
into existing energy grids and scaled up for widespread electricity production. 

•  Technology  Transfer:  Seizing  opportunities  in  the  short-term  for  developing 

fusion and non-fusion applications of research and raise interest in the field. 

•  Knowledge Management: Ensuring that the tacit knowledge generated in many 
years is not lost to foster risk mitigation, better exploitation, efficiency and issue 
prevention. 

Those  challenges  are  addressed  through  research:  the  European  Co-funded 
Partnership  EUROfusion,  specific  projects  like  the  International  Fusion  Materials 
Irradiation  FacilityDEMO  Oriented  NEutron  Source  (IFMIF-DONES)  and  the 

(175)   Fusion Energy: Potentially Transformative Technology Still Faces  Fundamental Challenges | U.S. 
GAO;  Stakeholders’  projections  of  the  timeline  to  reach  commercially  viable  power  source  range 
from 10 years to several decades. 

79 

 
 
Broader  Approach  activities (176),  IAEA’s  work  on  safety  framework  for  fusion, 
economics studies, and policy developments.  

5.2.1. 

ITER: The EU’s Flagship Project to demonstrate the scientific and 
technological feasibility of fusion  

The  International  Thermonuclear  Experimental  Reactor  (ITER),  based  in 
France, is the world’s largest fusion experiment aimed at demonstrating net energy 
gain  at  a  power  plant  scale.  It  represents  one  of  the  most  ambitious  international 
scientific  collaborations,  with  the  European  Union  being  the  primary  contributor 
(45%)  alongside  China,  India,  Japan,  Korea,  Russia,  and  the  US.  The  project  is 
designed to validate the feasibility of large-scale fusion energy production and serve 
as a prototype for future commercial reactors. 

Economic and technological impacts of ITER 

ITER has generated substantial employment across Europe, particularly in France and 
Spain, which are the largest beneficiaries in terms of job creation. Between 2008 and 
2017,  the  project  created  approximately  34,000  job-years  within  the  EU-28.  The 
direct  employment  impact  includes  construction  jobs  (2,300  at  the  ITER  site  in 
France), industrial manufacturing (1,400 jobs), and business services (2,100 jobs). 

ITER has played a crucial role in establishing a global fusion supply chain, engaging 
companies  across  multiple  sectors,  including  superconducting  magnet  production, 
cryogenic systems, and advanced materials. The project catalysed the development of 
a network of suppliers, many of which secured contracts beyond ITER, supporting 
both public and private fusion initiatives worldwide. In a worldwide perspective, the 
fusion energy supply chain is expected to expand significantly, with private fusion 
initiatives estimated to extend the market to reach EUR 500 million annually (177). 

Economic models indicate that ITER provides a nearly 1:1 return on investment in 
gross value added (GVA) (178). Between 2008 and 2017, the cumulative GVA impact 
was  approximately  EUR  4.8  billion,  almost  equivalent  to  the  amount  spent  on  the 
project. Projections  suggest  that by 2030, ITER  could  generate an  additional EUR 
15.9 billion in GVA and create 72,400 job-years. 

Spin-off effects  further enhance  ITER’s economic impact.  For example, firms  that 
have worked on ITER have gained a competitive edge, allowing them to win contracts 
in  other  industries (179).  This  "ITER  effect"  mirrors  the  benefits  experienced  by 
companies  involved  in  CERN’s  Large  Hadron  Collider,  where  high-tech  suppliers 
saw long-term profitability improvements. 

(176)   For  more  details  see  IFMIF-DONES,  International  materials  facility  IFMIF-DONES  starts 

construction phase - EUROfusion, and BROADER APPROACH 

(177)   Analysis  on  a  strategic  public-private  partnership  approach  to  foster  innovation  in  fusion  energy. 

Trinomics, p. 48 

(178)   Study on the impact of the ITER project activities in the EU, ENER/D4/2017-458, Trinomics, p. 23 

(179)   The giant EB welding machine (K6000) finds further application in pro-beams aerospace business 
and has helped the company to develop a competitive edge for welding assignments in this market, 
in Study on the impact of the ITER project activities in the EU, ENER/D4/2017-458, Trinomics, p. 
112. 

80 

 
 
ITER  has been a major  driver of scientific  and technological  innovation, fostering 
advancements in materials science, superconducting magnet technology, and plasma 
physics.  European  research  institutions  have  leveraged  ITER  funding  to  develop 
intellectual  property  and  enhance  technological  capabilities,  with  researchers 
obtaining PhD degrees through their work on ITER (180). 

Furthermore,  ITER’s  research  has  contributed  to  the  development  of  high-
performance  computing,  remote  handling  systems,  and  diagnostics,  which  have 
applications in industries such as aerospace, medical imaging, and robotics. 

Challenges and future prospects 

While  ITER  marks  a  significant  step  towards  fusion  commercialisation,  it  faces 
several challenges. 

•  Engineering  Complexities  of  a  First-of-a-Kind  (FOAK)  installation:  The 
unprecedented scale and complexity of components such as the vacuum vessel and 
superconducting coils require innovative manufacturing and assembly techniques. 

•  Rising Costs and Delays: The extensive research and construction efforts have 
led  to  budget  overruns  and  project  timeline  extensions,  necessitating  additional 
funding and international support. A new baseline 2024 was presented to the ITER 
members in June 2024 and is under examination. 

•  Tritium Fuel Supply and Handling: Ensuring a sustainable and efficient tritium 
cycle  is  essential  for  long-term  operation,  involving  both  breeding  technologies 
and regulatory compliance. 

Despite these hurdles, ITER remains the cornerstone of global fusion research and of 
the EU fusion strategy, with lessons learned expected to directly inform the design 
and construction of future commercial fusion power plants (within several decades). 

The  knowledge  and  industrial  base  built  through  ITER  will  be  essential  for  the 
development  of  the  EU’s  first  demonstration  fusion  power  plant  (DEMO),  able  to 
produce large quantities of energy on the grid. The DEMO project, developed by the 
European  partnership  EUROfusion (181),  is  tentatively  scheduled  in  2050  and  is 
expected  to  be  financed  through  several  sources  of  investment  for  an  amount  of 
several billions of Euros. The DEMO project will further strengthen Europe’s position 
in  the global fusion industry. Eurofusion will represent  European fusion industries 
and research organisations. The project  also  seeks to  develop  a Strategic Research 
and Innovation Agenda (SRIA) to guide R&D in fusion. 

5.2.2. 

The EURATOM Research & Training Programme 

The Euratom Research & Training Programme is a five-year initiative dedicated to 
advancing  nuclear  research  and  innovation.  In  addition  to  supporting  innovative 
fusion research, the programme also addresses nuclear safety, radiation protection, 

(180)   Study on the impact of the ITER project activities in the EU, ENER/D4/2017-458, Trinomics, pp. 

104-105. 

(181)   DEMO - EUROfusion 

81 

 
 
and  waste  management  within  the  realm  of  fission  (182).  These  global  efforts  are 
executed through grants awarded to research and industry beneficiaries. 

The  current  iteration,  running  from  2021  to  2025,  has  a  total  budget  of EUR  1.38 
billion,  with  EUR  583  million  specifically  allocated  for  fusion  research  and 
innovation. Since 2014, a total budget of EUR 1.66 billion has been committed to 
indirect actions supporting fusion research and innovation. 

EUROfusion serves as the fusion flagship of the Euratom Programme, operating as a 
co-funded  European  partnership  that  unites  leading  research  centres  specialised  in 
fusion research. (183) Established by the European Commission in 2014, EUROfusion 
comprises  30  member  organisations  and  collaborates  with  167  affiliated  entities, 
including nearly all EU Member States, as well as Ukraine, Norway, and Switzerland. 

EUROfusion’s  primary  aim  is  to  harmonise  fusion  research  and  development 
priorities with the ultimate objective of generating electricity from fusion energy. Its 
strategic roadmap is built on three pillars. 

•  Preparing for ITER experiments; 

•  Developing  a  concept  for  DEMO,  a  future  commercial  demonstration  fusion 
power  plant  and  ITER’s  successor,  which  aims  to  connect  fusion  energy  to  the 
grid; 

•  Supporting the IFMIF DONES project focused on fusion materials. 

EUROfusion’s  research  is  wide-ranging,  moving  from  strategies  for  particle  and 
power exhaust to safety, maintenance and design activities.  

Organisationally,  EUROfusion  is  a  European  partnership  and  encompasses  Work 
Packages on fusion science, fusion technology but also on communication, education, 
and public engagement. To support these objectives, EUROfusion employs a team of 
approximately 5,000 researchers, technicians, and administrators.  

Technology transfer 

A  key  aspect  of  EUROfusion  is  the  focus  on  technology  transfer  with  the  goal  of 
disseminating  research  results  and  fostering  collaboration  with  industry.  The 
partnership  has  engaged  with  industry  in  several  ways.  From  2014  to  2021,  it 
subcontracted  and  partnered  with  companies  as  affiliated  entities,  allocating  EUR 
35.5  million.  Additionally,  a  framework  contract  valued  at  EUR  10.14  million, 
spanning  from  2020  to  2024,  was  awarded  by  large  industrial  group  to  provide 
expertise. 

(182)  

In  particular,  research  and  development  (R&D)  in  nuclear  fission  is  crucial  for  enhancing  safety, 
including waste management, improving efficiency, and ensuring  sustainability. In terms of safety, 
R&D  focuses  on  advancing  reactor  safety  measures,  developing  sophisticated  waste  management 
solutions, and optimising fuel cycles. Efforts to improve efficiency aim to boost reactor performance 
and extend operational lifespans while considering economic viability. Achievements in these key 
areas of nuclear fission are a pre-requisite for public acceptance. 

(183)   For more details, see EUROfusion - Realising Fusion Energy 

82 

 
 
As  the  new  F4E  leadership  has  placed  the  development  and  consolidation  of  a 
European  fusion  supply  chain  at  the  heart  of  the  revised  industrial  policy,  F4E 
continues its efforts to map all relevant actors and their respective capabilities and 
encourage the development of clusters, as this is the case in other sectors such as the 
aerospace  and  the  microelectronics.  In  particular,  as  part  of  its  Technology 
Development programme (TDP), F4E aims to develop a comprehensive view of all 
the key enabling technologies needed before moving towards commercial fusion (e.g., 
tritium  breeding,  materials  qualification).  To  this  end,  F4E  collects  and  organises 
input from its competent experts and key external stakeholders to prepare its annual 
action plans, prioritising technology  development  activities in  order to  support the 
competitiveness  of  European  industry.  The  Technology  Transfer  Programme 
implemented  by  F4E  seeks  to  lay  the  foundations  for  a  structured  and  sustainable 
innovation  ecosystem  by  promoting  the  creation  of  new  businesses  based  on  the 
commercial exploitation of fusion breakthroughs in new markets. 

The alignment of technology transfer activities between  F4E and EUROfusion has 
recently led to the creation of a common platform (184) listing concrete applications, 
resulting from the participation of the European companies in ITER. The aim of this 
list  prepared  by  F4E  and  EUROfusion  is  to  promote  the  portfolio  of  technologies 
developed by F4E by making them widely available and commercially viable. 

5.2.3. 

Recent developments in private innovative projects 

Private Sector Growth and Funding 

Fusion  is  no  longer  a  “public  affair  only”.  An  increasing  number  of  startups  and 
ventures have emerged with the aim of privately developing this energy source. Their 
budget has been projected to be EUR 6.61 billion in 2024, marking a 1.5-fold increase 
since  2021  (185).  In  the  same  period,  the  number  of  fusion  entities  worldwide  has 
nearly  doubled,  reaching  a  total  of  45.  The  United  States  hosts  the  largest 
concentration, with 25 entities. The EU hosts 7 startups, but the interest of numerous 
companies  (from  France,  Germany,  Italy,  and  Spain)  highlights  the  Union’s 
dedication to advancing this innovative field of energy production. 

Table 12 shows the amount of public investment by national authorities. 

(184)   Fusion Technology portfolio - Fusion Technology Transfer 

(185)   FIA Launches 2024 Global Fusion Industry Report - Fusion Industry Association 

83 

 
 
Table 12 – Public investment on fusion by national authorities (non-exhaustive list) 

Countries 

Amount invested by national authorities 

China 
United States  
Japan 
United Kingdom 
Germany  
Italy 

USD 1,000 – 1,500 million annually 
USD 763 million in 2023 
Not available 
GBP 650 million over 2023–2027  
EUR 1,370 million over 2024–2029 
EUR 500 million over 30 years 

Source:  Different press articles. Figures not fully comparable. For Italy, amount above mentioned 
include the participation of a private investor (ENI, the energy company), which have joined 
the  consortium  led  by  ENEA,  the  Italian  national  advanced  energy  agency  to  build  the 
Divertor Tokamak Test (DTT). 

The overview given in Table 12 does not include the contributions to ITER, which 
represent a budget of approximatively EUR 651 million annually (186).  

The EU is the host of seven Fusion start-ups. 

•  Proxima Fusion (Germany): developing quasi-isodynamic stellarators (magnetic 
high-temperature 
power  plants, 

leveraging 

confinement) 
fusion 
superconductors and computational optimisation. 

for 

•  Gauss  Fusion  (Germany):  developing  high-field  magnetic  confinement  fusion 

for fusion power plants. 

•  Novatron  (Sweden):  developing  an  open-field  line  (magnetic)  confinement 

solution for fusion power plants. 

•  Marvel  Fusion  (Germany):  developing  a  laser-driven  fusion  solution  (inertial 

confinement). 

•  Focused Energy (Germany): developing a laser-driven fusion solution (inertial 
confinement), focusing on optimising the fuel and laser systems, and integration. 

•  Renaissance  Fusion  (France):  developing  stellarator  solutions  (magnetic 
confinement), working e.g. on high-temperature superconductor coils design and 
neutron shielding and heat extraction. 

•  Deutelio  (Italy):  developing  a  magnetic  confinement  solution  (“Polomac”)  for 

fusion power plants. 

At  the  international  level,  the  following  companies  are  illustrative  of  the  fast 
development of the sector. 

•  Commonwealth  Fusion  Systems  (CFS):  Developing  a  compact  high-field 
tokamak leveraging high-temperature superconductors to achieve net energy gain. 

(186)  

ITER - Performance - European Commission 

84 

 
 
•  Helion  Energy:  Pursuing  magnetised  target  fusion  with  direct  electricity 

conversion, targeting electricity production within a decade. 

•  TAE Technologies: Working on field-reversed configurations with an emphasis 

on using hydrogen-boron fuel cycles to reduce neutron production. 

•  Tokamak  Energy  (UK):  Focused  on  spherical  tokamaks,  aiming  to  develop 

commercial fusion power plants by the late 2030s. 

•  General Fusion (Canada): Developing magnetised target fusion with liquid metal 

walls to improve plasma stability and energy efficiency. 

•  ENN (China): Upgrade of a spherical tokamak, aiming to develop a pilot plant by 

2038. 

Public-Private Partnerships (PPP) 

Public-private  partnerships  can  play  a  crucial 
the 
commercialisation  of  fusion  energy  by  leveraging  the  strengths  of  both  sectors. 
Governments provide funding stability, regulatory support, and large-scale research 
facilities,  while  private  enterprises  bring  innovation,  agility,  and  commercial 
expertise. 

in  accelerating 

role 

The fusion PPP aims at supporting EU innovation on key enabling technologies for 
fusion  with  the  goal  to  contribute  to  future  DEMO  design  and  development,  to 
maintain EU industrial know-how and competitiveness, and to leverage EU scientific 
leadership and the ITER project. 

The benefits of PPPs can be summarised as follows. 

•  Risk Mitigation: Reducing financial and technological uncertainties by sharing 

costs and expertise between governments and private investors. 

•  Accelerated  Innovation:  Enabling  faster  prototype  development  through 

collaborative research and shared technological advancements. 

•  Infrastructure  Sharing:  Providing  access 

to  cutting-edge  facilities  and 
specialised  equipment  that  may  be  too  costly  for  private  entities  to  develop 
independently. 

•  Regulatory  Support:  Aligning  policy  frameworks  to  create  a  predictable  and 

conducive environment for fusion energy commercialisation. 

•  Long-Term  Investment  Stability:  Ensuring  sustained  financial  backing  and 

market confidence through government participation. 

In 2023, the Commission launched a study to examine best PPP arrangements options 
at EU level. In particular, three instruments (a Co-Programmed European Partnership, 
F4E  Innovation  Partnerships  and  the  EIT-KIC  InnoEnergy)  were  identified,  each 
addressing  different  needs  and  is  complementary  towards  achieving  the  proposed 
benefits.  

85 

 
In an effort to connect the public and private sectors, the European Commission is in 
a  process  of  creating  a  European  Fusion  Stakeholder  Platform  which  will  bring 
together industry (including supply chain, startups, energy providers and investors), 
technology  centres,  academia  and  research  organisations.  This  platform  will  be 
engaged  in  the  definition  of  an  Industry-led  European  association  with  legal 
personality  and  will  sign  the  Memorandum  of  Understanding  with  the  European 
Commission for the creation of the PPP (Public–private partnership) based on SRIA 
(Strategic  Research  and  Innovation  Agenda)  developed  by  the  Platform.  In  the 
framework  of  the  Partnership,  the  Platform  is  prepared  to  engage  the  EU  fusion 
industry,  support  innovation  in  alternative  fusion  concepts,  and  address  critical 
technology  bottlenecks.  This  will  be  done  through  calls  issued  in  2026  and  2027, 
where the gap identified by the platform will be taggle by jointed effort of industry 
and public bodies. 

Recently an Important Projects of Common European Interest (IPCEI) (187) proposal 
was introduced by a Member State with a view to complement the current fusion area 
innovation-to-
the  full 
initiatives  and  foster  a  cohesive  approach  across 
commercialization pipeline, through different means including PPPs. 

On PPP initiatives and timeline, it is worth to mention EU Fusion for Energy (F4E) 
(2007-Present),  which  facilitates  collaboration  between  public  institutions  and 
private companies, including start-ups, providing grants and infrastructure to support 
fusion startups. Key partnerships include contributions to ITER and emerging private-
sector projects. 

Also, the US Department of Energy’s Milestone-Based Fusion Program (2022-
Present)  offers  financial  incentives  tied  to  performance  milestones,  encouraging 
private  sector  advancements  in  fusion  technology.  The  program  has  accelerated 
prototype development efforts, with multiple companies targeting net energy gain by 
the 2030s. 

The  UK’s  STEP  Program  (2021-2040)  is  a  national  initiative  focusing  on 
commercial  fusion  power  plant  development,  with  the  goal  of  delivering  a  fully 
operational  demonstration plant by 2040. Industry partnerships and public funding 
play a central role in advancing STEP’s milestones. 

By fostering these partnerships, governments and private firms can create a pathway 
to achieving commercially viable fusion energy within the coming decades. 

5.2.4. 

Development of regulatory frameworks 

The development of regulatory frameworks for fusion energy is essential to facilitate 
its  commercialisation  while  ensuring  safety,  efficiency,  and  public  trust.  Unlike 
fission-based nuclear energy, fusion presents different safety challenges, requiring a 
tailored regulatory approach that balances innovation with precautionary measures. 

At  present,  no  country  has  a  dedicated  comprehensive  fusion-specific  regulatory 
framework  although  a  number  of  experimental  fusion  facilities  such  as  JET  (Joint 
European Torus) and ITER have been subject to safety regulations. 

(187)   Approved  integrated  Important  Projects  of  Common  European  Interest,  IPCEI  -  European 

Commission  

86 

 
 
While there is no international consensus on regulatory approach for fusion facilities, 
the  opinion  that  the  nuclear  safety  framework  for  fission  power  reactors  is  not 
appropriate  for  fusion  reactors  is  rather  spread  within  the  fusion  community  and 
regulators, who share the view that the fusion specificities should be addressed with 
a proportionate approach, taking the potential hazards in full consideration. 

The need for a differentiated, and proportionate, approach is also one conclusion of a 
EUROfusion  working  group  established  to  deliver  recommendations  on  the 
regulatory framework for the safety and licensing of fusion power plants (188) (189). 

At EU level, the question is focused on whether and how the existing nuclear safety, 
waste management and the radioprotection framework should be adapted to fusion 
needs. In this sense, the Commission is consulting interested stakeholders and notably 
the ENSREG (190).  

The Commission objectives are: 

•  To ensure safety for both the workers and the public, together with the protection 

of the environment for each fusion installation. 

•  To  provide  industry  and  research  organisations  with  a  regulatory  framework 
aiming at ensuring a common approach and at optimising the time and cost of the 
licensing process. 

The Commission also participates in international efforts on the topic: 

International Atomic Energy Agency (IAEA): The IAEA is leading global efforts 
to create harmonised regulatory approaches. At this stage, it collects “Experiences for 
Consideration in Fusion Power Plant Design Safety and Safety Assessment” (TecDoc 
2076) that will be followed by specific safety reports. 

ITER  and  International  Collaboration:  The  ITER  project  has  established 
precedent-setting  regulatory  procedures  that  serve  as  a  model  for  future  fusion 
facilities worldwide. As the largest international fusion experiment, ITER has brought 
together  scientists,  engineers,  and  policymakers  from  35  countries  to  develop  a 
comprehensive  regulatory  approach.  This  collaboration  has  helped  refine  best 
practices  in  safety,  licensing,  and  operational  procedures,  influencing  national 
regulatory frameworks.  

National approaches 

•  United  States:  The  2024  ADVANCE  Act  classifies  fusion  under  by-product 
material  regulations,  significantly  easing  regulatory  burdens  compared  to 
traditional nuclear fission plants. The US Nuclear Regulatory Commission (NRC) 
is also working on dedicated fusion-specific regulations to streamline licensing. 

(188)   J. Elbez-Uzan et al., Recommendations for the future regulation of fusion power plants, Nucl. Fusion 

64 (2024), https://iopscience.iop.org/article/10.1088/1741-4326/ad13ad/pdf  

(189)   Considerations for the future regulation of fusion power plants by Joelle Elbez-Uzan, © IAEA, 2024. 

(190)   European Nuclear Safety Regulators Group, ENSREG  

87 

 
 
•  United Kingdom: The UK government is developing a proportionate regulatory 
framework tailored to fusion energy, focusing on risk-based licensing that reflects 
the inherently safer nature of fusion compared to fission. 

•  Other  Countries:  China,  Japan,  and  Canada  are  also  actively  shaping  their 
regulatory  policies,  drawing  insights  from  international  research  programs  and 
ongoing fusion experiments. 

A well-structured regulatory framework could play a pivotal role bringing a high level 
of safety  and predictability on licensing time and cost  and  enabling the  successful 
transition  of  fusion  energy  from  experimental  research  to  large-scale  commercial 
deployment. 

5.2.5. 

Need for an EU Strategy on Fusion 

It  is  very  important  to  link  further  investments  in  fusion  research  to  a  broader 
European action, aimed at mastering fusion not just as a research topic but as a tool 
for  long-term  energy  independence,  sustained  decarbonisation  in  the  long  term,  as 
well  as  European  industrial  competitiveness.  This  ‘momentum’  (please  see  section 
5.2) shows the strong support to the development of such EU Energy Strategy within 
a large worldwide context.  

International  developments  show  rapid  and  massive  investments  both  public  and 
private  in  conjunction  with  national  fusion  strategies  developments  such  as  the 
publication of the UK Fusion Strategy in 2021 (and its update in 2023), the Japan’s 
Fusion Energy Innovation Strategy published in 2023, and the Fusion Energy Strategy 
2024 published by the US DoE. There is a clear identified risk for the EU to lose its 
leadership (191).  

The  Commission’s  March  2024  study (192),  the  Draghi (193)  report  and  the  recent 
European  Parliament (194)  debate  on  Fusion  energy  highlight  the  need  for  an 
overarching EU fusion innovation strategy and a public-private partnership to fast-
track  fusion  commercialisation.  Moreover,  this  would  give  a  strong  message  to 
private investors and mitigate the above-mentioned risk. 

The adoption of a comprehensive EU fusion strategy, as announced in the Action Plan 
for  Affordable  Energy  and  foreseen  for  the  end  of  2025,  with  EU’s  leading 
participation in ITER confirmed as its cornerstone, would pave the fastest possible 
way to the fusion energy commercialisation. 

The proposed strategy will aim at establishing a comprehensive EU-wide approach. 
It  will  cover  several  topics,  including  advancing  the  construction  of  ITER,  critical 
technological gaps, promoting stakeholder dialogue, international collaborations with 

(191)   Most of the private investment goes to the US (source FIA) 

The  EU  has  progressively  lost  its  share  in  nuclear  fusion  patents  while  China  has  increased  it 
significantly. 

(192)   New  Commission  report  on  potential  public-private  partnership  approach  to  foster  innovation  in 

fusion energy 

(193)   The Draghi report on EU competitiveness 

(194)   European  Parliament  plenary  session  in  Strasbourg,  Sitting  of  20-01-2025  |  Plenary  |  European 

Parliament 

88 

 
 
 
trusted partners, and an effective EU-level decision-making process. The strategy will 
aim at setting the stage for the developing a future pilot fusion power plant capable 
of  producing  net  electricity,  a  pivotal  milestone  for  the  industrial  growth  and 
commercialization of fusion energy. 

DG RTD and DG ENER have set up an informal Commission Expert Group known 
as  the  Fusion  Expert  Group  (FEG)  in  collaboration  with  EU  Member  States.  This 
group aims to streamline governance of all research and innovation activities related 
to fusion and provide advice to the Commission on fusion energy policy. Presently, 
the group’s tasks are primarily focused on reflecting on and contributing to the EU 
Fusion Strategy. Since its inaugural meeting on 26 June 2024, the group has engaged 
in  highly  productive  discussions  about  the  strategy’s  five  pillars  through  regular 
subgroup meetings and plenary sessions. An opinion paper from the FEG is expected 
to be completed by the first or second quarter of 2025. 

In  addition,  relevant  stakeholders  were  consulted  also  through  recently  organised 
events (195). 

Innovation pillar & European Innovation Council (EIC) funding 

The  European  Innovation  Council,  the  main  element  of  the  innovation  pillar  of 
Horizon  Europe,  supports  game  changing  innovations  throughout  the  entire 
innovation  lifecycle  from  early-stage  research  to  proof  of  concept,  technology 
transfer, and the financing and scale up of startups and SMEs. 

(195)   Fostering Fusion Innovation: High-Level European Roundtable (14 March 2024, Brussels), the EU 
Blueprint for Fusion Energy Conference (23 April 2024, Strasbourg), the EU Fusion Business Forum 
(3-4 July 2024, Berlin). 

89 

 
 
 
6.  ENABLERS 

In this chapter, the document delves into the EU’s regulatory capacity (Section 6.1), 
explores how trust is built through transparency measures (Section 6.2), discusses the 
development  of  skills  and  human  resources  within  the  industry  (Section  6.3),  and 
examines international partnerships (Section 6.4). 

Nuclear liability in case of an accident is another important element related to nuclear 
safety, public perception but also to legal certainty for investors. In the EU, nuclear 
third-party  liability  is  governed  by  national  law  and  shaped  by  two  international 
conventions, the 1960 Paris Convention or the 1963 Vienna Convention (196).  

6.1.  Regulatory capacity 

6.1.1. 

High-level qualitative requirements on the regulatory resources in 
the international and Euratom legislation on nuclear safety, spent 
fuel and radioactive waste management and decommissioning 

Having a strong and independent regulatory authority is instrumental to achieve 
a  high  level  of  nuclear  safety.  Endowing  the  national  regulators  with  sufficient 
resources  –  both  human  and  financial  –  to  carry  out  their  tasks  of  regulating, 
monitoring, and enforcing nuclear safety rules, as well as securing the safety of the 
spent fuel and radioactive waste management is an essential component of regulatory 
independence (197). This principle has been laid down in various international and 
Euratom  legal  instruments,  as  exemplified  in  Table  13  (198).  EU  Member  States 
incorporate  relevant  requirements  into  their  nuclear  safety-related  legislative, 
regulatory, and administrative measures, taking into account national specificities. 

(196)   Most of the Member States which joined the EU before 2004 are Parties to the Paris Convention and 
to  its  Supplementary  Convention,  the  Brussels  Convention,  adopted  under  the  auspices  of  the 
Organisation for Economic Co-operation and Development (OECD). Most of the EU Member States 
which  joined  the  EU  in  2004  and  2007  as  well  as  Croatia,  are  Parties  to  the  Vienna  Convention 
adopted under the auspices of the International Atomic Energy Agency (IAEA). 

(197)   A further challenge for nuclear safety regulators may arise from evolving requirements for nuclear 
safety,  for  instance  through  the  necessity  to  adapt  to  climate  change.  Existing  (and  planned) 
installations may need to anticipate that cooling with river water may not be possible all year due to 
lower water levels, and additional efforts may be required to achieve resilience against more severe 
extreme weather events (including downfalls leading to local flooding). In the context of placing small 
modular reactors, extreme weather events may expose them to the risk of damage or sudden lack of 
access to maintenance. The JRC has analysed these aspects as part of its “Technical assessment of 
nuclear  energy  with  respect  to  the  ‘do  no  significant  harm’  criteria  of  Regulation  (EU)  2020/852 
(‘Taxonomy Regulation’)”. 

(198)   At the same time, the environmental acquis must be strictly implemented, through assessments such 
as those stemming from Directive 2011/92/EU on the assessment of the effects of certain public and 
private projects on the environment, Directive 2001/42/EC on the assessment of the effects of certain 
plans  and  programmes  on  the  environment,  Directive  92/43/EEC  on  the  conservation  of  natural 
habitats  and  of  wild  fauna  and  flora,  and  Directive  2000/60/EC  establishing  a  framework  for 
Community action in the field of water policy. 

90 

 
 
 
Table 13 – Requirements on the adequacy of the regulatory resources 

Level 

Legally binding and non-legally binding instruments 

International 
level 

Convention on 
        S      (•) 
Joint Convention 
on the Safety of 
Spent Fuel 
Management and 
on the Safety of 
Radioactive Waste 
M          (†) 
IAEA safety 
standards (‡) 

Article 8, paragraph (1) 

Article 20 

Examples: 
−  Fundamental Safety Principles, IAEA Safety 

Standards Series No. SF-1, 2006 
−  Governmental, Legal and Regulatory 
Framework for Safety, IAEA Safety 
Standards Series No. GSR Part 1 (Rev. 1), 
2016 

−  Management and Staffing of the Regulatory 
Body for Safety, IAEA Safety Standards 
Series No. GSG-12, 2018 

−  Functions and Processes of the Regulatory 
Body for Safety, IAEA Safety Standards 
Series No. GSG-13, 2018 

−  Managing Regulatory Body Competence, 
Safety Reports Series No. 79, 2013 

Euratom 
level 

Nuclear Safety 
Directive (*) 

Article 5 paragraph 2, letter (c) 
Article 5 paragraph 2, letter (d) 

Radioactive Waste 
Directive (§) 

Article 6 

Source: 

(•) I   IR /  9      J     99  
(†) I   IR /          D         997 
(‡) S   IAEA          www.iaea.org/resources/safety-standards 
(*)         D            9/7 /E       
(§) Council Directive 2011/70/Euratom 

Focusing  on  the  Euratom  legislation,  the  Nuclear  Safety  Directive  addresses 
explicitly  the  regulatory  resources  aspect.  First,  with  respect  to  the  financial 
resources,  the  Directive  requires  that  the  national  competent  regulatory  authority 
must be provided with ‘dedicated and appropriate budget allocations to allow for the 
delivery of its regulatory tasks as defined in the national framework’ and should be 
‘responsible for the implementation of the allocated budget.’ (199) Second, as regards 
the human resources, the regulator should employ ‘an appropriate number of staff 
with qualifications, experience and expertise necessary to fulfil its obligations.’ The 
Directive also acknowledges the possibility of using ‘external scientific and technical 
resources  and  expertise  in  support  of  [the  competent  regulatory  authorities’] 
regulatory functions,’ (200) while encouraging the enactment of rules to prevent and 
resolve potential conflicts of interest. (201)  

(199)   Article 5 paragraph 2, letter (c), Nuclear Safety Directive. 

(200)   Article 5, paragraph 2, letter (d), Nuclear Safety Directive. 

(201)   Recital 9, Preamble of Council Directive 2014/87/Euratom. 

91 

 
 
 
 
 
 
The  Radioactive  Waste  Directive  also  contains  separate  provisions  on  regulatory 
authorities. First, it requires the Member States to ‘establish and maintain a competent 
regulatory  authority’  that  is  ‘functionally  separate  from  any  other  body  or 
organisation  concerned  with  the  promotion  or  utilisation  of  nuclear  energy  or 
radioactive  material’.  Second,  the  Member  States  must  ensure  that  the  regulatory 
authority has ‘the legal powers and human and financial resources necessary to fulfil 
its obligations’. 

The Directives, therefore, set out high-level provisions to ensure that the competent 
regulatory authorities are provided with adequate resources to properly carry out their 
assigned responsibilities (202). Insofar as they comply with the Directives’ obligations, 
the  Member  States  have  the  flexibility  to  choose  the  appropriate  transposition 
instruments and to put in place implementation tools and mechanisms. It is essential 
that providing sufficient resources to the regulatory authorities remains a top priority 
–  both  for  the  regulators  and  for  the  other  relevant  Member  States’  authorities, 
particularly those responsible for approving the state budget.  

6.1.2. 

Diversity  of  national  approaches  to  ensure  the  adequacy  of  the 
regulators’ financial and human resources  

the  characteristics  of 

At the Member State level, national circumstances (203) play an important role in 
developing the domestic approaches on regulatory resources. General considerations 
include  the  national  policy  in  respect  to  the  use  of  nuclear  energy  for  generating 
electricity, 
legislative,  regulatory,  and 
organisational  framework,  and  the  types  and  number  of  nuclear  installations  in 
operation or planned (as well as under decommissioning). Specific considerations are 
linked to the legal status and structure of the regulatory body (204), its concrete tasks, 
or  the  use  of  in-house  and  outsourced  competences. Without  prejudice  to  these 
national variables, regulators typically use a systematic approach to estimate their 
resources needs. (205)  

the  national 

It should be noted that the regulatory activities pertinent to new nuclear build and the 
lifetime extension of existing plants in the EU cover a wide variety of aspects, such 
as  nuclear  safety,  nuclear  safeguards,  nuclear  security,  radiation  protection, 
emergency preparedness and response. However, this section of the PINC discusses 
regulatory  capacity  in  respect  to  nuclear  safety  only,  since  regulatory  capacity  for 
nuclear safety is a fundamental feature for informing other regulatory tasks, focusing 
further on the regulatory activities related to licensing. From a nuclear safety angle, 
the  Commission’s  second  report  on  the  implementation  of  the  Nuclear  Safety 

(202)   Regulatory  capacity  and  resources  must  be  maintained  and  further  enhanced  to  ensure  robust 
safeguards and security. However, assessing these specific needs falls outside the scope of the current 
PINC Staff Working Document. 

(203)   Organization, Management and Staffing of the  Regulatory Body for Safety, General Safety Guide 

No. GSG-12, © IAEA, 2018. 

(204)  

In the EU, three organisational schemes can be identified: (i) regulatory authorities as self-standing 
administrative  authorities;  (ii)  regulatory  authorities  as  administrative  authorities,  which  are  not 
organisationally part of a specific Ministry, but fall under its supervision; (iii) regulatory authorities 
are  Directorates/Departments  or  Units/Services  of  Ministries  that  are  not  concerned  with  the 
promotion or utilisation of nuclear energy.  

(205)   ENSREG  Guidelines  regarding  Member  States  Reports  as  required  under  Article  9.1  of  Council 
Directive 2009/71/EURATOM of 25 June 2009 establishing a Community framework for the nuclear 
safety of nuclear installations, HLG_p(2012-21)_108. 

92 

 
 
Directive, (206) hereinafter referred to as the ‘2022 NSD Progress Report’ addressed 
the issue of regulatory resources, (207) based, primarily, on information drawn from 
the Member States’ national reports. (208) While more details are available in the 2022 
NSD Progress Report, Table 14 provides a summary of the domestic approaches on 
the topic of regulatory resources, as identified in this progress report.  

Table 14 – Common trends on resources of regulatory authorities in Member States 

Topic 

Summary 

National framework 
Type of 
requirements 

provisions 

−  General and/or specific legal requirements, general budgetary 

−  Specific regulatory procedures (in some cases) 

Financial resources 
Financing 
models 

−  State budget allocations or 
−  Combination of budgetary funds and recovery of incurred costs 

Role of the 
regulators 

Additional 
resources 

Transparency of 
expenditure 

from licence holders or service charges 

−  Planning of financing needs (notably as regards State budget 
         ) →              (         ) /                   ( . . 
3-year perspective)  

−  A                                                →        

plans 

−  Various mechanisms:  

o  special fees from the licensees 
o  state mechanisms in the budgetary procedures 
o 
o 

rebalancing funds among activities 
recourse to the state reserve 

−  non-limited credits for exceptional situations etc. 
−  Various mechanisms: 

o  key performance indicators,  
o  publication of annual reports  
−  publication of audit conclusions etc. 
−  Ensuring adequate financing of regulatory activities 

Areas for further 
work (some 
instances) 
Human resources (numbers and qualifications) 
Role of the 
regulators 

−  Evaluation of staffing needs (usually feeding into the financial 

        ) →              (         ) /                   ( -year 
perspective), complemented by operational plans / other types 
of evaluations 

Additional 
resources 
Staff 
qualification 

−  Recruitment of new staff 
−  Staff allocation 
−  Training (for new and existing staff) 
−  Possibility to request additional resources / flexibility clauses 

(in some cases) 
−  Various mechanisms: 

o  education and expertise conditions upon recruitment 
o 

initial training for newcomers 

(206)   Report from the Commission to the Council and the European Parliament on the progress made with 
the  implementation  of  Directive  2009/71/Euratom  establishing  a  Community  framework  for  the 
safety  of  nuclear  installations  amended  by  Directive  2014/87/Euratom  (COM/2022/173  final), 
accompanied by a Staff Working Document (SWD/2022/107 final). 

(207)   COM/2022/173 final (section 2.2), and SWD/2022/107 final (sections 2.2.1.3 and 2.2.1.4). 

(208)   Nuclear safety 

93 

 
 
External 
expertise 

Areas for further 
work (some 
instances) 

−  continuous training (recourse to a combination of in-house and 

external sources) etc. 

−  Commonly used to support regulatory decisions 
−  Various types of external expertise:  
o  scientific councils or committees  
o 

institutes or technical support organisations (TSOs) 
specifically established  

−  outside experts / consultants (specific projects) 
−  Maintaining appropriate staffing 
−  Attracting and keeping sufficient and/or qualified staff (in some 

cases, this shortage is covered by resorting to external 
expertise). 

Source:  European Commission 

The Commission made several observations addressed to the Member States in the 
2022 NSD Progress Report, and, on this basis, highlighted areas where there is scope 
for  future  action  at  EU  level  to  continuously  improve  nuclear  safety  in  the  EU. 
Specifically on the topic of regulatory resources, in its observations, the Commission 
stressed  the  need  to  enact  specific  legal  provisions  requiring  that  adequate  and 
dedicated financial and human resources (for the latter, both in terms of numbers and 
qualifications)  are  available  to  regulators,  supported  by  mechanisms,  criteria  and 
procedures,  including  flexibility  mechanisms  allowing  the  regulators  to  receive 
additional resources. (209)  

Furthermore, regulatory independence – including the components of the ‘dedicated 
and  appropriate  budget  allocations’  and  ‘appropriate  number  of  staff  with 
qualifications,  experience  and  expertise,  and  preservation  of  knowledge’  –  was 
highlighted  as  a  key  topic  where  a  common  approach  at  EU  level  could  be 
beneficial. (210)  In  line  with  the  2022  NSD  Progress  Report  and  considering  the 
outcomes of a workshop held in November 2022 to discuss the report’s findings with 
relevant  stakeholders  (including  regulators),  regulatory  independence  (together 
with  the  nuclear  safety  objective,  and  safety  culture)  were  confirmed  as  priority 
nuclear safety areas. Consequently, since 2023, with contractual support, (211) the 
Commission  has  been  focussing  on  these  topics  with  the  aim  of  identifying  good 
examples amongst the Member States’ practices and practical proposals that could be 
considered by the Member States when implementing the Directive’s requirements. 
For a wide and transparent dissemination of the results of the study contracted by the 
Commission, its findings will be discussed at a workshop planned to be organised in 
2025 with stakeholder participation. 

In the third Waste Report (212) it is concluded that Member States had at least one 
competent  regulatory  authority.  In  a  few  cases,  the  arrangements  are  such  that 
local/regional  competent  authorities  work  together  with  national  authorities  when 
they  deal  with  radioactive  waste  management;  the  related  national  reports  did  not 

(209)   COM/2022/173 final., section II, sub-section 2.2. 

(210)   COM/2022/173 final, section IV. 

(211)   Call for Tender “Support to EU Member States in the continued implementation of the Nuclear Safety 

Directive”, ENER/D3/2022-47 (ENER/LUX/2022/OP/0007). 

(212)   Report  from  the  Commission  to  the  Council  and  the  European  Parliament  on  progress  of 
implementation of Council Directive 2011/70/EURATOM and an inventory of radioactive waste and 
spent  fuel  present  in  the  Community's  territory  and  the  future  prospects  -  THIRD  REPORT 
{COM(2024) 197 final} - {SWD(2024) 127 final} 

94 

 
 
provide information on their roles and responsibilities, or on how they interact with 
each other. 

While  most  Member  States  devised  mechanisms  to  retain  skilled  staff  within  the 
regulatory  authorities,  some  faced  challenges  in  maintaining  adequate  human 
resources  in  the  long  term.  Outcomes  of  recent  international  peer  review  missions 
confirmed  this  trend.  Most  national  reports  provide  information  on  measures  for 
ensuring  technical  and  financial  independence  of  the  competent  regulatory 
authorities. A total of 19 Member States provided actual staff numbers; therefore, the 
information in Table 3 of the accompanying staff document to the Waste Report (213) 
does not cover the full EU-27.  

6.1.3. 

Regulators play a strategic role in ensuring the safe completion of 
nuclear new build investment projects  

The  EU  Member  States  have  a  rather  diverse  energy  mix.  For  nuclear  energy,  the 
situation  varies  from  those  that  have  one  or  more  nuclear  power  plants,  to  those 
without any. Some Member States plan to continue or even increase nuclear energy 
generation, while others have decided to discontinue operations after a certain date or 
have prohibited the construction of new plants. In the current global context, marked 
by an increasing support of nuclear energy to meet both climate objectives and the 
challenge  of  ensuring  secure  and  affordable  energy, (214)  several  Member  States 
intend  to  expand  their  electricity  generation  portfolio  with  new  nuclear  power 
reactors, as indicated in section 2.1. 

The  nuclear  energy  projects  typically  face  ‘complex  project  planning  period,  long 
construction  timelines,  regulatory  complexities,  long  payback  periods  and  lengthy 
debt tenors.’ (215) involving a wide variety of stakeholders (governments, regulators, 
industry, public).  In light  of their complexity, such projects  generate  an  additional 
workload for the regulatory authorities; the issue of sufficient financing and staffing 
comes, therefore, into the spotlight. As an illustration, one of the actions included in 
the  Summary  Report  of  the  8th  and  9th  Review  Meeting  under  the  Convention  on 
Nuclear  Safety  was  that  ‘Contracting  Parties  should  establish  durable  capacity 
building  programmes  to  align  regulatory  capabilities  with  future  needs.’  (216)  In 
addition, several IAEA Integrated Regulatory Review Service (IRRS) mission results 
(217) stress the importance of ensuring adequate staffing and financing of regulatory 
activities, highlighting instances when additional work is needed. 

(213)   Commission  Staff  Working  Document  Accompanying  the  Report  from  the  Commission  to  the 
Council  and  the  European  Parliament  on  progress  of  implementation  of  Council  Directive 
2011/70/EURATOM and an inventory of radioactive waste and spent fuel present in the Community's 
territory and the future prospects  - THIRD REPORT {COM(2024) 197 final}  - {SWD(2024) 127 
final} 

(214)   Nuclear Technology Review 2024, Report by the Director General, GC(68)/INF/4, © IAEA, 2024. 

(215)   Climate  Change  and  Nuclear Power  2024:  Financing  Nuclear  Energy  in  Low  Carbon  Transitions, 

Non-serial Publications, © IAEA, 2024. 

(216)   CNS/8&9RM/2023/08 – Final of 31 March 2023. 

(217)   See the IRRS mission reports available at https://www.iaea.org/services/review-missions/integrated-

regulatory-review-service-irrs 

95 

 
 
In  the  context  of  the  nuclear  energy  projects,  the  regulators’  role  is  instrumental, 
notably for the following activities. (218) 

•  Developing  regulations  for  the  licensing  process  of  nuclear  installations  and 
providing guidance to the applicants to provide clarity in the licensing process and 
assessing licence applications. 

•  Conducting  reviews,  assessments,  and  inspections  to  evaluate  the  applicants’ 

compliance with the regulatory requirements. 

•  Taking  regulatory  decisions  and  granting  (whenever  this  task  belongs  to  the 
licences,  conditions  or 

suspending  or 

revoking 

regulator), amending, 
authorisations, as appropriate. 

In  the  framework  of  the  Milestones  Approach,  the  IAEA  estimated  the  resources 
(including of regulators) for the development of a new nuclear power programme, as 
illustrated in Figure 36.  

Figure 36 – IAEA breakdown of resource requirements 

Source:  Resource  Requirements  for  Nuclear  Power  Infrastructure  Development,  Nuclear  Energy 

Series No. NG-T-3.21, © IAEA, 2022, 10. 

Notes: 

For the purposes of the IAEA referenced publication, the IAEA resource estimation is made 
against the Nuclear Infrastructure Competency Framework for nuclear power programmes, 
based on the Milestones approach and a number of other publications addressing specific 
aspects of nuclear infrastructure. The resource estimates are based on the development of 
a nuclear power programme of two units, in a country that already has some experience of 
and capability for managing large infrastructure projects. 

(218)   Licensing Process for Nuclear Installations, Safety Standards Series No. SSG-12, © IAEA, 2010. 

96 

 
 
 
This figure is pertinent as it reveals that, while the regulator is involved, to a different 
extent, in various activities, the most resource-intensive activity that falls exclusively 
under the regulator’s remit is reviewing licence applications. In the EU, there is a 
significant  variety  of  licensing  approaches  and  systems,  and  different  types  of 
licences and authorisations are issued at various stages. Member States choose either 
to issue licences corresponding to each step of the licensing process (siting, design, 
construction, commissioning,  operation, decommissioning) or to divide these steps 
into several sub-steps or merge several steps (e.g. combined licences for construction 
and operation). Conditions may be attached to the licences granted, requiring that the 
licensee obtains  further,  more specific,  authorisations  or approvals  before carrying 
out particular activities. While the regulatory authorities are generally empowered to 
make  regulatory  decisions  and  to  grant,  amend,  suspend  or  revoke  licences, 
conditions  or  authorisations,  in  a  few  cases,  the  licences  are  granted  by  the 
Government based on a prior evaluation of the licence application (including nuclear 
safety aspects) by the competent regulatory authority. 

Regardless of the licensing model adopted in the Member State engaged in a nuclear 
investment  project,  the  national  regulators  will  have  to  analyse  substantial  and 
complex documentation, as well as to conduct reviews, assessments and inspections. 
Already as part of the pre-application process the regulators will be involved in early 
engagement with the applicant to discuss the proposed project, its design and potential 
licensing challenges. This is, evidently, a highly resource-intensive process.  

Box below provides an example showing, on the one hand, planned increases in the 
staff numbers through recruitment or mobility solutions, but also, on the other hand, 
the need to further secure supplementary personnel.  

97 

 
Box  –  EU  regulators  human  resources  in  Member  States  planning  to 
develop nuclear energy 

A  survey  carried  out  by  the  European  Commission  in  2025  amongst  the 
regulatory  authorities  reunited  in  the  European  Nuclear  Safety  Regulators 
Group (ENSREG) revealed that several regulators, notably from Member States 
planning or implementing new reactor projects, envisage increasing resources 
(including those dedicated to nuclear safety). Examples include the regulators 
from Czechia, Hungary, the Netherlands, Poland, Slovenia, and Finland. 

Evolution  of  new  build  projects  and  need  of  retaining  existing  regulatory 
competence  are  important  factors  coming  into  play  when  planning  human 
resources uptake. Projections indicate both annual increases and increases with 
a multiannual perspective. As compared to the 2024 baseline figures, planned 
additional positions ranges from 10% to 50% percent staff increase up to 
doubling the number of staff, depending on the national circumstances. 

In  addition  to  own  staff,  regulatory  authorities  of  some  Member  States  are 
supported  by  external  expertise,  some  having  a  permanent  status  (scientific 
councils,  committees, 
institutes,  or  Technical  Support  Organisations 
specifically  established  with  the  aim  of  advising  the  regulators).  Examples 
include Belgium, Bulgaria, Czechia, Germany, France, Slovenia, and Finland. 

Considering the specificities of each licensing system, the precise quantification of 
the resources involved in the licensing is made by each domestic authority. Whenever 
additional resources are needed, besides relying on the available national mechanisms 
mentioned in Table 14, the cooperation between the regulatory authorities of various 
countries, notably those licensing a similar reactor technology, is an opportunity for 
sharing regulatory knowledge and experience.  

6.1.4. 

Regulatory  cooperation  as  a  solution  to  optimise  the  use  of 
resources 

The  Nuclear  Safety  Directive  requires  that  the  Member  States’  safety  frameworks 
provide for a system of licensing and prohibits the operation of nuclear installations 
without a licence. The Waste Directive requires that the national framework provides 
a  system  of  licensing  of  spent  fuel  and  radioactive  waste  management  activities, 
facilities  or  both,  including  the  prohibition  of  spent  fuel  or  radioactive  waste 
management  activities,  of  the  operation  of  a  spent  fuel  or  radioactive  waste 
management  facility  without  a  licence  or  both  and,  if  appropriate,  prescribing 
conditions for further management of the activity, facility or both. 

The Directives are not prescriptive as regards the licensing process, its steps, or the 
national authorities responsible for issuing licenses. Ultimately, the decision on how 
to  structure  the  licensing  system  remains  a  national  responsibility.  In  the  EU,  the 
licensing approaches are diverse, with the regulators being typically responsible for 
granting licences, as well as amending, suspending or revoking licences. According 
to  the  OECD  NEA,  current  reactor  licensing  frameworks  typically  rely  ‘on  an 
extensive experience base with large single-unit LWRs that use uranium oxide fuel 

98 

 
 
with  enrichment below 5%.’ (219) Therefore, acquiring or transferring  the requisite 
expertise to assess alternative reactor technologies is not straightforward. It is even 
more  complicated  in  relation  to  wide  range  of  spent  fuel  and  radioactive  waste 
management facilities. 

The  2022  NSD  Progress  Report  acknowledges  this  variety  and  encourages 
strengthened  collaboration  amongst  regulatory  authorities  on  licensing  practices, 
regarded  as  bringing  benefits  ‘by  identifying  potential  commonalities  to  promote 
consistency and best use of resources.’ (220) As a nuclear installation built in a country 
is likely to be similar to installations being proposed or built in many countries around 
the world, taking account of international good practice, international standards, and 
the  assessments  undertaken  by  other  regulators  is  beneficial.  Besides  offering  a 
platform  for  effectively  exchanging  experience,  regulatory  cooperation  can  also 
contribute to the resource optimisation. 

Such cooperation (221) can be achieved by working with the nuclear regulators of other 
countries (bilateral collaboration) or under the auspices of international organisations 
(multilateral  collaboration).  An  example  of  bilateral  cooperation  is  the  exchange 
between Sweden, Denmark, Finland and Norway, that include licensing aspects. (222) 
Bilateral  agreements  are  also  commonly  in  place  between  neighbouring  countries. 
Examples of multilateral cooperation fora include the IAEA Nuclear Harmonisation 
and  Standardisation  Initiative  (NHSI),  (223) the  OECD  NEA  Multinational  Design 
Evaluation  Programme  (MDEP),  (224)  and  the  World  Nuclear  Association 
Cooperation in Reactor Design Evaluation and Licensing (CORDEL). (225) 

Safety and licensing aspects for SMRs and AMRs are covered in section 5.1.4. 

In  conclusion,  the  regulatory  cooperation  at  a  European  level  may  support  the 
regulatory infrastructure development, optimise resources, improve coordination and 
complementarity, as well  as identify any barriers and limitations at  an early stage, 
seeking convergence solutions. 

On  a  general  level,  when  selecting  locations,  Member  States  should  perform  a 
screening  for  climate  risks  next  to  the  general  risk  assessment  for  the  planned 
infrastructure and take into  account  which areas are more  conducive to  reduce the 
identified risks to acceptable levels. 

At all levels – the EU, national, regional and local – authorities must make a major 
effort to accelerate the permitting procedures for clean energy projects, as outlined in 

(219)   NEA (2021), Small Modular Reactors: Challenges and Opportunities, OECD Publishing, Paris. 

(220)   COM/2022/173 final., section II, sub-section 2.1. 

(221)   For an overview of the cooperation activities in nuclear, see the WNA website Cooperation in Nuclear 

Power - World Nuclear Association 

(222)   As  indicated  in  the  National  Report  of  Sweden  of  2020  under  the  Nuclear  Safety  Directive 
‘Notifications according to the agreement have been made, among other things, in connection with 
applications  for  increasing  the  thermal  power  in  nuclear  reactors,  planned  decommissioning  and 
ongoing licensing preparation of new final repositories.’  

(223)   Nuclear Harmonization and Standardization Initiative (NHSI), © IAEA, 2025.  

(224)   NEA Multinational Design Evaluation Programme (MDEP) 

(225)   Working Groups - World Nuclear Association 

99 

 
 
the Draghi report. A large part of the time taken by the permitting processes for clean 
energy investments is dedicated to environmental assessments. Targeted updates to 
the  legislative  framework  on  environmental  assessments  could  support  faster 
permitting  procedures  for  such  projects,  while  maintaining  same  level  of 
environmental safeguards and protecting human health. Against this background, the 
Commission  will  assess the  possibility  streamlining  of  licencing  practices  for  new 
innovative nuclear energy technologies such as SMRs. 

6.2.  Transparency 

6.2.1. 

The importance of public information and public participation in 
the decision making on nuclear installations is globally recognised  

Nuclear programmes and activities typically involve a wide variety of stakeholders to 
engage  with,  building  trust,  demonstrating  accountability,  exhibiting  open  and 
transparent  communication,  practising  early  and  frequent  consultation  and 
communicating benefits and risks. (226) 

While the term ‘stakeholder’ can be interpreted in different ways, a broad definition 
encompasses  ‘any  group  or  individual  who  feels  affected  by  an  activity,  whether 
physically or emotionally.’ (227) Distinctions can also be drawn between organisations 
and groups that are statutory stakeholders (those required by law to be involved in 
any  planning,  development  or  operation  of  a  nuclear  project)  and  non‑statutory 
stakeholders (those who have an interest in or will be directly or indirectly impacted). 
(228)  This  section  will  focus  on  the  latter  category,  by  looking  at  ways  to  ensure 
effective public communication and consultation on nuclear safety matters.  

Public  information  about  nuclear  activities  in  general,  and  on  the  development  of 
nuclear programmes/projects in particular, and active public engagement contribute 
to enhancing awareness, understanding, and confidence, thereby supporting nuclear 
safety. In this respect, it was noted that, ‘intensive public scrutiny may in a certain 
way contribute to nuclear safety by challenging the experts to do their analyses as 
transparently, comprehensively and soundly as possible, and to present a generally 
understandable  and  compelling  justification.’  (229)  While  the  responsibility  for 
decision  making  lies  with  national  authorities,  public  involvement  enhances  the 
component of confidence and trust, essential for the successful completion of nuclear 
investment  projects.  However,  for  the  engagement  with  the  public  to  be  effective, 
some  challenges  that  should  be  considered  include  ensuring  the  participation  of 
informed members of the public who can question the experts, (230) as well as for the 
public  to  respond  positively  and  actively  participate  every  time  consultation 
opportunities are presented. 

(226)   Stakeholder Engagement in Nuclear Programmes, Nuclear Energy Series No. NG-G-5.1, © IAEA, 

2021. 

(227)  

ibid. 

(228)   Handbook on Nuclear Law, © IAEA, 2003. 

(229)   Raetzke,  C.  (2014),  Nuclear  law  and  environmental  law  in  the  licensing  of  nuclear  installations, 

Nuclear Law Bulletin, vol. 2013/2. 

(230)   An example is the establishment of the local information committees (in France, CLI) that include in 

their composition also persons appointed for their expertise in the nuclear field.  

100 

 
 
From a regulatory perspective, involving the public in a new nuclear project has the 
potential to reinforce public awareness on the role and responsibility of the regulatory 
authority,  strengthen  the  legitimacy  of  the  regulatory  decisions  by  considering  a 
broader pool of views, and ensure the external scrutiny that enhances the ability of 
the  regulator  to  make  independent  regulatory  judgement  and  decisions.  Indeed, 
openness  (operating in  a way which does not  conceal  thoughts or information and 
supports ongoing communication) and transparency (proactively disclosing relevant, 
accessible and accurate information about the regulatory process and decisions) are 
regarded as essential characteristics of a trusted nuclear regulator. (231) 

Transparency  requirements  relevant  for  the  nuclear  domain  are  laid  down  in 
instruments  with  varying  legal  force,  pertaining  to  nuclear  law  and  environmental 
law, at international and Euratom levels (see Table 15). 

Table 15 – Requirements on transparency 

Level 

Legally binding and non-legally binding instruments 

International 
level 

Treaties – 
environment 

Treaties – 
nuclear 

−  Convention on Access to Information, Public 

Participation in Decision-Making and Access to 
Justice in Environmental Matters (Aarhus 
Convention) (i) 

−  Convention on Environmental Impact Assessment 
in a Transboundary Context (Espoo Convention), 
(ii) as amended; Protocol on Strategic 
Environmental Assessment to the Convention on 
Environmental Impact Assessment in a 
Transboundary Context (iii) 

−  Convention on Nuclear Safety (iv) 
−  Joint Convention on the Safety of Spent Fuel 

Management and on the Safety of Radioactive 
Waste Management (Joint Convention) (v) 

IAEA safety 
standards (vi) 

Examples: 
−  Fundamental Safety Principles, IAEA Safety 

Standards Series No. SF-1, 2006 

−  Licensing Process for Nuclear Installations, IAEA 
Safety Standards Series No. SSG-12, 2010 
−  Communication and Consultation with Interested 
Parties by the Regulatory Body, IAEA Safety 
Standards Series No. GSG-6, 2017 

−  Arrangements for Public Communication in 

Preparedness and Response for a Nuclear or 
Radiological Emergency, IAEA Safety Standards 
Series No. GSG-14, 2020 

−  Stakeholder Involvement Throughout the Life 

Cycle of Nuclear Facilities, IAEA Nuclear Energy 
Series No. NG-T-1.4, 2011 

−  Stakeholder Engagement in Nuclear Programmes, 

IAEA Nuclear Energy Series No. NG-G-5.1, 2021 

−  Public Access to Environmental Information 

Directive (vii) 

−  Environmental Impact Assessment (EIA) Directive 

(viii) 

−  Regulation (EC) N° 1367/2006, as amended (ix) 
−  Nuclear Safety Directive, as amended (x) 

EU level 

Legislation – 
environment  

Euratom 
level 

Legislation – 
nuclear 

(231)   NEA (2024), Characteristics of a Trusted Nuclear Regulator, OECD Publishing, Paris. 

101 

 
 
−  Spent Fuel and Radioactive Waste Directive (xi) 
−  Basic Safety Standards Directive (xii) 

Source: 

(i) 
(ii) 
(iii) 
(iv) 
(v) 
(vi) 
(vii) 
(viii) 
(ix) 
(x) 
(xi) 
(xii) 

UNTS 447, 38 ILM 517 (1999). 
1989 UNTS 309, 30 ILM 800 (1991). 
2685 UNTS 140.   
INFCIRC/449 of 5 July 1994. 
INFCIRC/546 of 24 December 1997. 
See IAEA website, www.iaea.org/resources/safety-standards.   
Directive 2003/4/EC of the European Parliament and of the Council. 
Directive 2011/92/EU of the European Parliament and of the Council. 
Regulation  (EC)  No  1367/2006  of  the  European  Parliament  and  of  the  Council. 
Council Directive 2009/71/Euratom.  
Council Directive 2011/70/Euratom.  
Council Directive 2013/59/Euratom. 

At national level, while the domestic legal and regulatory framework sets out the key 
requirements on both informing and allowing the public to be heard, it is important to 
complement this framework with dedicated communication strategies and plans, as 
well as practical communication mechanisms and channels (both national and cross-
border).  Focusing  on  public  participation  as  an  enabler  for  investment  projects, 
several  key  parameters  should  be  clearly  spelled  out,  notably  the  place  where  the 
documentation can be consulted, the consultation modalities (e.g. submitting written 
comments or appearing at public hearings), the time schedule, and the way the input 
is taken into account. 

More detailed guidance on the communication and consultation with the public and 
other interested parties by the regulatory body can be found in several IAEA safety 
standards series publications. In particular, the IAEA Safety Standard Series GSG-6, 
Communication  and  Consultation  with  Interested  Parties  by  the  Regulatory  Body, 
(232) focuses on the role of the regulatory body in communicating and consulting the 
public for all facilities and activities, and for all stages during their lifetime. These 
activities  are  seen  as  ‘strategic  instruments  that  support  the  regulatory  body  in 
performing  its  regulatory  functions;’  enabling  the  regulators  to  ‘make  informed 
decisions  and  to  develop  awareness  of  safety  among  interested  parties,  thereby 
promoting safety culture.’ (233)  

While, as indicated in section 6.1, licensing arrangements vary, they typically include 
specific milestones that present opportunities for the public to be consulted and have 
a say. While the siting phase is identified as potentially being ‘extremely contentious,’ 
even when it had been completed, it is advisable that, building on the lessons learned, 
to continue to engage with in the public during the other licensing phases. The end of 
the  installation’s  lifecycle  should  not  be  overlooked,  with  ‘local  oversight  of 
decommissioning and cleanup activities’ being a feature of stakeholder involvement. 

In practical terms, the public participation can be organised in several ways, such as. 
(234)  

•  Consultations initiated by national regulators. 

(232)   Communication and Consultation with Interested Parties by the Regulatory Body, Safety Standards 

Series No. GSG-6, © IAEA, 2017. 

(233)   Handbook on Nuclear Law, © IAEA, 2003. 

(234)   See ENSREG website: Public participation | ENSREG  

102 

 
 
 
 
 
 
 
 
•  Hearings and debates coordinated by public entities other than regulators (such as 
local planning authorities, environmental authorities or government departments), 
which include. 

o  National debates – organised in the context of a draft law, major new policy or 
a nation-wide project such as the construction of a new nuclear power plant. 

o  Local hearings – organised locally in the context of a specific project, such as 
the extension of the operating life of a nuclear installation, or a change in its 
operating licence. 

•  Standing  bodies,  that  are  often  set  up  in  the  vicinity  of  a  nuclear  power  plant. 
Examples  exist  at  national  level,  particularly  the  Local  Information  Committee 
(CLI)  in  France.  There  is  also  a  tendency  towards  establishing  groupings  of 
affected communities, such as the Group of European Municipalities with Nuclear 
Facilities  (GMF)  (235),  seeking  to  represent  the  views  of  its  member  local 
authorities at European level. 

As  an  illustration  of  the  public’s  views,  the  World  Nuclear  Association  report 
“Licensing and Project Development of New Nuclear Plants” (236) reveals that almost 
all  respondents  stress  that  early  and  adequate  public  involvement  is  essential, 
indicating that fairness in the process of public consultation is certainly a vital factor 
for  acceptance  of  nuclear  projects.  It  was  recommended  that  public  participation 
should be coordinated with the steps of the licensing process, concentrating on the 
early phases when the basic decisions are taken, and that discussions, once they are 
resolved, should not be re-opened later.  

In experience of the several companies, the continuous, transparent interaction with 
stakeholders is essential for building and maintaining acceptance and trust throughout 
the projects. For example, stakeholder engagement and public acceptance are linked 
to  all  of  Posiva’s  activities.  Posiva  Oy  is  an  expert  organisation  in  environmental 
technology, which is tasked with handling the final disposal of the spent nuclear fuel. 
The aim of Posiva is also to increase knowledge about nuclear and its back end, as 
well as to support open and constructive interaction in the company's neighbourhood, 
Finnish society and industry world.  In their lessons learned, Posiva concluded that 
trust is built slowly and maintaining it must be taken care of from the very beginning 
throughout the long lifetime of any project, including the final disposal project.  

(235)   GMF EUROPE – Group of European Municipalities with Nuclear Facilities 

(236)   WNA_REPORT_Nuclear_Licensing.pdf 

103 

 
 
Box  –  Public  consultation  on  the  continued  operation  of  the  900  MWe 
reactors in France 

As reported in the National Report of France for the 8th and 9th Review Meeting 
under the Convention on Nuclear Safety (August 2022), the High Committee 
for  Transparency  and  Information  on  Nuclear  Safety  (HCTISN),  acting  on  a 
proposal  of  the  French  nuclear  safety  authority,  and  with  the  support  of  a 
number  of  players,  including  the  National  Association  of  Local  Information 
the  Local  Information 
Committees  and  Commissions  (ANCCLI)  and 
Committee (CLI), held a public consultation (for which no provision was made 
in  the regulations) from  6 September 2018 to  31 March 2019 on the generic 
phase of the 4th periodic safety review of the 900 MWe reactors in the French 
NPP fleet (32 reactors operated by EDF on eight sites), coinciding with their 
40th year of operation.  

The public consultation, consisting in both on-line and at local public inquiry 
meetings,  was  related  to  the  conditions  for  continued  operation  of  these  900 
MWe reactors. The public was asked to help determine the priority themes for 
the safety improvement debates, on the basis of 15 topics. The public was able 
to hold discussions with experts from the Électricité de France (EDF), the ASN 
and  the  French  Institute  for  Radiation  Protection  and  Nuclear  Safety  (IRSN) 
during the public meetings, to ask questions and obtain information from the 
on-line platform created for this public inquiry.  

The  public  was  informed  and  its  questions  and  opinions  collected  at  both 
regional  and  national  levels,  via  a  digital  platform.  A  total  of  16  meetings 
attracting 1,300 participants was held around each of the eight sites concerned, 
as well as within a number of higher education facilities. 

The stakeholder involvement is continuous process and there is also value to be open, 
proactive and understandable in communications. 

From these general considerations, the ensuing text will look at the EU situation. 

6.2.2. 

Variety  of  EU  arrangements  aiming  to  ensure  that  the  public  is 
properly informed and involved 

the  Euratom  nuclear  safety-related 

Focusing  on 
legislation  addressing 
transparency, the Nuclear Safety Directive addresses it both from the perspectives 
of providing information and offering participation opportunities. First, in respect to 
public information, the Directive lays down the general obligation to make available 
“necessary information in relation to the nuclear safety of nuclear installations and its 
regulation”  to  “the  general  public,  with  specific  consideration  to  local  authorities, 
population  and  stakeholders  in  the  vicinity  of  a  nuclear  installation.”  (237)  The 
Directive  further  specifies  this  obligation  by  referring  to  information  on  normal 
operating conditions of nuclear installations, and in case of incidents and accidents, 
incumbent on both the regulatory authority and on the licence holder in the framework 
of  their  communication  policy.  Second,  concerning  public  participation,  the 

(237)   Article 8, paragraph 1, Nuclear Safety Directive. 

104 

 
 
 
Directive  calls  for  the  general  public  to  be  given  appropriate  opportunities  to 
participate  effectively  in  the  decision-making  process  related  to  the  licensing  of 
nuclear  installations.  (238)  The  link  to  the  environmental  legislation  is  made  in  the 
Directive’s  Preamble  that  refers  to  the  use  of  nuclear  safety  assessments  for  the 
assessment of the risk of a major accident, as covered by the EIA Directive.  

The Radioactive Waste Directive contains similar requirements. In respect to public 
information, it requires Member States to ensure that necessary information on the 
management of spent fuel and radioactive waste be made available to workers and the 
general public”, including the competent regulatory authority to inform the public in 
the  fields  of  its  competence.  Concerning  public  participation,  it  obliges  Member 
States to ensure that “the public be given the necessary opportunities to participate 
effectively in the decision-making process regarding spent fuel and radioactive waste 
management in accordance with national legislation and international obligations”. 
The Directive also requires the Member State to set out how they intent to implement 
these obligations in their national programmes under the Directive and to report on 
their implementation of these programmes every three years. 

In  light  of  the  above,  the  Euratom  directives  enshrine  fundamental,  high-level 
requirements on public information and public participation. The Member States have 
the flexibility of choosing the appropriate transposing instruments and, importantly 
when  it  comes  to  transparency,  putting  in  place  the  adequate  toolbox,  taking  due 
account  of  the  national  specificities.  In  this  vein,  based  on  the  Euratom  legal 
requirements, the European Nuclear Safety Regulators Group (ENSREG) identified 
several  good  practices  for  the  regulatory  authorities  (see  Box  below),  indicating, 
however,  that  these  are  “generic  in  nature  and  may  need  to  be  adapted  to  the 
organisational structures in individual Member States.” (239) 

Good practices for regulatory authorities identified by ENSREG. 

1)  Promote  a  culture  of  openness  and  transparency  within  the  Regulators  so 
that all staff understand the importance of being transparent and of engagement 
with interested parties. Openness and transparency shall be included in the core 
of the organisational values and behaviours. 

2)  Develop  a  policy/strategy  on  communication  which  clearly  sets  out  the 
organisation’s  commitment  to  open  communication  and  the  way  in  which 
transparency is implemented. Underpin this with, if applicable, regularly updated 
plans detailing the activities that the Regulators will undertake to ensure effective 
communication with interested parties.  

3)  Develop an appropriate toolkit for effective communication with the public 
and  other  interested  parties.  For  example,  an  accessible  website  where  the 
general public and specific interested parties can find in-depth and understandable 
information on aspects of the Regulator’s work and, in particular, on regulatory 
decisions and opinions. The website should, for example, include access to on-
line radioactivity monitoring data, to  the  relevant  guidelines and legislation, to 
information on specific events and incidents, to research and other reports and to 

(238)   Article 8, paragraph 1, Nuclear Safety Directive. 

(239)   European Nuclear Safety Regulators Group, “Guidance on Openness and Transparency for European 

Nuclear Safety Regulators”, HLG-p(2019-39)_165. 

105 

 
 
press  releases.  It  should  also  support  interactive  consultation  with  interested 
parties and collection of feedback from website visitors. It is recommended to use 
online communication, including social media, as appropriate.  

4)  Produce  an  annual  report  on  the  Regulator’s  activities  with  the  aim  to 
demonstrate key achievements of the previous year. The annual report should be 
accessible to the public.  

5)  Communicate effectively and proactively with interested parties in a timely 
manner using appropriate means that enhance their participation, in accordance 
with  the  requirements  included  in  national,  European  and  international  law. 
Establishing relations in a more informal manner could help to build trust. The 
Regulators may consider the organisation of public meetings on a regular basis, 
as a way of promoting dialogue and interaction with interested parties.  

6)  Communicate  effectively  with  the  media  and  become  the  main  point  of 
reference for traditional and new media for information related to nuclear safety, 
radioactive  waste  management  or  safety-significant  nuclear  and  radiological 
events to the public. Efforts for coordinated information should be applied. Doing 
this will help to establish the Regulators as a credible source of information and 
will ensure that there is coordinated regular interaction.  

7)  Produce  information  in  plain  language.  The  information  may  need  to  be 
adapted for different target audiences. For example, some audiences will require 
more technical and complex information. Provide translated information where 
deemed necessary.  

8)  When developing documents, consider in advance which information might 
be  sensitive,  and  organise  the  content  so  as  to  ensure  that  the  public  version 
contains  as  much  useful  information  as  possible.  For  pre-existing  documents 
being made public, delete only those parts of the document where commercial, 
national  defence,  public  safety,  security,  proprietary,  privacy  issues  or  other 
restrictions within the framework of national legislation apply. This promotes a 
high  degree  of 
transparency  against 
sensitivity/security  it  is  important  to  justify  why  some  information  cannot  be 
disclosed.  

transparency.  When  balancing 

9)  Evaluate  the  effectiveness  of  the  Regulator´s  communication  in  terms  of 

openness and transparency. Share the results, as appropriate.  

At  the  EU  level,  from  a  nuclear  safety  perspective,  the  Commission’s  2022  NSD 
Progress Report addressed in detail, inter alia, the issue of transparency, (240) based, 
primarily, on information drawn from the Member States’ national reports. (241) While 
more  details  are  available  in  the  2022  NSD  Progress  Report,  Table  16  provides  a 
summary  of  the  typical  domestic  approaches  on  transparency,  identified  in  this 
progress report. 

(240)   COM/2022/173 final (section 2.4), and SWD/2022/107 final (section 2.4). 

(241)   Nuclear safety 

106 

 
 
Table 16 – Common trends on transparency in Member States 

Topic 

Summary 

National framework 
Type of 
requirements 

−  General legislation – right of free access to information 
−  Specific legal provisions – nuclear-related transparency 
(dissemination of information, public participation) 

Provision of information 
Information 
dissemination 
mechanisms 

−  National arrangements  

o  Regulatory authorities:  
▪  annual reports 
▪ 
▪ 

results of regular inspection reports 
information on the website available in more than one 
language 
social media 
contacts with the press 
special websites following major events 

▪ 
▪ 
▪ 
▪  opportunities to provide feedback and ask questions  
▪  bodies for information, consultation and debate on the 

risk associated with nuclear activities etc. 

o  Licence holders:  
visitor centres 

▪ 
▪  printed information magazines and brochures 
▪ 

consultative bodies to reinforce the relations with local 
residents 

▪  meetings at schools and universities 
▪ 
▪ 

site visits 
thematic events and open days etc. 

− 

International, regional and bilateral cooperation 
agreements 

Public participation 
Consultation 
framework 

−  Consultations in the frame of the EU environmental legislation 

on Environmental Impact Assessments or international 
“             ”                       E         A      
conventions 

Public 
consultation 
mechanisms 

−  Specific nuclear-related consultations (in some cases)  
−  Various mechanisms:  

o  announcements in the press inviting replies within clear 

deadlines 

o  non-technical summaries 
o  public hearings 
o 

independent expert panels 

−  dedicated organisations to provide information to the public and 
                         ’                  k               . 

Source:  European Commission. 

Overall, in its observations to the Member States, the Commission supported a self-
standing public consultation process on the licensing of nuclear installations from the 
perspective  of  nuclear  safety. (242) In  support  of  this  observation,  the  Report  noted 
that  the  Member  States  generally  link  their  consultation  processes  with  the 

(242)   Report from the Commission to the Council and the European Parliament on the progress made with 
the  implementation  of  Directive  2009/71/Euratom  establishing  a  Community  framework  for  the 
safety of nuclear installations amended by Directive 2014/87/Euratom, COM/2022/173 final, section 
II / 2.4. 

107 

 
 
information and consultation obligations laid down in the international and the EU 
environmental legislation mentioned in Table 15, and that only a few Member States 
conduct specific nuclear safety-related public consultations, including in relation to 
major  operational  changes  or  LTO  decisions.  Furthermore,  the  Commission  also 
highlighted the topic of strengthening transparency as a key topic where developing 
a common approach at EU level would be beneficial. (243) Any reflection process 
on this issue can only be made in close partnership with the involved stakeholders, 
including the civil society.  

6.2.3. 

Nuclear  safety  is  of  high  interest  for  the  citizens  calling  for  a 
continuous dialogue and exchange 

Since  the  previous  Nuclear  Illustrative  Programme,  the  2019  Eurobarometer  on 
‘Europeans  attitudes  on  EU  Energy  Policy’ (244)  revealed  that,  in  response  to  the 
question ‘What does EU energy policy mean to you?’, for 18% of the respondents, 
EU policy means ensuring that nuclear energy is  safe and secure, with  the highest 
percentages  being  registered  in  Slovakia  (36%)  and  Lithuania  (36%).  In  addition, 
85% of respondents say it is necessary to ensure that nuclear energy is safe and secure 
in the EU.  

A more recent international survey of the OECD NEA in the framework of the Global 
Forum on Nuclear  Education, Science, Technology  and Policy,  (245) whose results 
were released in 2024, confirmed this general interest. This survey sought to explore 
the links between an individual’s core values and their perception of science, risk and 
nuclear  matters.  In  relation  to  the  topic  of  nuclear  energy  (questions  whether  new 
nuclear power plants should be built, whether building nuclear power plants in their 
country  was  a  good  thing,  and  whether  the  existing  nuclear  power  plants  in  their 
country should be shut down), the replies show an opinion which is overall favourable 
to nuclear energy. A total of 74% declare that building nuclear power plants was a 
good thing, 71% are in favour of building new nuclear power plants and only 10% 
believe that ‘existing nuclear power plants must be closed.’ 

In  addition,  it  should  be  acknowledged  that  a  major  preoccupation  for  the  public 
relates to the risk of accidents and the emergency preparedness and response (EP&R) 
arrangements. This is a key finding stemming from the ‘Study on good practices in 
implementing the requirements on public information in the event of an emergency, 
under the Euratom Basic Safety Standards Directive and Nuclear Safety Directive’ 
(246) commissioned by the Commission. This study covers the topics of information 
and  transparency  requirements;  the  role  of  media  in  nuclear  and  radiological 
emergencies; communication in exercises; stakeholder engagement before and during 

(243)   Report from the Commission to the Council and the European Parliament on the progress made with 
the  implementation  of  Directive  2009/71/Euratom  establishing  a  Community  framework  for  the 
safety of nuclear installations amended by Directive 2014/87/Euratom, COM/2022/173 final, section 
IV.  

(244)   Europeans attitudes on EU Energy Policy - September 2019 - - Eurobarometer survey 

(245)   NEA (2024), The Perception of Science, Risk and Nuclear Energy: An International Survey, NEA 
Working Papers, OECD Publishing, Paris, https://www.oecd-nea.org/jcms/pl_90306/the-perception-
of-science-risk-and-nuclear-energy-an-international-survey?details=tru 

(246)   Study on good practices in implementing the requirements on public information in the event of an 
emergency,  under  the  Euratom  Basic  Safety  Standards  Directive  and  Nuclear  Safety  Directive  - 
Publications Office of the EU 

108 

 
 
an emergency and cross-border arrangements. It also highlights good practices in each 
of these areas, which could be considered by the Member States. Examples of good 
practices include paying attention to recognising challenges concerning transparency 
during a nuclear or radiological emergency in advance and developing approaches to 
deal with these challenges during an emergency; monitoring and reviewing regulatory 
processes  related to  emergency preparedness  and response to  ensure openness  and 
transparency; including informed civil society and citizen scientists (i.e. volunteers in 
the  scientific  process)  in  emergency  management,  including  in  conducting 
independent measurements.  

Taking into account these views from the public (exemplified in the above examples), 
the Commission considers that the dialogue with an active and engaged civil society 
promotes  a  better  understanding  of  the  concerns  and  can  positively  contribute  to 
strengthening  nuclear  safety.  In  the  nuclear  field,  the  Commission  has  been 
systematically engaging in a dialogue with the civil society, with several roundtables 
having been organised in cooperation with the civil society, (247) addressing important 
safety  topics  like  emergency  preparedness  and  response,  and  transparency.  These 
events  reunited a broad  spectrum of stakeholders (civil  society, nuclear regulators, 
nuclear industry, Aarhus Compliance Committee), and provided a forum to discuss 
national  and  transboundary  experiences,  identify  challenges,  and  best  practices  to 
address  them.  The  European  Cluster  Collaboration  Platforms  could  serve  as  an 
instrument for raising awareness at regional level and to promote cooperation between 
nuclear-relevant clusters across the EU (248). 

Transparency and stakeholder engagement/involvement are critical to achieving 
public acceptance and thereby enhancing the efficiency and cost-effectiveness of 
the  licensing  process  for  new  nuclear  facilities.  This  may  reduce  the  time 
required for licencing and the cost of the licensing process overall: 

Foremost, transparent communication and stakeholder involvement are fundamental 
in building trust among stakeholders, which is essential for streamlining the siting and 
licensing processes of nuclear facilities and facilitating public acceptance throughout 
the  lifecycle  of  such  nuclear  facilities.  When  stakeholders,  including  the  general 

(247)   Aarhus  Convention  and  Nuclear  Roundtable  "Emergency  Preparedness  and  Response  to  nuclear 
accidental  and  post-accidental  situations"  (29-30  November  2016)  organised  by  the  European 
Commission  (DG  ENER),  and  the  French  Federation  of  Local  Commission  of  Information 
(ANCCLI); Aarhus Convention and Nuclear Roundtable "On information and public participation in 
the field of Radioactive Waste Management (RWM)” (13-15 January 2021) organised by the Nuclear 
Transparency  Watch  (NTW)  network  and  the  European  Commission  (DG  ENER);  Aarhus 
Convention and Nuclear Roundtable "Cross-border Emergency Preparedness and Response to nuclear 
accidental and post-accidental situations (EP&R)” (12-19-26 January 2022) organised by the Nuclear 
Transparency  Watch  (NTW)  network  and  the  European  Commission  (DG  ENER);  Aarhus 
Convention and Nuclear Round Table "Implementation of the Nuclear Safety Directive: transparency, 
public participation, and the role of civil society in independent nuclear regulation” (21-22 January 
2025) organised by the Nuclear Transparency Watch network and the European Commission (DG 
ENER). 

(248)   Homepage | European Cluster Collaboration Platform 

109 

 
 
public,  are  continuously  informed  and  included  in  the  decision-making  process,  it 
fosters trust (249) and reduces opposition (250). 

Moreover,  engaging  stakeholders  early  and  continuously  throughout  the  licensing 
process leads to better understanding and cooperation (251). This involvement allows 
stakeholders  to  express  their  concerns  and  influence  decisions,  which  can  pre-
emptively address potential issues, thereby facilitating smoother and faster approval 
processes.  

Furthermore, by gaining public acceptance through transparency and engagement, the 
likelihood of delays caused by public opposition decreases (252). This can result in a 
more efficient licensing process, ultimately saving time and reducing associated costs.  

Finaly, by involving the public and stakeholders, regulatory bodies can make more 
practical, relevant, and coordinated decisions (253). This level of scrutiny ensures that 
decisions are better informed and more widely accepted, contributing to a faster and 
more economical licensing process.  

6.3. 

Skills and human resources  

6.3.1. 

Skills shortage affects nuclear investments 

Now that investments in new nuclear capacity appear to be increasing, either based 
on existing technologies or new technologies like SMRs or AMRs, renewed emphasis 
needs to be placed on securing the necessary skills and workforce to accompany those 
investments.  

Similar conclusions have been drawn by the IAEA, NEA, the US, Canada, the UK 
and  several  EU  Member  States,  and  numerous  initiatives  have  been  launched  to 
respond to these challenges (254). 

(249)   T. Perko, H. Monken-Fernandes, M. Martell, N. Zeleznik, P. O’Sullivan. Societal constraints related 
to  environmental  remediation  and  decommissioning  programmes.  Journal  of  Environmental 
Radioactivity 196 (2019) 171-180. 

(250)   T.  Perko,  M.  Martell  and  C.  Turcanu.  Transparency  and  stakeholder  engagement  in  nuclear  or 

radiological emergency management. Radioprotection, Volume 55, May 2020.  

(251)   Communication and Stakeholder Involvement in Radioactive Waste Disposal. IAEA Nuclear Energy 

Series No. NW-T-1.16.  

(252)   Communication and Stakeholder Involvement in Radioactive Waste Disposal. IAEA Nuclear Energy 

Series No. NW-T-1.16. P. 12, 14 and 59.  

(253)   NEA (2022), Stakeholder Confidence in Radioactive Waste Management. An annotated Glossary of 

Key Terms – 2022 Update. Nuclear Energy Agency No. 7606.  

(254)   Managing human resources in the field of nuclear energy, Nuclear Energy Series No. NG-G-2.1 (Rev. 

1), © IAEA, 2023.   
IAEA: https://www.iaea.org/topics/human-resource-development 
NEA: https://www.oecd-nea.org/jcms/pl_21786/nuclear-education-skills-and-technology-nest-
framework 
UK: https://nuclearskillsdeliverygroup.com/ 
Canada: https://cna.ca/2024/11/19/building-a-skilled-nuclear-workforce-for-canadas-energy-future/ 
US: https://www.energy.gov/ne/articles/5-workforce-trends-nuclear-energy 
Finland: Survey  of  Competence 
in 
http://urn.fi/URN:ISBN:978-952-327-410-5 
France: GIFEN, Programme Match, April 2023 

the  Nuclear  Energy  Sector  2017–2018 

in  Finland, 

110 

 
 
 
 
 
 
There  is  increasing  demand  for  workers  at  all  levels  and  in  all  sub-sectors  of  the 
nuclear  ecosystem  –  construction  workers,  technicians,  nuclear  engineers  and 
scientists,  skilled  power  plant  operators,  nuclear-aware  generalists  and  regulatory 
staff to assess and license new projects (255). 

Many regulatory bodies in the EU have concentrated on long-term operation, but the 
assessment of advanced reactors will demand different expertise, which needs to be 
built up. 

Another challenge is the lack of quantified data on the current nuclear workforce and 
future  needs  for  the  whole  EU.  Some  Member  States  have  carried  out  their  own 
assessments,  but  not  all  have  disclosed  this  information.  In  France,  which  has  the 
largest nuclear sector in Europe with around 220,000 workers, the trade association 
of  the  French  nuclear  industry  GIFEN  has  estimated  the  recruitment  needs  in  the 
period 2023–2033 to be in the order of 60,000 full time jobs in the 20 key activities 
studied  and  around  100,000  jobs  for  the  whole  nuclear  sector,  with  up  to  10,000 
recruits needed per year (256). 

There is a need for comprehensive workforce assessments at the national level also in 
other Member States to provide data for a sound formulation of a clear skills strategy. 

According to different estimates (257), the EU nuclear sector provided around 500,000 
direct and indirect jobs in 2022–2023. It is estimated that each gigawatt of nuclear 
power generates 50,000 labour years of direct employment during its lifetime. (258) 

In addition, it is estimated that the ecosystem generates 2.2 indirect jobs per 1 job in 
the  nuclear  sector  (e.g.  subcontractors,  secondary  technology  suppliers,  steel 
manufacturers). (259)  Consequently,  this  economic  activity  creates  several  hundred 
thousand additional induced jobs, and according to some estimates the sector sustains 
more than 1.1 million jobs in total (260). 

According to a recent study sponsored by the Commission (261), the EU nuclear sector 
may need an additional 180,000 – 250,000 new professionals until 2050, in addition 
to replacing retiring employees. Approximately 100,000 – 150,000 professionals may 
be required to cover the construction phase of the planned new nuclear power plants. 
Another 40,000 to almost 65,000 professionals are necessary to operate and maintain 

(255)   The  workforce  can  be  categorised  in  the  following  groups:  (i)  nuclear  experts  (those  with  formal 
higher  education  in  nuclear  fields:  nuclear  engineers  and  scientists,  power  plant  operators);  (ii) 
nuclearised  professionals  (non-nuclear  engineers  and  technical  staff:  construction  workers, 
technicians);  and  (iii)  nuclear-aware  support  staff  (e.g.  regulatory  staff  to  access  and  license  new 
projects). 

(256)   GIFEN, Programme Match, April 2023 

(257)   GIFEN,  Programme  Match,  April  2023;  ENEN2plus  Euratom  Research  and  Training  Programme 

Project. 

(258)   NEA (2018), Measuring Employment Generated by the Nuclear Power Sector. 

(259)   Report  on  the  European  nuclear  ecosystem,  prepared  by  Deloitte  for  DG  ENER,  2023  [yet 

unpublished]. 

(260)  

Impact Report – Vision to 2050, prepared by Deloitte for Foratom, April 2019. 

(261)   Report  on  the  European  nuclear  ecosystem,  prepared  by  Deloitte  for  DG  ENER,  2023  [yet 

unpublished]. 

111 

 
 
the planned nuclear power plants. Lastly, the decommissioning sector may require a 
further 40,000 professionals. 

Figure 37 presents an overview of the expected recruitment needs in the nuclear sector 
until 2035, depending on the growth in the sector. Even under a no-growth scenario 
(nuclear generation capacity stays stable), around 100,000 people would still need to 
be recruited to replace retiring workers. 

Figure 37 – Recruitment needs under different nuclear growth scenarios by 2035 (thousands) 

Source:  ENEN2plus Euratom Research and Training Programme Project. 

6.3.2. 

Main challenges 

•  Ageing workforce 

Many of the skilled professionals  were  recruited  in  the 1970s and 1980s, during a 
period of rapid growth of the nuclear industry. These workers are now approaching 
retirement age.  

The ageing workforce and the decline in the number of nuclear professionals under 
the age of 35 presents a risk for the future construction and operation of nuclear power 
plants and decommissioning of old ones. 

•  Nuclear sector has an image problem and is not attractive to young people, often 

not even considered as an option. 

Like many traditional industries, the nuclear industry has experienced  a  decline in 
popularity, with  many  young people opting for careers in  other industries, such as 
renewable energy or information technology, leading to a lack of human capital to 
replace the existing workforce. 

The ageing workforce and lack of sufficient newcomers creates a bottleneck for new 
nuclear projects and leads to a situation where many companies are competing for a 
limited number of professionals.  

112 

 
 
•  Insufficient  education  in  science,  technology,  engineering,  and  mathematics 
(STEM  subjects),  in  particular  when  compared  with  Asian  countries (262).  This 
topic  is  addressed  in  more  detail  in  the  recent  Commission  Communication  “A 
STEM Education Strategic Plan: skills for competitiveness and innovation” (263). 
Even with good educational programmes, there are no quick fixes, since becoming 
a skilled nuclear worker takes many years. Figure 38 shows that depending on the 
starting point, it takes 4–14 years to achieve a basic high level STEM education, 
which then needs to be further developed by on-the-job training. 

Figure 38 – Timeline for becoming a skilled nuclear worker 

Source:  Report on the European nuclear ecosystem, prepared by Deloitte for DG ENER, 2023 [yet 

unpublished]. 

Improving  the  availability  of  skilled  personnel  for  the  nuclear  industry  requires  a 
structured, targeted and multifaceted approach that involves education and training 
programmes, increased university programmes, apprenticeships and internships, and 
partnerships between public organizations and industry. 

This will require a clear EU vision for nuclear energy, availability of quantified data 
from  national  workforce  assessments  and  better  funding  and  financing  options. 
Engaging  national/regional  and  local  authorities,  as  well  as  improving  the  gender 
balance and youth engagement through scholarship opportunities, are also critical for 
ensuring the long-term sustainability of the sector. 

Focusing  on  the  low-carbon  benefits  of  nuclear  energy  and  the  promising  new 
technologies – SMRs and AMRs – could help to improve the attractiveness of the 
nuclear  sector.  SMRs  can  also  help  maintain  highly  skilled  and  well-paid  jobs  in 
places where they would otherwise disappear (for example due to the closure of coal 
fired plants), and they can help to attract workers if they are sited closer to major cities 
than  conventional  nuclear  power  plants.  At  the  same  time,  insufficient  human 
resources  may  also  become  an  important  bottleneck  for  SMR  deployment.  In  the 

(262)   The Global Distribution of STEM Graduates: Which Countries Lead the Way? | Center for Security 

and Emerging Technology 

(263)   Commission Communication to the European Parliament, the Council, the European Economic and 
Social  Commitee  and  the  Commitee  of  Regions  “A  STEM  Education  Strategic  Plan:  skills  for 
competitiveness and innovation”, COM(2025) 89 final 

113 

 
 
 
context of the European Industrial Alliance on SMRs, a dedicated Technical Working 
Group on skills has been set up, see section 5.1.5. 

The  elevation  of  skills  to  the  Executive  Vice  President  level  within  the  new 
Commission  and  the  recent  Commission  Communication  Union  of  Skills (264) 
underscore the growing recognition of their importance in different policy areas. The 
Draghi report highlights the necessity for a Nuclear Skills Academy for attracting and 
retaining talent, particularly in light of the emergence of new technologies (SMRs and 
AMRs)  (265).  Such  an  Academy  could  serve  as  an  EU  umbrella-initiative  that 
encompasses all ongoing EU activities, develops complementary training actions, and 
offers strategic advice for the support of future initiatives. In this context, Net Zero 
Industry Act (266) also establishes Net Zero Industry Academies to develop learning 
content for education and training providers in EU countries. 

Member  States  play  a  vital  role  in  formulating  policies  and  providing  funding  to 
facilitate  the  development  and  functioning  of  the  nuclear  industry  and  academia. 
However,  budgets  would  need  to  be  increased  to  ensure  a  sufficient  number  of 
professionals for the nuclear sector. 

The  Commission  can  play  a  pivotal  role  as  a  catalyst  and  network  facilitator, 
including  through  coordinating  research  and  innovation  needs  under  the  Euratom 
Research  and  Training  Programme.  Currently  the  Horizon  Europe,  a  Research  & 
Innovation funding programme that runs until 2027 is providing support for education 
and training activities, albeit not specifically in the nuclear sector. It is also crucial to 
have  sufficient  up-to-date  high-level  nuclear  research,  testing  and  training 
infrastructures  available  in  Europe,  and  to  maintain  access  to  the  facilities  of  the 
Commission’s Joint Research Centre. 

The  need  for  robust  European  nuclear  research  infrastructure  has  an  important 
significance  as  it  supports  cutting-edge  research,  fosters  innovation,  and  enhances 
collaborative  efforts  among  Member  States.  This  includes  the  development  and 
maintenance  of  experimental  facilities,  data-sharing  platforms,  and  integrated 
research  networks  that  enable  scientists  and  engineers  to  conduct  comprehensive 
studies in nuclear safety, waste management, fusion energy, and the development of 
next-generation  reactor  technologies.  It  also  ensures  that  Europe  remains  at  the 
forefront of nuclear science and technology, maintaining Europe’s competitive edge 
in  the  global  research  landscape  and  in  meeting  future  energy  and  environmental 
challenges. 

(264)   COM(2025) final. 

(265)   The  Draghi  Report,  The  future  of  European  competitiveness,  Part  B  |  In-depth  analysis  and 

recommendations, p. 37. 

(266)   Regulation  (EU)  2024/1735  of  the  European  Parliament  and  of  the  Council  of  13  June  2024  on 
establishing a framework of measures for strengthening Europe’s net-zero technology manufacturing 
ecosystem and amending Regulation (EU) 2018/1724, OJ L, 2024/1735, 28.6.2024 

114 

 
 
 
Box – EHRO-N 

The  European  Human  Resources  Observatory  for  the  Nuclear  Sector 
(EHRO-N)  is  driven  by  organisations  representing  major  stakeholders  in  the 
European Civil  Nuclear  Sector and managed by  the European Commission’s 
Joint Research Centre (JRC). 

EHRO-N mission is built on the strong mandate of the Council of the European 
Union in 2008: “It is essential to maintain in the European Union a high level 
of education and training in the nuclear field and, at the same time, preserve the 
skills that we already have.” 

EHRO-N  is  collaborating  with  “EURATOM  Coordination  and  Support 
Actions” on education and training such as ENEN2Plus. 

Finally, students and graduates must know that they are needed, and that there is work 
for  them.  This  can  be  done  by  more  frequent  exchanges  between  industry  and 
academia  (hosting  lectures,  workshops,  industry  apprenticeship,  mentoring).  The 
industry could also support independent scientific centres outside their companies. 

Above  all,  close  cooperation  between  industry,  universities  and  governments  is 
needed. 

115 

 
 
Box – Cooperation on skills between different stakeholders  

In  the  Netherlands,  a  declaration  of  intent  was  signed  in  January  2024  by 
industry participants COVRA, EPZ, NRG-Pallas and Urenco, and educational 
institutions  Scalda,  Horizon  College/Regio  College,  Vonk,  ROC  van  Twente 
and TU Delft. 

The aim was to jointly develop a new nuclear curriculum to attract students for 
careers in the nuclear sector. The organisations will develop a multi-year plan 
for cooperation and will jointly explore funding opportunities. 

NRG-Pallas  and  TU  Delft  are  already  cooperating  on  the  Nuclear  Academy 
programme, which is funded by the Ministry of Economic Affairs and Climate. 
The programme focuses on strengthening nuclear knowledge and skills in the 
Netherlands on various levels. 

Moreover,  Urenco is  supporting  the Delft Excellent Laboratory  Facilities  for 
Innovation and Nuclear Education (DELFINE) programme for three years to 
increase  the  pool  of  nuclear  talent.  The  collaboration  between  TU  Delft  and 
Urenco annually supports at least 60 students and researchers in their research 
work, both in the field of energy and medical isotopes.  

In France, the French nuclear industry, the Union des Industries et Métiers de 
la  Métallurgie  (UIMM),  the  Union  Française  de  l'Electricité  (UFE),  France 
Industrie and Pôle Emploi have created a "Université des Métiers du Nucléaire" 
(University  of  Nuclear  Professions)  to  boost  the  nuclear  sector’s  training 
systems at regional, interregional and national levels. 

EDF  is  also  involved  at  all  levels  of  education,  from  high  schools  to  higher 
education institutions. It collaborates with the Training Centre for Apprentices 
in  Energy  Professions  (Centre  de  Formation  des  Apprentis  des  Métiers  de 
l’Energie – CFA) to increase the number of technician trainees, as well as of 
apprentices and interns. 

The  Euratom  project  Skills4Nuclear  started  in  March  2025  to  address 
shortages in nuclear skills for current and future technologies, such as SMRs 
and fusion energy. The initiative gathered 19 European partners: universities, 
research centres, nuclear and other industrial sectors, as well as education and 
human  resources  specialists.  Skills4Nuclear  will  lay  the  groundwork  for  a 
nuclear  skills  strategy  for  Europe.  It  aims  at  promoting  cross-sector 
collaboration and mobility, including upskilling and reskilling. Additionally, it 
seeks  to  improve  diversity  and  digitalisation  in  the  sector.  Skills4Nuclear 
complements the existing efforts carried out under the Euratom Research and 
Training Programme to  support nuclear education and ease access to nuclear 
research infrastructures with projects such as ENEN2Plus and OFFERR. 

116 

 
 
6.4. 

International cooperation 

6.4.1. 

International partnerships 

Euratom external relations with third countries and international organisations allow 
to foster progress in the peaceful uses of nuclear energy. 

According  to  article  101  of  the  Euratom  Treaty,  the  Community  may  conclude 
agreements with a third-State or an international organisation.  

Furthermore,  Euratom,  its  26  non-nuclear  weapon  Member  States,  and  the 
International Atomic Energy Agency (IAEA) signed agreements (267) to implement 
safeguards  in  connection  with  the  Treaty  on  the  Non-Proliferation  of  Nuclear 
Weapons (NPT). 

In 2022 Euratom also signed a Memorandum of Understanding (MoU) with the IAEA 
on nuclear safety cooperation, covering, in addition to developing R&D cooperation, 
the safety of SMRs and fusion devices.  

Euratom, while not a member of the OECD Nuclear Energy Agency (NEA), attends 
as  an  invited  guest  its  Steering  Committee  for  Nuclear  Energy.  Euratom’s  goal  in 
participating in these meetings is to help align the positions of its Member States. 

Ukraine  is  associated  with  the  Euratom  Research  and  Training  Programme  2021-
2025,  while  the  agreement  for  Switzerland’s  association  has  been  initiated  and  is 
pending signature.  

6.4.2. 

Nuclear  cooperation  agreements  as  facilitators  and  enablers  for 
investments 

Euratom  has  so  far  signed  nuclear  cooperation  agreements  (NCAs)  with  10  third 
countries, see Table 17. The NCAs provide for cooperation with key partner countries 
on issues of mutual interest, including on nuclear safety and security of supply. They 
also  govern,  for  example,  the  transfer  of  nuclear  materials,  equipment  and 
technologies.  As  the  NCAs  provide  an  overall  framework  for  cooperation  in 
compliance with international norms, they can be seen as enablers and facilitators for 
investments.  

NCAs establish a legal framework that facilitates a wide range of cooperation in the 
peaceful uses of nuclear energy. 

•  Some  extended  scope  NCAs  aim  specifically  to  facilitate  nuclear  trade  and 
commercial  cooperation  (e.g.  Euratom  –  US,  UK (268)  or  JP).  In  the  US  or 

(267)  

 INFCIRC/193, 5 April 1973; INFCIRC/290, 27 July 1978. 

(268)   As evidence for the enabling nature of NCAs, in addition to the 2021 NCA with UK, a  2018 UK 
Euratom  Exit  factsheet  explicitly  noted  that:  “[…]  The  UK  currently  utilises  Euratom’s  NCAs  to 
enable  trade  with  Australia,  Canada  and  the  US  (trade  with  Japan  is  facilitated  by  an  existing 
Euratom-Japan  NCA  in  addition  to  the  UK-Japan  NCA).”  –  Euratom  Exit  Factsheet:  Nuclear 
Cooperation Agreement 

117 

 
 
Canada (269),  for  example,  a  NCA  is  a  legal  pre-condition  for  cooperation  with 
Euratom Member States as regards bilateral transfers of nuclear materials.  

•  Other NCAs have a narrower scope and are mostly limited to nuclear safeguards 

and non-proliferation provisions (Uzbekistan, Kazakhstan, Ukraine). 

Table 17 – Euratom Nuclear Cooperation Agreements (with a narrow and extended scope) 

Scope 

Year of signature 

CA 
1959 

Facilitating trade 
Supply of nuclear material 
Supply of non-nuclear material 
Supply of equipment 
Technology transfer 
Procurement & equipment of devices 
Waste management 
Nuclear safety 
Nuclear security and physical 
protection 
Nuclear safeguards 
Non-power uses 
Mining 
Research and development 
Fusion 
Tritium 

✔ 
✔ 
✔ 
✔ 
✔ 
✔ 
✔ 

✔ 

✔ 

✔ 

✔ 

Year of signature 

AR 
1997 

Extended scope 
JP 
2007 

US 
1996 
✔ 
✔ 
✔ 
✔ 

✔ 
✔ 

✔ 

✔ 
✔ 

ZA 
2013 
✔ 
✔ 
✔ 
✔ 

✔ 
✔ 

✔ 

✔ 
✔ 

✔ 
✔ 

✔ 
✔ 
✔ 

✔ 
✔ 

✔ 

✔ 

✔ 

Narrow scope 
UA 
2006 
✔ 

KZ 
2009 
✔ 

UZ 
2003 
✔ 

Facilitating trade 
Supply of nuclear material 
Supply of non-nuclear material 
Supply of equipment 
Technology transfer 
Procurement & equipment of devices 
Waste management 
Nuclear safety 
Nuclear security and physical 
protection 
Nuclear safeguards 
Non-power uses 
Mining 
Research and development 
Fusion 
Tritium 

Source:  European Commission. 

✔ 
✔ 

✔ 
✔ 

✔ 

✔ 
✔ 

✔ 

✔ 
✔ 

✔ 

✔ 

✔ 

✔ 
✔ 

✔ 
✔ 

✔ 

✔ 

✔ 
✔ 

✔ 

UK 
2021 
✔ 
✔ 
✔ 
✔ 
✔ 
✔ 
✔ 
✔ 

✔ 

✔ 
✔ 
✔ 
✔ 
✔ 

AU 
2012 

✔ 
✔ 
✔ 
✔ 
✔ 
✔ 
✔ 

✔ 

✔ 
✔ 
✔ 
✔ 

Notes: 

Dates refer to the publication year in the Official Journal of the EU.  
EURATOM also concluded R&D NCAs with India and China; as such they are however less 
likely to trigger important investments. 

(269)  

International agreements 

118 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In conjunction with other non-proliferation tools, particularly the NPT, the NCAs help 
to  advance  broader  non-proliferation  and  safeguards  principles.  They  include 
assurances that transfers of nuclear items in the scope of an agreement are properly 
protected, securely handled and used exclusively for peaceful purposes. 

6.4.3. 

Bilateral agreements as enablers for investments 

Some Members States prefer the use of bilateral agreements. They are complementing 
the Euratom level NCAs and cover elements which are not within the scope of such 
NCAs (e.g. transfer of technologies).  

Such  agreements  need  to  be  notified  to  the  Commission  under  Article  103  of  the 
Euratom Treaty so that the European Commission can carry out an assessment on the 
compatibility of any draft agreement or contract concluded by a Member State with a 
third  State,  an  international  organisation  or  a  national  of  a  third  State  with  the 
provisions of the Euratom Treaty and the secondary legislation adopted on its basis.  

Such  agreements  may  be  enablers  for  future  investments  decisions.  This  is  for 
example the case for the Canada-Romania cooperation agreement of 1977 as amended 
in 2015: 

Box – Nuclear cooperation agreements, the case of Romania and Canada  

The Canada-Romania nuclear cooperation agreement was signed in 1977 and 
amended in 2015. The agreement has had effects as facilitated investments in 
Romania’s nuclear sector, especially in recent developments. 

In September 2023, significant financial support enabled by the agreement was 
announced:  Canada  committed  CAD 3  billion  (c.  EUR  1.9  billion)  in  export 
financing  to  support  the  construction  of  two  new  CANDU-6  reactors  at  the 
Cernavoda Nuclear Power Plant. The investment is expected to create jobs both 
in Canada and Romania. 

The  agreement  has  also  effects  on  strategic  security  of  supply  as  it  allowed 
Romania to develop a stable and independent energy infrastructure, reducing 
dependency from Russia. 

6.4.4. 

Conclusion 

The Euratom external relations framework plays a crucial role in advancing peaceful 
nuclear  energy  initiatives  by  fostering  international  cooperation  and  investment. 
Through  strategic  agreements,  such  as  NCAs  and  Member  States’  bilateral 
agreements, Euratom may enhance compliance with safety standards, align Member 
States’  positions,  and  adapt  to  emerging  technologies,  ensuring  robust,  forward-
looking nuclear partnerships in accordance with the Euratom Treaty (270). 

(270) 

In addition. the European Instrument for International Nuclear Safety Cooperation (INSC) is a key 
tool for strengthening the adoption of the highest international nuclear safety standards globally. 

119 

 
 
 
The Commission  will reflect  on how to  further enhance these agreements  so as to 
capture new realities such as cooperation on the development of new technologies for 
example (SMRs/AMRs) not yet addressed in existing NCAs. 

120 

 
 
7.  FINANCIAL MODELS 

A frictionless market allows the financing of all economically efficient activities. In 
the context of power generation, a frictionless market would facilitate the deployment 
of the economically efficient mix of power generation technologies without a need 
for  state  intervention.  However,  in  the  presence  of  costs  and  benefits  market 
participants do not fully take into account (271), non-intervention from the government 
may  lead  to  unacceptable  outcomes,  such  as  insufficient  availability  of  generation 
capacity,  a  generation  mix  that  would  be  costlier  than  necessary,  or  the  failure  to 
decarbonise.  Section  7.1  describes  such  costs  and  benefits  the  Commission  has 
identified in the context of nuclear energy. Section 7.2 provides a brief overview of 
available instruments governments have used. In this context, the (re-)allocation of 
risks plays a crucial role. Section 7.3 summarises main risks affecting nuclear new 
build projects. Section 7.4 addresses the impact state support mechanisms may have 
on beneficiaries’ incentives in the context of nuclear energy. Section 7.5 summarises 
policy actions. It should be noted that this section is without prejudice to the case-by-
case  assessment  on  necessity,  appropriateness  and  proportionality  of  State  support 
required  to  ensure  State  aid  can  be  found  compatible  under  Article  107  TFEU. 
Member States considering the support of nuclear generation assets via State aid are 
invited to contact the Commission early on, and in any case considerably in advance 
of  any  formal  State  aid  notification,  to  avoid  delays  and  ensure  a  legally  and 
economically sound decision is taken. 

7.1.  Costs and benefits market participants do not fully take into account in 

nuclear energy and public intervention  

The Commission has identified certain costs and benefits market participants may not 
fully  take  into  account  relating  to  nuclear  power  development  that  could  be 
considered as a basis for public intervention.  

7.1.1. 

Lack of market-based instruments for risk allocation 

The Commission identified a lack of market-based instruments enabling stakeholders 
of a nuclear new build project  to  efficiently allocate the project  risks among them 
(272).  The  relevant  stakeholders  include  project  developer,  technology  vendor, 
electricity  consumers,  lenders,  state  entities,  however  there  are  possibly  more  to 
consider  on  a  case-by-case  basis.  Nuclear  new  build  projects  exhibit  longer 
construction  times  as  well  as  longer  operating  lifetimes  than  other  large-scale 
infrastructure and energy projects, see the Box below. An absence of market-based 
instruments that cover such long periods reduces the ability of private stakeholders to 
implement the optimal (or their desired) risk allocation among them. A suboptimal 
risk  allocation  results  in  one  or  more  stakeholders  assuming  risks  for  which  they 
demand  higher  compensation  in  the  form  of  return  on  investment  than  another 
stakeholder  would  under  the  optimal  allocation.  Thus,  suboptimal  risk  allocation 
increases the project’s cost of capital, i.e. the rate of return the project must generate 

(271)   See  Communication  from  the  Commission  –  Guidelines  on  State  aid  for  climate,  environmental 

protection and energy 2022 (2022/C 80/01) for more details.  

(272)   Commission Decision (EU) 2015/658 of 8 October 2014 on the aid measure SA.34947 (2013/C) (ex 
2013/N)  which  the  United  Kingdom  is  planning  to  implement  for  support  to  the  Hinkley  Point  C 
nuclear power station, (recitals 381 – 383). 

121 

 
 
 
for investors to sponsor the project (273). Changes in the required rate of return have 
a significant impact on the earnings the plant needs to generate during operations to 
recoup the initial investment. If the required rate of return goes too high, the project 
may not go ahead at all. This is consistent with industry players confirming at recent 
stakeholder events that the next nuclear new build projects will in their view require 
state support (274). It should be noted that some investors realise projects in nuclear 
installations  without  state  intervention.  Examples  include  lifetime  extensions  of 
existing  plants  in  the  EU,  Microsoft’s  investment  in  the  restart  of  the  previously 
shutdown plant at Three Miles Island in the US, and recently announced projects on 
investments in SMRs (see the box on data centres in section 5.1.3). 

Well-designed public interventions improve the risk allocation beyond what private 
parties could achieve by themselves. This reduces the project’s cost of capital (275). It 
enables  contributions  from  private  investors  who  would  otherwise  provide  less 
funding  or  stay  away  altogether.  Thus,  improving  the  risk  allocation  beyond  what 
private stakeholders can achieve on their own is part of minimising the public support 
required for the project to go ahead (276). Public intervention must respect State aid 
requirements and avoid overcompensating project sponsors (277). Thus, the lower the 
project’s  remaining  risk-exposure  post-intervention,  the  lower  is  the  return  project 
sponsors need and may expect, and vice versa.  

(273)   The lack of market-based instruments to implement the desired risk allocation may also affect the 
capital structure, i.e. the debt-to-equity ratio. Project developers may not be able to implement the 
capital structure they would desire in a complete market. For instance, the lack of a liquid market for 
long-term power purchase agreements could limit the amount of debt project developers can take on 
relative to a situation where such a market existed.  

(274)  

Industry  representatives  have  repeatedly  confirmed  this  view,  for  instance  at  the  17th  European 
Nuclear Energy Forum held from 30 September to 1 October 2024 in Prague, Czech Republic. 17th 
European Nuclear Energy Forum.  

(275)   The OECD’s Nuclear Energy Agency shares the view that a nuclear new build project’s risk allocation 
affects its cost of capital: “It is useful to think of financing as a project output, rather than a project 
input. Financing conditions are primarily the outcome of decisions regarding the management of the 
different risks affecting the project.” OECD Nuclear Energy Agency (2024), Effective Frameworks 
and Strategies for Financing Nuclear New Build, https://www.oecd-nea.org/jcms/pl_96124/effective-
frameworks-and-strategies-for-financing-nuclear-new-build, p. 11. 

(276)   This is consistent with the Commission’s practice to assess the proportionality of a proposed measure 

when assessing State aid notifications.  

(277)   Art 19d, para. 2 (c), Regulation (EU) 2019/943 of the European Parliament and of the Council of 5 
June 2019 on the internal market for electricity, as amended by Regulation (EU) 2024/1747 of the 
European Parliament and of the Council of 13 June 2024. 

122 

 
 
 
Box – Long project life cycle contributes to uncertainty 

Nuclear power plants and other clean energy generation technologies, e.g. solar 
and wind, have in common that the upfront capital costs account for a relatively 
large share of lifecycle costs. In contrast, operating costs account for a larger 
share of lifecycle costs for fossil-fuelled generation assets.  This  makes  clean 
technologies “capital intensive”. Nuclear power plants differ from most other 
clean generation technologies in that their construction periods are longer. The 
average commissioning time (i.e. time for planning and construction) for solar 
photovoltaic  (PV)  and  onshore  wind  projects  commissioned  in  the  OECD 
countries after 2011 was 2.3 and 2.7 years, respectively (•). By comparison, four 
nuclear  new  build  projects  began  construction  in  the  OECD  countries  after 
2011, the Vogtle 3 and 4 plants in the US, and the Shin-Hanul 1 and 2 plants in 
South Korea. The average construction time (i.e. excluding planning time) for 
these  four  plants  was  10.5  years  (†).  There  are  more  extreme  examples,  e.g. 
Olkiluoto 3 in Finland and Flamanville 3 in  France, where construction took 
more than 17 years.  

The long construction period contributes to uncertainty of construction costs. 
For  projects  with  relatively  short  construction  periods,  e.g.  solar  PV,  project 
developers may be able to contract all required input materials and services for 
a fixed price in advance. At the time of the final investment decision, there is 
only little uncertainty around construction costs, because all or a large part of 
the  construction  costs  are  locked  in.  For  projects  with  a  longer  construction 
period, e.g. nuclear or offshore wind, suppliers and service providers may not 
be able or may not be willing to agree to fixed prices several years in advance 
(‡).  Therefore,  prices  of  the  required  goods  and  services  may  change  as 
construction  is  already  underway.  This  leads  to  higher  uncertainty  around 
construction costs at the time the project developer takes the final investment 
decision. The long operating period also poses a challenge. The design life of 
the EPR2 reactor model is 60 years, older reactor models have design lives of 
30  or  40  years.  Available  market-based  instruments  to  trade  electricity,  e.g. 
power futures or power purchase agreements, do not cover such long periods. 
Likewise, commercial banks typically do not offer loans for such long horizons 
and typically only sovereign entities can emit bonds with such long maturities. 
Therefore, project developers remain exposed to uncertainty on market price of 
electricity, which limits their ability to fund the project with debt. 

(•)  Anurag  Gumber,  Riccardo  Zana,  Bjarne  Steffen,  A  global  analysis  of  renewable  energy  project 

commissioning timelines, Applied Energy, Volume 358, 2024, 122563, Figure 2. 

(†)  Analysis based on IAEA PRIS database. 

(‡)  The lead contractor for engineering, procurement, and construction (EPC) at the Olkiluoto 3 new build 
project  agreed  to  a  fixed  price  ‘turnkey’  contract.  However,  the  EPC  contractor  itself  relies  on 
numerous suppliers and subcontractors during the construction project, and the EPC contractor may 
not be able to enter fixed-price contracts with all of them for all required inputs to the construction 
project at the time of the final investment decision. 

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7.1.2. 

Hold-up risk 

The Commission  also  recognised the challenge of (predominantly political) “hold-
up” risk in the context of nuclear new build projects (278). Laws and regulations may 
change during the lifetime of the project and thereby make the project less profitable 
than planned. Once private parties have sunk capital in the project, they are locked in 
and may not be able to recover their investment if the state intervenes afterwards. In 
principle,  all  investments  face  this  risk,  i.e.  it  is  not  specific  to  infrastructure  or 
nuclear.  However,  for  projects  with  long  lifetimes  and  with  more  applicable 
regulations,  such  as  nuclear,  potential  investors  may  perceive  the  risk  to  be  more 
pronounced. This risk of ex-post intervention may lead private investors to require a 
higher  return  on  investment  than  they  would  otherwise,  or  it  may  deter  potential 
private investors from participating in a project altogether. The lack of market-based 
risk  allocation  instruments  may  further  compound  this  challenge.  The  state  can 
alleviate hold-up risk by providing specific change-of-law or policy protections, or 
by  participating  in  the  project,  e.g.  through  derisking  instruments  like  loans  or 
guarantees,  which  are  in  general  less  distortive  than  an  equity  contribution.  State 
funding  may  serve  as  a  commitment  device  by  which  the  state  reassures  private 
investors that it will not harm the project ex post.  

7.1.3. 

Externalities relating to investment needs in other infrastructure 

In  addition,  there  may  be  a  further  rationale  for  state  intervention  arising  from  a 
possible externality: the continued efforts to decarbonise the economy will require an 
expansion  of  electricity  generation  capacity  in  the  EU.  Every  newly  deployed 
generator must be connected to the existing electricity grid except for special cases 
where a generator has a direct connection to a consumer. Distributed generation assets 
may  require  higher  investments  in  the  build-out  of  electricity  transmission  and 
distribution networks than centralised assets. However, under the current electricity 
market  design  in  the  EU,  wholesale  power  prices  do  not  fully  reflect  network 
capacities, or the costs associated with expanding the network (279). Studies carried 
out by the French electricity transmission system operator RTE (280) and by the US 
Department of Energy (281) have demonstrated that the deployment of new large-scale 
nuclear reactors may contribute to reduce the electricity system integration costs (see 
section  2.1).  Depending  on  the  electricity  system  under  consideration,  the  lower 
investment  needs  for  transmission  and  distribution  infrastructure  and  storage  can 
outweigh the high upfront costs for new large-scale reactors. In such an instance, the 
potential  to  reduce  investments  in  networks  and  storages  constitutes  a  positive 
externality (282), which is neither reflected in wholesale electricity prices nor fully in 

(278)   Commission Decision (EU) 2015/658 of 8 October 2014 on the aid measure SA.34947 (2013/C) (ex 
2013/N)  which  the  United  Kingdom  is  planning  to  implement  for  support  to  the  Hinkley  Point  C 
nuclear power station (recitals 384 – 385). 

(279)   The  Joint Research Centre (JRC) has procured a tender in order to analyse the possibility and the 
effects of implementing nodal pricing in the European Internal electricity market based on the current 
and proposed legal framework: Antonopoulos, G. Vitiello, S. Fulli, G. Masera, M., Nodal pricing in 
the European Internal Electricity Market, EUR 30155, Publications Office of the European Union, 
Luxembourg, 2020, ISBN 978-92-76-17571-1, doi:10.2760/41018, JRC119977. 

(280)   RTE (October 2021), Futurs énergétiques 2050, Principaux résultats, p. 31.  

(281)   US Department of Energy (September 2024), Pathways to Commercial Liftoff: Advanced Nuclear, 

p. 10. 

(282)   Achieving  decarbonisation  targets,  including  further  electrification  of  the  economy,  will  require 
significant  investments  in  network  and  storage  infrastructure  in  any  scenario.  The  quoted  studies 

124 

 
 
the fees project sponsors pay for having their newly built generation assets connected 
to  the  network  (283).  This  externality  may  provide  an  additional  rationale  for  state 
intervention to support nuclear power development beyond what the Commission has 
identified to date.  

In summary, a well-designed state intervention: (i) should facilitate an efficient risk 
allocation among stakeholders, including the risks allocated to the state, while using 
instruments which are the least distortive for the market; (ii) address potential hold-
up  risk;  and  (iii)  internalise  externalities  relating  to  total  system  costs  if  there  are 
some.  

7.1.4. 

Costs  and  benefits  market  participants  do  not  fully  take  into 
account in the context of SMRs and AMRs 

SMRs  and  AMRs  are  an  emerging  technology  and  not  yet  mature.  Promoting  the 
development and adoption of these technologies may benefit from state intervention 
as well. However, the costs and benefits  market  participants do not  fully take into 
account justifying the intervention in SMRs and AMRs are likely to be different than 
for  large-scale  reactors,  which  are  an  established  technology.  The  Commission 
cleared the State aid application submitted by France to support the Nuward SMR 
project (284). When assessing the application, the Commission applied the State aid 
framework  for  research  and  development  and  innovation  (RDI  framework).  The 
Commission Communication on the RDI framework clarifies the economic rationale 
to support RDI in early-stage technologies such as SMRs and AMRs: “Whereas it is 
generally accepted that competitive markets tend to bring about efficient results in 
terms of prices, output and use of resources, in the presence of [costs and benefits 
market participants do not fully take into account]State intervention may be necessary 
to facilitate or incentivise the development of certain economic activities that, in the 
absence of aid, would not develop or would not develop at the same pace or under 
the  same  conditions  and,  thereby,  contribute  to  smart,  sustainable  and  inclusive 
growth. In the context of R&D&I, [costs and benefits market participants do not fully 
take into account] may arise for instance because market players do not necessarily 
or at least spontaneously take into account the wider positive effects for the European 
economy, consider reaching a positive economic result as overly risky, and therefore, 
in the absence of State aid, would engage in a level of R&D&I activities which is too 
low from the point of view of society. Likewise, in the absence of State aid, R&D&I 
projects  may  suffer  from  insufficient  access  to  finance,  due  to  asymmetric 
information,  or  from  coordination  problems  among  firms.  […]  The  R&D&I 
Framework applies to all technologies, industries and sectors to ensure that the rules 
do not prescribe in advance which research paths would result in new solutions for 
products,  processes  and  services  and  do  not  distort  market  players’  incentives  to 
develop innovative technological solutions even in the presence of high risks” (285). 
Thus, the economic rationale to support SMRs and AMRs is not specific to nuclear 

suggest that deploying nuclear energy may allow reducing the investments in networks and storage 
relative to a decarbonisation scenario without nuclear energy. 

(283)  

If network operators distribute the costs of maintaining and expanding the network across network 
users,  the  price  signal  for  individual  project  developers  does  not  reflect  the  incremental  cost  of 
connecting their project to the network.   

(284)  Decision C(2024) 2655 final 

(285)   Communication from the Commission Framework for State aid for research and development and 

innovation 2022/C 414/01 (C/2022/7388), OJ C 414, 28.10.2022, p. 1–38  

125 

 
 
energy,  but  the  same  as  for  all  early-stage  technologies.  Once  SMRs  and  AMRs 
mature, the Commission may re-assess if any costs and benefits market participants 
do not fully take into account persist.  

7.2.  Legislation providing support instruments to manage risks  

Several EU Member States plan to include nuclear energy in their future energy mix. 
This involves facilitating new build projects or the LTO of existing plants. As long as 
the costs and benefits market participants do not fully take into account described in 
section 7.1 are present, state intervention can be required to avoid underinvestment in 
nuclear new build projects and possibly also in LTO projects. Thus, Member States 
must consider which financing model to employ to realise their plans.  

Recent  nuclear  new  build  projects  around  the  world  exhibit  a  variety  of  financing 
schemes,  including  two-way  contracts  for  difference  (CfDs),  power  purchase 
agreements (PPAs), and other mechanisms (286).  

•  CfDs: New build projects at Dukovany in the Czech Republic and in Poland, LTO 
of the Doel 4 and Tihange 3 units in Belgium, and the new build project at Hinkley 
Point C (HPC) in the United Kingdom.  

•  PPAs: The Barakah and Akkuyu new build projects in the United Arab Emirates 

and in Türkiye, respectively. 

•  Mankala model: The Olkiluoto 3 new build project in Finland (287). 

•  Fully  state  financed:  The  Paks  II  new  build  project  in  Hungary  is  fully  state 
financed,  based  on  an  intergovernmental  agreement  between  Hungary  and  the 
Russian Federation (288).  

•  Construction cost recovery: The consortium of utilities realising the Vogtle 3 and 
4 units in Georgia in the United States funded the project with equity and were 
allowed to pass-through partial construction costs in consumers’ electricity tariffs 
already during construction.  

•  Regulated asset base (RAB) model: The UK government proposes the RAB model 

for the planned Sizewell C nuclear new build project.  

(286)   A recent report by the OECD’s Nuclear Energy Agency provides a more comprehensive overview: 
OECD Nuclear Energy Agency (2024), Effective Frameworks and Strategies for Financing Nuclear 
New  Build, 
https://www.oecd-nea.org/jcms/pl_96124/effective-frameworks-and-strategies-for-
financing-nuclear-new-build 

(287)   Under the Mankala  model, several energy-intensive electricity consumers co-own the  power plant 
and  retain  the right  to  purchase  electricity  at  cost.  Thus,  the  Mankala  model  can  be  viewed  as  an 
example of vertical integration along the value chain. 

(288)   Commission Decision of 6.3.2017 on the Measure / Aid Scheme / State Aid SA.38454 - 2015/C (ex 
2015/N) which Hungary is planning to implement for supporting the development of two new nuclear 
reactors at Paks II nuclear power station,  C(2017) 1486 final (recitals 9 – 16). Austria pleaded the 
General  Court  for  the  annulment  of  this  Commission  decision  in  Case  T-10.  The  General  Court 
dismissed the action in its judgment of 30 November 2022. In the ongoing appeal Case C-59/23 P | 
Austria v Commission, Austria pleas to set aside in its entirety the Case T-10 judgment and to annul 
the Commission Decision (EU) 2017/2112 on the State aid. 

126 

 
 
The EU’s Electricity Market Design (EMD) reform requires that direct price support 
schemes for investment in new power-generating facilities including nuclear facilities 
must  take  the  form  of  two-way  CfDs  or  equivalent  schemes  with  the  same 
effects (289). The EMD reform also encourages Member States to promote the uptake 
of PPAs (290).  

7.2.1. 

Two-way CfDs 

A two-way CfD takes  a “reference price” and a “strike price” as inputs. The plant 
operator  is  one  of  the  parties  to  the  CfD.  When  using  CfDs  for  state  support,  a 
government-sponsored entity may be the counterparty to the CfD. The counterparty 
need  not  be  the  electricity  off-taker.  For  each  unit  of  electricity  produced  or  for  a 
defined reference quantity, the plant operator pays the difference between the strike 
price and the reference to the counterparty if the reference price is above the strike 
price,  and  it  receives  the  difference  from  the  counterparty  if  the  reference  price  is 
below the strike price. Figure 39 illustrates this. 

(289)   Art 19d, para. 1, Regulation (EU) 2019/943 of the European Parliament and of the Council of 5 June 
2019  on  the  internal  market  for  electricity,  as  amended  by  Regulation  (EU)  2024/1747  of  the 
European Parliament and of the Council of 13 June 2024. 

(290)   Art 19a, para. 1, Regulation (EU) 2019/943 of the European Parliament and of the Council of 5 June 
2019  on  the  internal  market  for  electricity,  as  amended  by  Regulation  (EU)  2024/1747  of  the 
European Parliament and of the Council of 13 June 2024. 

127 

 
 
Figure 39 – Illustration of a CfD 

Source:  European Commission. 

Notes: 

All  numbers  are  for  illustration  only  and  do  not  reflect  any  real-world  examples.  The  top 
                                 D’  R         P                              . E        
the evolution is uncertain. The dark blue bars and light blue bars represent the inner 25% 
probability  and  inner  50%  probability  area  for  the  materialisation  of  the  reference  price, 
respectively. The solid blue graph represents a random realisation of the Reference Price.

The bottom panel shows the payments between the operator and the CfD counterparty for 
a given Strike Price (dashed green line) for the realised Reference Price. If the Reference 
Price is lower than the Strike price, the CfD counterparty pays the difference to the operator 
(blue crossed areas). If the Reference Price exceeds the Strike Price, the operator pays the 
difference to the CfD counterparty (green squared area). If the operator sells the produced 
electricity  at  the  Reference  Price,  the  earnings  from  the  electricity  market  together  with 
these difference payments result in a combined, stable earnings stream equivalent to having 
sold the electricity at the Strike Price. 

The  design  choices  in  a  CfD  pertain  to  contract  term,  the  definition  of  strike  and 
reference  prices,  reference  quantities  where  applicable,  and  other  features.  For 
instance,  the  strike  price  could  be  a  fixed  number,  it  could  track  some  long-term 
average electricity price, it could be indexed to some inflation measure, or it could 

128 

 
 
  
reflect the construction cost of the plant. The reference price is typically a price index, 
but here, too, there are multiple design options. 

7.2.2. 

PPAs 

PPAs differ from two-way CfDs in some key respects.  

•  Counterparty: For a given PPA, the supplier’s counterparty is the electricity off-
taker,  i.e.  a  single,  and  typically  private  economic  agent (291).  In  contrast,  the 
counterparty  to  a  CfD  is  typically  a  government-backed  entity.  This  has 
implications for the potential to re-allocate risks using a PPA (see section 7.3). 

•  Contract clauses: The two parties to a PPA are in principle free to negotiate any 
contract clauses they desire. Supplier and off-taker can agree freely the deliverable 
quantity, payable price, possible rights for the off-taker to modulate the quantity, 
and many other rights and obligations of supplier and off-taker (292).  

PPAs can facilitate delivering state support. If the off-taker is a private party, the state 
may provide additional guarantees to the PPA, and thereby improve the risk allocation 
between the two counterparties. If a state-sponsored entity is trading on the electricity 
wholesale market, it may directly act as counterparty to the PPA, i.e. as off-taker.  

7.2.3. 

RAB model 

The  UK  government  proposes  to  finance  the  planned  nuclear  new  build  project 
Sizewell C by adapting the RAB model (293). In the EU, the RAB model has not yet 
been  used  for  nuclear  installations.  It  has  a  long  track  record  regarding  assets  not 
exposed  to  competition,  as  it  has  been  widely  used  across  Member  States  to  set 
allowed  revenues  for  regulated  electricity  and  natural  gas  transmission  and 
distribution system operators (294), as well as for some transport infrastructure.  

(291)   Project sponsors could aim at selling the plant’s production via one PPA to a single counterparty. This 
approach may be particularly relevant for SMRs, as their smaller size may fit the need of a large off-
taker.  Alternatively, project sponsors could aim at entering multiple PPAs with a portfolio of off-
takers and spread risks over a wider group of economic agents this way. This approach may be more 
relevant for large-scale reactors. For instance, the Mankala model underlying the Olkiluoto 3 project 
in Finland foresees that project shareholders, which in this case are consumers from energy-intensive 
industries, off-take the produced electricity. 

(292)   Policymakers have considered the potential benefits of supporting the standardisation of PPA contract 
terms for renewables, e.g. through developing voluntary contract templates. The EU Agency for the 
Cooperation  of  Energy  Regulators  (ACER)  investigated  the  potential  benefits  of  PPA  terms 
standardisation for renewables. Following a stakeholder consultation, ACER concluded in October 
2024, “that it does not need to develop new voluntary PPA contract templates” [ACER, 15 October 
2024, Assessment on the need of ACER’s voluntary Power Purchase Agreement contract template(s),  
https://www.acer.europa.eu/electricity/market-
monitoring/ppas#:~:text=Power%20Purchase%20Agreements%20(PPAs)%20are,renewable%20ene
rgy%20sources%20(RES).] Given the large size of nuclear power plants, project sponsors who want 
to  use  PPAs  to  develop  their  projects  are  likely  to  prefer  bespoke,  i.e.  tailor-made  rather  than 
standardised,  contract  terms  for  nuclear  new  build.  If  SMRs  or  even  microreactors  become  wide-
spread in the future, potential benefits of standardised contract terms may become more relevant.  

(293)   Ofgem (06 November 2023), Guidance on our approach to the Economic Regulation of Sizewell C,  

(294)   ACER  (16  December  2024),  Electricity  infrastructure  development  to  support  a  competitive  and 

sustainable energy system, 2024 Monitoring Report, p. 28.  

129 

 
 
If  a  Member  State  and  project  developers  proposed  to  finance  nuclear  new  build 
projects using a RAB model in the future, they would have to consider at  least the 
following items. 

•  Compliance  with  EMD:  Direct  price  support  schemes  for  investment  in  new 
power-generating facilities shall take the form of two-way contracts for difference 
(CfDs) or equivalent schemes with the same effects. The Member State and project 
sponsors would have to ensure compliance with  the existing  legislation, e.g. by 
demonstrating that their proposed model qualifies as an equivalent scheme with 
the same effects (295).  

•  Reimbursement of allowed revenues: So far, the RAB model is mostly used to 
regulate  undertakings  which  are  either  licensed  monopolists  or  enjoy  a  certain 
degree of market power. The RAB model sets an upper limit for allowed revenues, 
but the regulated entities must earn revenues from their customers (296). If revenues 
fall short of the allowed upper limit, e.g. because of low demand, the shortfall may 
be credited to the allowed revenues in future years. This system works when the 
regulated  entity  enjoys  sufficient  market  power,  as  is  the  case  with  licensed 
monopolists. In contrast, nuclear power plants compete with other generators in 
the  electricity  wholesale  market  and  do  not  enjoy  market  power  if  the  market 
performs as intended. Thus, financing power plants through a RAB model would 
require  the  Member  State  to  appoint  an  entity  from  which  the  RAB-financed 
nuclear  power  plant  can  claim  revenue  shortfalls,  and  to  which  it  would  owe 
revenue surpluses (297). This entity would have to be backed either by electricity 
consumers or taxpayers (298). In fact, the UK government’s proposal for financing 
Sizewell C through a RAB model proposes the government-owned Low Carbon 
Contracts Company as the designated revenue collection counterparty (299).  

The RAB model relies on two high-level cornerstones. These are the “regulated asset 
base”  and  an administratively allowed rate of return. The regulated asset  base is  a 

(295)  

If  the  Member  State  and  project  sponsor  show  that  their  proposed  RAB  model  qualifies  as  an 
equivalent  measure  with  the  same  effects,  they  would  also  have  to  ensure  alignment  with  the 
remaining provisions of Art. 19d Regulation (EU) 2019/943 of the European Parliament and of the 
Council  of  5  June  2019  on  the  internal  market  for  electricity,  as  amended  by  Regulation  (EU) 
2024/1747 of the European Parliament and of the Council of 13 June 2024. 

(296)   EU regulators setting network tariffs using a RAB model oftentimes proceed in two steps. In a first 
step, the RAB model determines the allowed revenues. In a second step, the regulator applies an ex-
ante assumption for the likely quantity sold during the relevant regulatory period to derive regulated 
network  tariffs.  In  a  hypothetical  case,  where  a  Member  State  used  the  RAB  model  to  finance  a 
nuclear power plant, the second step, deriving regulated prices from allowed revenues, would not be 
needed.  

(297)   Supporting a beneficiary through a CfD requires appointing a similar counterparty.  

(298)   Whereas backing through taxpayers may be possible in principle, EU legislation prescribes that “any 
revenues,  or  the  equivalent  in  financial  value  of  those  revenues,  arising  from  direct  price  support 
schemes in the form of two-way contracts for difference and equivalent schemes with the same effects 
referred […] shall be distributed to final customers”; Art 19d, para. 5, Regulation (EU) 2019/943 of 
the European Parliament and of the Council of 5 June 2019 on the internal market for electricity, as 
amended by Regulation (EU) 2024/1747 of the European Parliament and of the Council of 13 June 
2024.  

(299)   Department  for  Energy  Security  and  Net  Zero  and  Department  for  Business,  Energy  &  Industrial 
Strategy (9 June 2022), Notice given pursuant to Section 16 of the Nuclear Energy (Financing) Act 
2022  to  designate  Low  Carbon  Contracts  Company  Ltd  as  a  counterparty  for  revenue  collection 
contracts for the purposes of the nuclear RAB Model  

130 

 
 
register  of  historical  capital  expenditures,  approved  by  a  regulatory  authority,  that 
gets depreciated over time. Allowed revenues usually reflect depreciation of the asset 
base,  allowed  return  on  the  asset  base,  and  regulatory  approved  operational 
expenditures.  In  practice,  there  are  many  different  design  features  that  allow  fine-
tuning  of  the  RAB  model.  The  specific  RAB  model  implementations  for  network 
operators  vary  across  Member  States,  within  each  Member  State,  they  often  vary 
across the regulated network operators (300), and they may evolve over time. 

7.3.  Allocating electricity market and construction risk is key  

Figure 40 illustrates the main risk categories a nuclear new build project faces during 
its life cycle. Political and regulatory risks are constantly present. In addition, there 
are distinct risks in each of the project’s life cycle, i.e. construction risk, operational 
radioactive  waste  management,  and 
and  electricity  market 
decommissioning risks. 

risks,  and 

Figure 40 – Risks along the life cycle of a nuclear installation 

Source:  OECD Nuclear Energy Agency (2024), Effective Frameworks and Strategies for Financing 
Nuclear  New  Build,  https://www.oecd-nea.org/jcms/pl_96124/effective-frameworks-and-
strategies-for-financing-nuclear-new-build, Figure 1.1, p. 18. 

A key question for every nuclear new build project is the allocation of construction 
and electricity market risks (301). Public interventions with the goal to unlock private 
investment  in  new  build  nuclear  projects  could  be  particularly  effective  if  project 
sponsors and policymakers design them in such a way that they allocate both risks. It 
is important that this does not mean that the investor should be shielded from all risk, 
as this  could  result in  a lack of incentives to  reduce construction cost  or to  follow 
market signals in operating the plant, see section 7.4. 

(300)   CEER (21 February 2024), Report on Regulatory Frameworks for European Energy Networks 2023, 

Ref: C23-IRB-70-03  

(301)   For instance, the Nuclear Energy Agency organised a workshop on “Financing Nuclear New Build 
Today”  in  Prague,  Czech  Republic,  on  13  June  2024,  where  participants  compared  a  number  of 
recently  adopted  or  discussed  financing  models  to  better  understand  the  allocation  they  imply  for 
construction and electricity price risks.  

131 

 
 
 
Stakeholders also regularly point to the importance of political and regulatory risk 
and the importance of a stable and predictable regulatory environment.  

7.3.1. 

Electricity market risk 

Electricity  market  risk  primarily  arises  from  uncertainty  about  future  electricity 
prices, which drives uncertainty about earnings. Re-allocating electricity price risk, 
e.g. through a CfD or a PPA, can lower a project’s cost of capital (302).  

A two-way CfD transfers the electricity market  risk  from  the plant operator to  the 
CfD counterparty, where precise risk allocation depends on the design of strike and 
reference prices. Beiter et al. (2024) find that “CfDs are a floating-for-fixed electricity 
price swap that transforms a variable electricity price into a fixed electricity price 
cash flow, with the two parties sharing in the electricity price risk. […] CfDs share 
similarities  with  financial  derivatives  used  to  manage  risk  in  other  sectors  of  the 
economy  –  for  instance,  an  interest  rate  swap,  where  banks  trade  the  difference 
between  interest  payments  calculated  on  the  basis  of  short-term  versus  long-term 
interest  rates,  or  mortgages  with  fixed  interest  rates  (to  ensure  predictability  of 
payments)  that  are  hedged  by  banks  through  swapping  the  long-term  fixed  rate 
against short-term rates to match the long-term exposure of the loan.” (303)  

PPAs allow for flexible pricing structures, which enables the two counterparties to re-
allocate  electricity  market  risk  between  the  two  of  them.  The  absence  of  a  liquid 
market for long-term PPAs is consistent with the Commission’s finding of a lack of 
market-based  instruments  for  risk  allocation  in  nuclear  energy  (304).  It  is  also 
consistent with the EMD requiring Member States to promote the uptake of PPAs.  

PPAs  allow  to  re-allocate  electricity  market  risk  only  between  two  parties,  the 
supplier and the off-taker. The electricity market risk arising from a GW-scale nuclear 
power  plants  may  be  too  large  for  most  private  counterparties  to  take  on 
individually (305). Project developers may be able to spread the risk across multiple 
off-takers, as is the case with the Olkiluoto 3 plant in Finland. In contrast, the CfD 
counterparty is usually a state-sponsored entity. This way, CfDs allow re-allocating 
the  electricity  market  risk  exposure  of  one  producer  to  all  electricity  consumers 
connected to the grid, i.e. to a numerous group of other economic agents, reducing 
the exposure of any individual.  

In 2024, the OECD’s Nuclear Energy Agency (NEA) prepared a comparative review 
of several case studies for nuclear new build projects around the world, focusing on 
the risk allocations implemented by the respective financing models. Figure 41 below 
shows  how  the  different  models  allocate  electricity  market  risk.  The  parties  who 
assume the largest share of electricity market risk in most  of the financing models 

(302)   Gohdes, Nicholas, Paul,  Simshauser, Wilson, Clevo, 2022. Renewable entry costs, project finance 
and the role of revenue quality in Australia’s National Electricity Market. Energy Econ. 114, 106312. 

(303)   Beiter,  P.,  Guillet,  J.,  Jansen,  M.  et  al.  The  enduring  role  of  contracts  for  difference  in  risk 

management and market creation for renewables. Nat Energy 9, 20–26 (2024), pp 22, 23. 

(304)  

If market-based instruments for risk allocation in nuclear energy were widely available, one would 
expect  to  observe  PPAs  spanning  the  operational  life  of  nuclear  power  plants,  as  well  as  other 
instruments.  

(305)   An intermediary might be able to pass-on the risk to a larger group of users, but it would require a 

sufficiently large client base.  

132 

 
 
surveyed  in  NEA’s  study  are  either  electricity  consumers  or  the  government,  i.e. 
taxpayers (306). 

Figure 41 – Electricity market risk across nuclear new build projects 

Source:  OECD Nuclear Energy Agency (2024), Effective Frameworks and Strategies for Financing 
Nuclear  New  Build,  https://www.oecd-nea.org/jcms/pl_96124/effective-frameworks-and-
strategies-for-financing-nuclear-new-build, Figure 3.6, p. 76. 

Notes: 

EPC = Engineering, Procurement, and Construction. 

7.3.2. 

Construction risk 

Construction risk remains a major hurdle to financing nuclear new build (307). From 
a  valuation  perspective,  construction  risk  is  driven  by  potential  cost  overruns  and 
delays  during  construction.  Pure  cost  overruns  increase  the  present  value  of 
construction capex and thereby reduce a project’s net present value (NPV). Delays 
lead to a later start of the operating period, i.e. they postpone the point in time as of 
which cash flows from operation come in and thereby reduce the present value of cash 
flows from operation and by extension the NPV of the project. In practice, delays are 
likely to go hand in hand with cost overruns, compounding the negative impact on the 
NPV.  

CfDs and PPAs, the two instruments featuring in the EMD reform, primarily focus 
on allocating electricity price risk. However, their features can be designed such that 
construction risk can also be addressed.  

•  The strike price of a CfD could be indexed to turnout construction costs, or to price 
indices for goods or services that are likely to affect construction costs, or there 
could be a review of the strike price after construction is finished. This would shift 
the risk of delays and cost overruns to the CfD counterparty. Thus, Member States 
and project developers may in principle use CfDs to re-allocate construction risk. 

(306)   Olkiluoto 3 and Paks II form the only two examples, where the authors classify the electricity market 
risk  to  reside  with  equity  providers.  However,  in  the  Mankala  model  applied  at  Olkiluoto  3,  the 
shareholders are large industrial electricity consumers who are also the plant’s off-takers, so one might 
classify this financing model as allocating the electricity market risk to consumers after all.  

(307)  

IEA (2025), The Path to a New Era for Nuclear Energy, IEA, Paris https://www.iea.org/reports/the-
path-to-a-new-era-for-nuclear-energy, Licence: CC BY 4.0 

133 

 
 
 
•  As  the  elements  of  a  PPA  can  be  designed  freely,  the  two  counterparties  may 
allocate some of the construction risk to the off-taker, if both parties agree to it. In 
turn, this may allow the plant owner to pass-on some insurance further up the value 
chain,  e.g.  to  the  contractor  for  Engineering,  Procurement,  and  Construction 
(EPC).  In  the  case  of  Olkiluoto  3,  off-takers  are  simultaneously  shareholders, 
which exposed them to  construction risk anyhow. Member States may consider 
designing guarantees to PPAs that cover construction risks.  

In practice, as the remuneration of the project developer should be closely linked to 
the amount of risk born, a reallocation of the construction risk toward the Member 
State would come with a reduction of its expected remuneration. 

The recently completed Vogtle plant in the US and the planned Sizewell C plant in 
the  UK  feature  financing  mechanisms  which  aim  to  enhance  the  re-allocation  of 
construction risk. Vogtle’s Nuclear Construction Cost Recovery (NCCR) mechanism, 
and  the  RAB  model  envisaged  for  Sizewell  C  allow  project  developers  to  collect 
revenues  even  before  the  construction  is  completed.  This  feature  can  avoid  that 
interest during construction piles up in the event of delays. This in turn, allows project 
developers to earn an agreed return on their capital expenditures with lower nominal 
earnings during operation than would be the case if earnings only came in once power 
production began. It may also allow project developers to increase the debt-to-equity 
ratio of the project earlier, i.e. already during construction, which has the potential to 
reduce the project’s cost of capital.  

Figure 42 shows the allocation of construction risk across nuclear new build projects 
according to NEA’s analysis. Most financing models allocate a significant share of 
construction risk to the Engineering, Procurement, and Construction (EPC) vendor or 
equity  providers,  and  all  models  leave  at  least  some  construction  risk  exposure  to 
them.  These  parties  seem  best  placed  to  influence  the  cost  and  duration  of  the 
construction process. Keeping them exposed to construction risk is consistent with 
providing incentives to deliver the project on time and within budget, see section 7.4 
(308). 

(308)   The  incentives  arising  from  a  support  measure  and  its  associated  financing  model  depend  on  the 
details  of  the  model  and  cannot  be  inferred  from  a  high-level  classification  or  risk  allocations  as 
presented in Figure 40. 

134 

 
 
Figure 42 – Electricity market risk across nuclear new build projects 

Source:  OECD Nuclear Energy Agency (2024), Effective Frameworks and Strategies for Financing 
Nuclear  New  Build,  https://www.oecd-nea.org/jcms/pl_96124/effective-frameworks-and-
strategies-for-financing-nuclear-new-build, Figure 3.4, p. 75. 

7.3.3. 

Political and regulatory risk 

Potential equity investors and stakeholders from the nuclear industry regularly point 
to  the  importance  of  political  and  regulatory  risk  and  the  challenge  arising  from 
uncertainty around long-term nuclear energy policy and regulatory frameworks.  

Financing investment projects in the nuclear industry as well as in any other industry 
can become more challenging if there is significant uncertainty around the duration 
and outcome of key administrative procedures. Member States can aim to reduce the 
perceived  uncertainty  around  these  decisions  by  providing  clear  guidelines, 
streamlining the process, ensuring sufficient resources for regulatory authorities and 
similar measures.  

A  more  fundamental  challenge  arises  from  the  fact  that  governments  may  retro-
actively change previous decisions. This source of uncertainty may interact with the 
other risks discussed earlier. It is closely related to the challenge of potential “hold-
up” discussed before. Some Member States have introduced retro-active changes to 
their wider energy policy in the past, and have been challenged for it by investors, 
who considered their energy assets had suffered damages as a result (309). It should be 
noted that in 2018, the Court of Justice found that investor-State arbitration clauses 
in intra-EU bilateral investment treaties (“intra-EU BITs”) are incompatible with the 
EU Treaties. To implement this judgement, 23 Member States signed the agreement 

(309)   As of 4 March 2025, the World Bank’s International Centre for Settlement of Investment Disputes 
(ICSID) lists 45 concluded cases and 35 pending cases against EU Member States in the economic 
sector  of  “Electric  Power  &  Other  Energy”.  https://icsid.worldbank.org/cases/case-database  
The  case  of  Germany  may  serve  as  an  example.  Swedish  state-owned  power  energy  company 
Vattenfall co-owned and operated two nuclear power plants located in Brunsbüttel and Krümmel, In 
August 2011, against the backdrop of the nuclear accident in Fukushima-Daiichi, Japan, the German 
Parliament amended its legislation to statutorily accelerate fixed end dates for the operation of nuclear 
power plants. The amendment cut short the operational lifetimes of Vattenfall’s nuclear power plants 
that had been fixed in 2010 by a previous amendment. Vattenfall challenged this amendment through 
the filing of a constitutional challenge with the German Federal Constitutional Court, and through the 
initiation of an investment arbitration against Germany under the Energy Charter Treaty.  

135 

 
 
 
for the termination of intra-EU bilateral investment treaties, which entered into force 
in 2020. 

On the one hand side, retro-active interventions may erode investor confidence in the 
long-term  stability  of  policy  measures.  This  can  reduce  the  effectiveness  of 
mechanisms  designed  to  manage  other  risks.  For  instance,  if  investors  are  not 
confident  that  the  strike  price  of  a  two-way  CfD  will  evolve  as  agreed,  they  may 
require the same compensation as if they were fully exposed to electricity price risk, 
even though the CfD re-allocates this risk on paper. This may drive up the project’s 
cost of capital despite the presence of a CfD, which may make it either costlier than 
necessary or may stop it from going ahead altogether. Member States committed to 
nuclear energy may try to re-assure investors through mechanisms that protect them 
from  potential  damages  of  retro-active  interventions.  For  instance,  the  state  may 
contribute the most junior tranche of capital or offer other guarantees. On the other 
hand, retro-active changes, e.g. the decision to  phase-out  nuclear or allocate fewer 
public  funds  to  supporting  clean  energy,  may  reflect  an  evolving  distribution  of 
preferences in the electorate.  

Figure  43  shows  the  allocation  of  political  and  regulatory  risk  across  nuclear  new 
build projects according to NEA’s analysis. NEA classifies most models as allocating 
this risk primarily to the government. This reflects that in many of the surveyed cases, 
the government offered some form of guarantee to protect the other stakeholders from 
unforeseen changes. 

Figure 43 – Political and regulatory risk across nuclear new build projects 

Source:  OECD Nuclear Energy Agency (2024), Effective Frameworks and Strategies for Financing 
Nuclear  New  Build,  https://www.oecd-nea.org/jcms/pl_96124/effective-frameworks-and-
strategies-for-financing-nuclear-new-build, Figure 3.3, p. 74. 

7.4. 

Incentives 

The design choices in CfDs and PPAs not only implement a desired risk allocation, 
but they also set incentives for the project developer and the counterparty. The plant 
operator  cannot  control  the  evolution  of  electricity  prices,  but  it  can  control  the 
dispatch of the plant, which affects earnings from the electricity market. Likewise, 
the project developer cannot fully control the cost and time to completion of a nuclear 
power  plant  construction  project,  but  it  has  some  influence  on  it,  e.g.  through 
implementing efficient project management.  

136 

 
 
However,  if  the  public  intervention  fully  insures  against  electricity  market  or 
construction risk, there is no longer an incentive for efficient behaviour. If the plant 
operator receives a guaranteed, fixed price per produced unit, there is no longer an 
incentive to optimise the plant dispatch in response to market signals (310). This would 
interfere with the wider electricity system, e.g. through distorting the plant operator’s 
incentives  to  provide  flexibility  to  the  system.  Such  interferences  would  lead  to 
disproportionate distortions of competition and trade in the internal market, and they 
must be avoided. Likewise, if a support scheme guarantees an agreed rate of return 
on any construction capital expenditures incurred, the project developer no longer has 
an incentive to do what is possible to deliver the project on time and within budget.  

An incentive-compatible financing mechanism does not insure the project sponsor in 
full. Instead, the mechanism shares the relevant risks between the project sponsor and 
a counterparty. The risk sharing mechanism will ensure that the project  sponsor is 
sufficiently protected to lower the project’s cost of capital, but at the same time leave 
the sponsor sufficiently exposed to incentivise efforts towards desirable objectives, 
including  plant  dispatch  based  on  market  signals,  construction  on  time  and  within 
budget, and adherence to the highest safety standards. 

As stated before, a lowering of the risk exposure born by the investor would come in 
parallel with a reduction of the expected remuneration.  

7.5.  Conclusions 

The Commission proposed a reform of the existing electricity market rules in March 
2023, as part of the Green Deal Industrial Plan (311). They entered into force in July 
2024. The Commission will work together with Member States to support them in 
transposing the rules into national law. This reform established amongst others that 
direct  price support schemes for investments in  new generation of electricity from 
low-carbon sources including nuclear energy must take the form of two-way CfDs or 
equivalent schemes with the same effects. In addition, Member States shall promote 
the uptake of PPAs.  

The Commission  will publish a Guidance on CfD design,  including  on combining 
CfDs and Power Purchase Agreements (PPAs) as announced in the Clean Industrial 
Deal (312).  This  Guidance  applicable  to  all  energy-related  projects,  may  support 
Member  States  in  designing  CfDs  for  nuclear  projects  in  an  incentive-compatible 
way, which may streamline State aid procedures. 

In  line  with  the  approach  in  the  Electricity  Market  Design,  the  Commission  will 
engage with the EIB to promote PPAs in a technology-neutral way.  

(310)  

Ingmar Schlecht,  Christoph Maurer, Lion Hirth, Financial contracts for differences: The problems 
with conventional CfDs in electricity markets and how forward contracts can help solve them, Energy 
Policy, Volume 186, 2024; Newbery, D. (2023). Efficient Renewable Electricity Support: Designing 
an Incentive-compatible Support Scheme. The Energy Journal, 44(3), 1-22.  

(311)   The  new  electricity  market  design  rules  consist  of  the  amending  Directive  EU/2024/1711  and  the 

amending Regulation EU/2024/1747. 

(312)   Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic and Social Committee and the Committee of the Regions, The Clean Industrial Deal: A 
joint roadmap for competitiveness and decarbonisation; COM/2025/85 final.  

137 

 
 
At the third high-level meeting of the Joint European Forum for Important Projects 
of  Common  European  Interest  (JEF-IPCEI)  on  9  April  2025,  13  Member  States 
endorsed  a  potential  IPCEI  candidate  on  innovative  nuclear  technologies.  This 
enables  the  IPCEI  candidate  to  transition  to  the  design  phase,  where  the 
Commission’s IPCEI Design Support Hub will assist it. 

The  EIB  and  the  European  Investment  Fund  (EIF)  support  start-ups  and  scale-ups 
across  Europe  by  providing  targeted  financial  products  and  risk  finance  through 
initiatives like InvestEU and the European Tech Champions Initiative (ETCI). These 
efforts  aim  to  enhance  access  to  finance  for  SMEs,  strengthen  European 
competitiveness, and drive innovation and growth in key sectors.  

The  European  Atomic  Energy  Community  (Euratom)  supports  the  further 
development of nuclear skills and competences through the Euratom Research and 
Training  programme.  Euratom  also  supports  Bulgaria,  Slovakia (313),  and 
Lithuania (314) as part of the nuclear decommissioning assistance programmes.  

The  European  Commission  is  empowered  to  issue  bonds  on  behalf  of  Euratom  to 
finance back-to-back loans to investment projects related to nuclear power generation 
and the nuclear fuel cycle in EU countries (315). Euratom can also finance investment 
projects related to nuclear safety improvements or the decommissioning of nuclear 
installations in certain EU neighbourhood countries (316). The total amount of lending 
for these activities is limited to EUR 4 billion (317), of which EUR 3.67 billion has 
already been allocated. 

(313)   Council  Regulation  (Euratom)  2021/100  of  25  January  2021  establishing  a  dedicated  financial 
programme for the decommissioning of nuclear facilities and the management of radioactive waste, 
and repealing Regulation (Euratom) No 1368/2013.  

(314)   Council  Regulation  (EU)  2021/101  of  25  January  2021  establishing  the  nuclear  decommissioning 
assistance programme of the Ignalina nuclear power plant in Lithuania and repealing Regulation (EU) 
No 1369/2013. 

(315)   Council Decision 77/270/Euratom of 29 March 1977 empowering the Commission to issue Euratom 
loans for the purpose of contributing to the financing of nuclear power stations, OJ L 88, 6.4.1977, p. 
9–10. 

(316)   Council Decision of 21 March 1994 amending Decision 77/270/Euratom to authorize the Commission 
to contract Euratom borrowings in order to contribute to the  financing required for improving the 
degree of safety and efficiency of nuclear power stations in certain non-member countries, OJ L-84, 
29.03.1994 p 4. 

(317)   Council Decision 90/212/Euratom of 23 April 1990, OJ No L 112, 03.05.1990, p 26. 

138 

 
 
 
 
Annex A 

Factual  summary  report  on  the  Call  for 
Evidence (CfE) (318) 

1.  OBJECTIVE OF THE CALL FOR EVIDENCE 

The 2025 Commission work programme (319) and the Action Plan for Affordable Energy 
(320) announced an updated assessment of investment needs in the EU’s nuclear sector in 
the form of a new PINC, to be adopted in 2025. Under Article 40 of the Euratom Treaty, 
the  Commission  is  required  to  publish  a  PINC  periodically.  These  programmes  are 
intended to stimulate action by undertakings and Member States and facilitate coordinated 
development of their investments in the nuclear field. 

The aim of the CfE was to inform Member States, the public and interested stakeholders, 
and  to  ask  for  feedback  and  insights  on  the  intended  initiative.  This  gives  them  an 
opportunity to help assess the EU’s nuclear investment needs in a collaborative, transparent 
and inclusive manner. 

This outreach to EU countries and stakeholders complements the Commission’s own data 
and information gathering process and prepares the ground for publishing the new PINC. 

2.  APPROACH TO THE CALL FOR EVIDENCE 

The  Commission  published  the  CfE  document  on  the  ‘Have  Your  Say’  website  in  24 
languages. There was no questionnaire but the possibility to submit free-text comments or 
attached documents. The consultation period ran from 14 April to 12 May 2025, lasting 
four weeks. Prior to publication, the Commission informed Member States about the CfE 
at  the  meeting  of  the  Working  Party  on  Atomic  Questions  on  9  April  2025,  and  the 
Commission invited Member States to advertise the CfE.  

3.  FEEDBACK 

3.1.  Respondent profile 

A total of 215 stakeholders submitted their feedback in response to the CfE. 67 respondents 
submitted feedback in the form of attached documents. Respondents were asked to identify 
as  one  of  the  following  categories:  EU  citizen,  NGO  (non-governmental  organisation), 
environmental  organisation,  business  association,  public  authority,  company/business, 
academic/research  institution,  trade  union,  or  other.  138  identified  as  EU  citizens,  23 
identified as NGO, 21 identified as company/business, 11 identified as public authority, 8 
as  business  association,  6  as  environmental  organisations,  3  as  academic/research 
institution,  1  as  trade  union,  and  4  as  other.  Figure  44  illustrates  the  distribution  of 
respondents. 

(318)   Disclaimer:  This  Annex  should  be  regarded  solely  as  a  summary  of  the  contributions  made  by 
stakeholders during the Call for Evidence. It cannot in any circumstances be regarded as the official 
position  of  the  Commission  or  its  services.  Responses  to  the  consultation  activities  cannot  be 
considered as a representative sample of the views of the EU population. 

(319)   COM(2025) 45 final, Commission work programme 2025 - European Commission 

(320)   COM(2025)  79  final, Action Plan  for Affordable  Energy: Unlocking  the  true  value  of our  Energy 

Union to secure affordable, efficient and clean energy for all Europeans - European Commission 

139 

 
 
Figure 44 – Distribution of all received responses by respondent category 

Source: PINC CfE. 

Figure 45 summarises the distribution of feedback by country of origin. A significant share 
of responses (105 out of 215) came from EU citizens located in Italy. 

Figure 45 – Distribution of all received responses by respondent country of origin 

Source: PINC CfE. 

3.2. 

Feedback content 

This section provides an overview of the contributions received in response to the CfE. It 
groups respondents’ feedback by topic.  

Outlook  on  nuclear  energy:  The  views  expressed  and  evidence  presented  in  the  CfE 
reflect a wide range of viewpoints. Many argued that nuclear energy plays a critical role in 
achieving  the  EU’s  climate  and  energy  security  goals  while  others  called  for  all  EU 

140 

020406080100120140160Number of respondents020406080100120Number of respondents 
 
 
Member States to phase out nuclear energy and to focus on renewables. In general, nuclear 
the  EU’s  electricity  supply, 
energy  was  seen  as  contributing  significantly 
decarbonisation, economic growth and competitiveness but facing challenges such as high 
construction  and  capital  costs,  concerns  about  safety  and  waste  management,  and 
regulatory  and  public  acceptance  barriers.  Most  respondents  shared  the  need  for  a 
transition to low-carbon energy sources and to minimise dependency on fossil fuels. 

to 

Respondents raised the age of the existing fleet of nuclear power plants and the potential 
for lifetime extensions and new-build projects, the latter of which have often faced delays 
and cost overruns. They discussed the associated operational and capital expenditures, and 
the  levelised  cost  of  electricity  from  nuclear  plants  and  other  generation  technologies. 
Respondents also commented on the role of nuclear energy in the wider electricity system, 
their 
the  distinction  between 
complementarity, the need for flexibility between energy sources, the overall integration 
of  the  energy  system,  i.e.  requirements  for  other  infrastructure  such  as  networks  and 
storages, and the total system costs.  

intermittent  generation  sources  and 

firm  and 

Non-power  uses  of  nuclear  energy:  Respondents  brought  up  several  uses  of  nuclear 
energy besides electricity generation, including the production of medical radioisotopes, 
heat supply, propulsion systems, and water desalination.  

Supply chain: Respondents presented evidence on several aspects of the nuclear supply 
chain,  pertaining  to  the  fuel  cycle,  to  lifetime  extensions,  potential  new  build,  and  to 
decommissioning and the safe management of radioactive waste and spent fuel. Regarding 
the  supply  chain  for  nuclear  fuel,  respondents  addressed  mining  and  uranium  supply 
(including  health  and  environmental  aspects),  conversion,  enrichment,  fuel  fabrication, 
reprocessing,  the fuel  needs  of SMRs and AMRs, and nuclear fuel  prices. Respondents 
also commented on the availability and geographic distribution of uranium sources, the 
resulting implications for EU’s strategic autonomy, and the need to avoid dependence on 
any single or unreliable suppliers, such as Russia. Regarding the supply chain for nuclear 
installations,  respondents  discussed  the  experiences  with  recent  new-build  projects, 
pointed  at  potential  bottlenecks  in  the  EU  supply  chain  that,  if  left  unaddressed,  might 
challenge  Member  States’  plans.  Respondents  also  raised  the  question  how  the  supply 
chain needs to evolve to facilitate the rollout of SMRs. It was furthermore suggested to 
learn  from  other  countries  where  new-build  projects  have  been  realised  without  major 
delays.  On  decommissioning  and  the  management  of  radioactive  waste  and  spent  fuel 
(“back-end”),  respondents  highlighted  the  need  for  long-term  solutions,  appropriate 
management of back-end funds, and addressing the issue of insurance coverage for nuclear 
liability risks.  

Innovative nuclear technologies: Respondents presented evidence on several innovative 
nuclear energy technologies, including SMRs, AMRs, and fusion energy. They discussed 
the  potential  to  roll  out  of  SMRs  in  the  EU,  recent  developments  around  demand  for 
electricity arising from data centres, as well as remaining challenges relating to licencing, 
fuel supply, safety, and radioactive waste and spent fuel potentially emanating from SMRs. 
In the context of fusion energy, respondents discussed the technology’s potential to supply 
clean  energy,  its  path  to  commercialisation,  recent  initiatives  by  startups,  and  whether 
fusion energy needs a separate regulatory framework besides the one existing for fission 
energy. 

141 

 
Cross-cutting  topics:  Respondents  raised  the  importance  of  strong  and  independent 
regulatory oversight to ensure the highest levels of safety and also hinted at potential for 
further evolution of the existing regulatory framework. Proposals were made to streamline 
legal  frameworks  and  to  harmonise  licensing  procedures  in  order  to  reduce  delays  and 
costs,  and  to  simplify  state  aid  processes.  Respondents  stressed  the  importance  of 
transparency relating to nuclear energy matters, and the need for public participation in 
key decision-making processes, e.g. siting decisions for nuclear installations. Respondents 
raised the need to invest in the workforce, and to strengthen EU’s international cooperation 
in  the  nuclear  field.  Some  respondents  also  raised  interlinkages  between  civilian  and 
military uses of nuclear technologies, perceiving this as problematic. 

Financing: Respondents brought  up the significant  investments  required to  use nuclear 
energy and discussed options to finance these investments from public or private funds, 
also citing experience in other jurisdictions, e.g. the UK. Several respondents called for 
technology neutrality and for including nuclear energy in EU funding instruments from 
which it is currently excluded. Some suggested establishing a dedicated instrument for the 
funding  of  nuclear  projects  or  the  creation  of  an  IPCEI  (Important  Project  of  Common 
European  Interest). Respondents  also  raised the topic of financing  SMRs and sufficient 
funding for the nuclear back-end (waste management and decommissioning). 

142