COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Interim Progress Report on the implementation of Council Directive 2024/1265/EU of 29 April 2024 amending Council Directive 2011/85/EU on requirements for budgetary frameworks of the Member States
Date: 2025-06-30
Institutions: Directorate-General for Economic and Financial Affairs, European Commission
Subjects: EU Member State, budget deficit, budget estimate, budget policy, fiscal policy, national budget, national implementing measure, national planning, stability pact

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.6.2025  SWD(2025) 161 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Interim Progress Report on the implementation of Council Directive 2024/1265/EU of 29 April 2024 amending Council Directive 2011/85/EU on requirements for budgetary frameworks of the Member States {COM(2025) 317 final}  
 
 
COMMISSION STAFF WORKING DOCUMENT 
Accompanying the document 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

Interim Progress Report on the implementation of Council Directive 2024/1265/EU of 
29 April 2024 amending Council Directive 2011/85/EU on requirements for budgetary 
frameworks of the Member States 

1 

 
 
This  Working  Document  accompanying  the  Commission  Interim  Progress  Report  provides 
detailed  country  fiches  on  existing  national  measures,  envisaged  steps  or  plans  for  the 
implementation  of  Council  Directive  2024/1265/EU  of  29  April  2024  amending  Council 
Directive  2011/85/EU.  In  accordance  with  Article  2(5)  of  the  Directive  2024/1265/EU, 
Member States have been asked to contribute to the preparation of the document by providing 
answers  to  a  questionnaire  distributed  on  4  March  2025  to  the  Economic  and  Financial 
Committee (Alternates). The questionnaire focused on: 

(i) 

(ii) 

(iii) 

(iv) 

(v) 

amendments  to  the  statistical,  public  accounting  and  transparency  requirements, 
regarding  new  requirements  for  quarterly  data  reporting  or  accrual  accounting 
systems and transparency on bodies or funds outside general government; 
the requirements for independent fiscal institutions (IFIs), regarding independence 
safeguards and tasks for IFIs as well as a comply-or-explain principle for authorities 
relating to IFI assessments 
amendments  to  the  requirements  for  medium-term  budgetary  frameworks, 
regarding  new  elements  of  the  frameworks  (describing  planned  reforms  and 
investments and the impact of policies on sustainable and inclusive growth) as well 
as some clarifications; 
requirements  introduced  in  relation  to  disaster-  and  climate-related  fiscal  risks, 
regarding new reporting requirements on macro-fiscal risks from climate change, 
related contingent liabilities and incurred fiscal costs 
clarification  amendments,  clarifying  and  updating  some  language  and  legal 
references. 

Whenever possible, the layout of the country fiches follows the above structure. As Member 
States delivered their contributions in April 20251, the information contained in the country 
fiches reflects the state-of-play in national transposition efforts at the time. Unless explicitly 
stated otherwise, Article numbers in this Working Document refer to the amended Directive 
2011/85/EU. 

1 

6 Member States have reported in May. 

2 

 
 
 
 
 
1 

Implementation of the main provisions of the Directive in BELGIUM 

The  interministerial  conference  on  Finance  and  the  Budget  decided  on  25  March  2024  to 
establish  an  administrative  inter-federal  working  group,  tasked  with  identifying  the 
adjustments needed to align Belgium’s regulatory framework with the revised EU economic 
governance  framework,  and  to  develop  proposals  to  adapt  the  regulatory  framework 
accordingly.  This  working  group  brings  together  administrations  and  departments  from  the 
federal government as well as the governments of the Communities and the Regions and is 
coordinated  by  the  Federal  Public  Service  Policy  and  Support  (FPS  BOSA),  with  the  final 
report to be delivered in May 2025. 

The Belgian authorities note that work on transposing the Directive was delayed due to the 
timeline of the federal government formation following the 2024 elections.  

The authorities emphasise that the legislative changes proposed are still preliminary - they may 
be subject to amendments and will require political review and approval. The authorities also 
note that proposed amendments to the Law of 16 May 2003 would require the Communities 
and  the  Regions  to  amend  the  decrees  organising  their  respective  budgets.  While  the 
information reported identifies the texts and articles that are likely to be amended, it does not 
include details on the proposed changes or a specific transposition timeline. 

1. Statistics, accounting, transparency 

The Belgian authorities report that they intend to amend the following national legislations in 
order to comply with the revised provisions of Article 3 of the Directive: 

•  Article 124/1 of the Law of 22 May 2003 on the organisation of the Federal budget and 

accounts (“Law of 22 May 2003”). 

•  Article 16/10 of the Law of 16 May 2003 laying down the general provisions governing 
the budgets,  control  of subsidies and accounting  of the communities and  regions, as 
well as the organisation of the audit by the Court of Audit (“Law of 16 May 2003”). 
•  The Cooperation Agreement of 13 December 2013 between the Federal Government, 
the  Communities,  the  Regions  and  the  Community  Commissions  regarding  the 
transposition of Article 3(1) of the Treaty on Stability, Coordination and Governance in 
the  Economic  and  Monetary  Union  may  also  be  amended  (“2013  Cooperation 

Agreement”). 

The Belgian authorities report that they intend to amend the following national legislations in 
order to comply with the revised provisions of Article 14(1) of the Directive: 
•  Article 124/3, 5e and Article 124/5 of the Law of 22 May 2003. 
•  Article 16/12, 5e and Article 16/14 of the Law of 16 May 2003. 
•  The Royal Decree of 23 May 2018 on the High Council of Finance. 

2. Independent fiscal institutions 

The Belgian authorities report that no changes are required in the national legislation to comply 
with amendments to Article 2 of the Directive. 

The Belgian authorities report that they intend to amend the following national legislations in 
order to comply with the revised provisions of Article 8a of the Directive: 

•  The 2013 Cooperation Agreement. 
•  The Law of 21 December 1994 on social and various measures. 

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3. Medium-term budgetary frameworks 

The Belgian authorities report that they intend to amend the following national legislations in 
order to comply with the revised provisions of Article 9 of the Directive: 

•  Article 16/12 of the Law of 16 May 2003. 
•  Article 124/3 of the Law of 22 May 2003. 

The  Belgian  authorities  highlight  that  no  changes  are  required  in  the  national  legislation  to 
comply with amendments to Article 10 and 11 of the Directive. 

4. Reporting on disaster- and climate-related fiscal risks 

The Belgian authorities report that they intend to amend the following national legislations in 
order to comply with the revised provisions of Article 9(2)(d) of the Directive: 

•  Article 124/3 of the Law of 22 May 2003. 
•  Article 16/12 of the Law of 16 May 2003. 

The Belgian authorities report that they intend to amend the following national legislations in 
order to comply with the revised provisions of Article 14(3) of the Directive: 
•  Article 124/3, 5e and Article 124/5 of the Law of 22 May 2003. 
•  Article 16/12, 5e and Article 16/14 of the Law of 16 May 2003. 

5. Clarification amendments 

The Belgian authorities report that no changes are required in the national legislation to comply 
with Article 2 of the Directive. 

The Belgian authorities report that they intend to amend the following national legislations in 
order to comply with the revised provisions of Article 3 of the Directive: 

•  Article 124/1 of the Law of 22 May 2003. 
•  Article 16/10 of the Law of 16 May 2003. 
•  The 2013 Cooperation Agreement may also be amended. 

The Belgian authorities report that they intend to amend the following national legislations in 
order to comply with the revised provisions of Article 4 of the Directive: 
•  Article 124/2 and Article 124/5 of the Law of 22 May 2003. 
•  Article 16/9 and Article 16/11 of the Law of 16 May 2003. 
•  Article 108(g) of the Law of 21 December 1994 on social and various measures. 

Modifications needed to comply with Article 5, Article 6 and Article 7 of the Directive will be 
set out in the revised 2013 Cooperation Agreement. 

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2 

Implementation of the main provisions of the Directive in BULGARIA 

The fiscal framework in Bulgaria is regulated by two legal acts: the Public Finance Act of 15 
February 2013, as amended, and the Fiscal  Council and Automatic Correction  Mechanisms 
Act of 21 April 2015, as amended. Both these acts are planned to be revised to align them with 
changes to Directive 2011/85/EU. Two dedicated working groups have been set-up in relation 
to each of the two legal documents and they are planned to deliver the draft amending laws by 
end 2025. A Council of Ministers’ Decision has already introduced several amendments to the 
second stage of the budget procedure for 2025 to extend the time horizon of the budget forecast 
for a period of four years and include the national medium-term fiscal structural plan for the 
period 2025-2028 among budget documents. 

1. Statistics, accounting, transparency 

The  authorities  report  that  existing  provisions  of  the  Public  Finance  Act  cover  relevant 
Directive 2011/85/EU provisions, and any further necessary alignment with Article 14(1) will 
be reflected in the planned amendments of the Public Finance Act.  

Regarding Article 3(2), the authorities report that the Bulgarian National Statistical Institute 
publishes monthly and quarterly fiscal data, while quarterly data on the consolidated general 
government debt is published on the Ministry of Finance website. Regarding Article 14(1), the 
authorities report that the Bulgarian National Statistical Institute publishes the required data on 
units reclassified as part of the general government twice a year, while the fiscal impact on 
general government debt and deficit thereof is already included in the medium-term budgetary 
forecast document. 

2. Independent fiscal institutions 

The  Fiscal  Council  and  Automatic  Correction  Mechanisms  Act  regulates  the  set-up  of  the 
existing Bulgarian Fiscal Council, which covers some of the amended Directive 2011/85/EU 
provisions  for  independent  fiscal  institutions.  Any  further  legal  alignment  with  the  relevant 
provisions of the amended Directive is planned to be discussed by the dedicated working group 
within the Ministry of Finance. No granular information on how Article 8 will be transposed 
is provided. 

3. Medium-term budgetary frameworks 

Regarding  the  medium-term  budgetary  framework  (Article  9  of  Directive  2011/85/EU), 
planned  amendments  to  the  Public  Finance  Act  to  align  the  medium-term  budget  forecast 
(which is  the main medium-term  budget  document) with  changes to  the  directive are being 
discussed and include: 

•  an extension of the planning horizon from three to four years; 
• 

information on planned medium-term policies, including reforms and investments, 
with an impact on the general government, broken down by main revenue and 
expenditure items; 

•  how  adjustments  to  the  national  budgetary  targets  are  achieved  in  the  medium  term 

compared to projections under unchanged policies; 

•  an  assessment  of  the  ways  in  which  the  envisaged  policies  are  likely  to  affect  the 
medium- and long-term sustainability of public finances and sustainable and inclusive 
growth,  considering  their  direct  medium-  and  long-term  impact  on  the  general 
government; 

5 

 
 
Possible alignment with Articles 2, 10 and 11 of Directive 2011/85/EU will also be considered 
in the law amending the Public Finance Act.  

4. Reporting on disaster- and climate-related fiscal risks 

Discussions  are  under  way  regarding  amendments  to  the  Public  Finance  Act  to  transpose 
Articles 9(2)(d) and 14(3) of Directive 2011/85/EU, while recognising the difficulties related 
to uncertainties in methodology and standards.  

5. Clarification amendments 

It is reported that work to align the Public Finance Act with Articles 2, 3, 4, 5, 6 and 7 of the 
Directive  is  currently  underway.  Regarding  national  fiscal  rules  (Article  5  of  Directive 
2011/85/EU), the authorities highlight that a streamlining of the numerical national fiscal rules 
(expenditure,  deficit  and  debt  according  to  the  national  methodology  -  consolidated  fiscal 
program, cash basis) is under consideration in the ongoing work on  the Public Finance Act. 

6 

 
 
 
 
3 

Implementation of the main provisions of the Directive in CZECHIA 

Czechia’s fiscal framework was established by the Act on Budgetary Responsibility Rules of 
2017, amended on several occasions since then. The Czech authorities indicate their intention 
to  revise  the  Act  on  Budgetary  Responsibility  Rules  after  the  election  for  the  Chamber  of 
Deputies  planned  for  the  end  of  2025  with  the  aim  to  transpose  the  amendments  and 
clarifications  of  Directive  2011/85/EU  and  reflect  the  new  EU  economic  governance 
framework.  However,  the  information  provided  by  the  Czech  authorities  indicates  that  the 
process is in its early stages in April 2025 as the exact scope of changes and precise timeline 
of the transposition are yet to be determined. 

1. Statistics, accounting, transparency 

The Czech authorities report three different initiatives in relation to the Directive amendments 
of statistical and public accounting provisions: (i) the Public Finance Governing and Control 
Bill covering the general government sector except state enterprises and business corporations 
which should enter into force from 2027, (ii) a draft law for a new accounting system covering 
the  general  government  sector  except  for  business  corporations,  school  legal  entities  and 
private  law  ones,  which  should  take  effect  from  2027  and  (iii)  the  Act  on  State  Statistical 
Service  on  the  publication  of  quarterly  data  on  the  general  government  deficit  and  debt  (in 
force). 

Regarding  the  Directive  amendments  to  the  transparency  provision,  the  Czech  authorities 
indicate  that  a  draft  law  amending  the  Act  on  Budgetary  Responsibility  Rules  includes 
provisions to publish the relevant information during the preparation of the State budget draft 
law. The draft law is planned for adoption in 2026 after the Chamber of Deputies elections.  

The Czech authorities indicate that work is ongoing on draft documents for the transposition 
of the amendments to the statistical, public accounting and transparency requirements of the 
Directive. No details are provided on the state of play of the draft law and their application is 
planned as of 2026 or after. 

2. Independent fiscal institutions 

The Czech Fiscal Council and the Committee on Budgetary Forecasts have been established 
by  the  Act  on  Budgetary  Responsibility  Rules  (the  Act)  adopted  on  17  January  2017.  The 
Czech  authorities  indicate  that  the  Act  covers  the  requirements  for  the  nomination  and 
appointment of the members of the independent fiscal institutions outlined in Article 8a(3) of 
the Directive, the independence safeguards set in Article 8a(4)(a)-(d) and the tasks included in 
Article 8a(5)(a)-(b) to independently produce, assess or endorse the annual and multiannual 
macroeconomic  forecasts  and  to  monitor  compliance  with  country-specific  numerical  fiscal 
rules. Finally, the authorities indicate that the planned amendments to the Act aim to transpose 
the  provisions  of  Article  8a(4)(e),  Article  8a(5)(c)-(e)  and  partly  Article  8a(6),  with  an 
application of the new provisions in 2026, after the elections for the Chamber of Deputies. 

3. Medium-term budgetary frameworks 

The features of the Czech budget strategy, which is the medium-term budgetary framework 
currently in force, have been established by the Act on Budgetary Responsibility Rues of 2017. 
The Czech authorities  report on their  plans to  amend the Act  to  include provisions that the 
Ministry of Finance publishes the national medium-term fiscal structural plan and the annual 
progress report prepared in accordance with Regulation 2024/1263, together with projections 

7 

 
 
of the main macroeconomic aggregates and of the main expenditure and revenue items for the 
general  government  including  at  unchanged  policies.  According  to  the  authorities,  these 
amendments would enter into force in 2026 after the elections for the Chamber of Deputies. 

The amendments of Article 10 of the Directive would be covered according to the authorities 
by the amendments to the Act planned to enter into force in 2026. The Czech authorities plan 
to  replace  the  structural  budget  balance  with  the  net  expenditure  path,  also  including  the 
national escape clauses. 

The authorities do not plan any additional changes to the national legal provisions to transpose 
Article 11 of the Directive as they report that the planned draft law and the direct application 
of Regulation 2024/1263 Article 15(2) and Article 15(6) would be compatible. 

4. Reporting on disaster- and climate-related fiscal risks 

The Czech authorities indicate their intention to amend the Act on Budgetary Responsibility 
Rules to include a requirement for the Ministry of Finance to publish, to the extent possible, 
relevant information on disaster and climate-related fiscal risks in the national medium-term 
fiscal structural plan and annual progress report and on disaster and climate-related contingent 
liabilities and on fiscal costs incurred due to disasters and climate-related shocks at least once 
per year. The authorities plan to amend the Act on Collection of Laws and International Treaties 
to  transpose  the  Directive  provision  regarding  distributional  impacts.  These  changes  are 
planned to take effect in 2026, but this depends on the results of the elections for the Chamber 
of Deputies.  

5. Clarification amendments 

The Czech authorities outline other changes aimed to address the clarifications brought to the 
provisions of Directive 2011/85  and beyond. For instance, the authorities intend to task the 
Committee on Budgetary Forecasts instead of the Ministry of Finance to perform the ex-post 
evaluation  of  macroeconomic  and  budgetary  forecasts  from  2026  onwards.  Moreover,  the 
Czech fiscal framework is planned to mirror the EU framework and thus be centred on the net 
expenditure  path  instead  of  the  structural  balance  and  planned  changes  aim  to  ensure 
consistency of the medium-term fiscal planning horizon with Regulation 2024/1263, that the 
annual budget is consistent with the fiscal rules in force and to clarify the definition of escape 
clauses. 

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4 

Implementation of the main provisions of the Directive in DENMARK 

The Danish Ministry of Economic Affairs reports that Denmark is currently examining to what 
extent  further  measures  are  needed  to  meet  all  requirements  of  the  Council  Directive 
2024/1265/EU,  especially  in  regards  to  the  new  IFI  tasks.  In  the  authorities’  view,  many 
requirements are already covered by the existing Danish legislation or practices. 

1. Statistics, accounting, transparency 

The  Danish  Ministry  of  Economic  Affairs  reports  that  Statistics  Denmark  will  henceforth 
publish quarterly data on public debt for sub-sectors of general government in line with Article 
3(2) of the Council Directive 2024/1265/EU Amending the Council Directive 2011/85/EU on 
Budgetary  Frameworks.  The  Danish  authorities  estimate  that  Denmark  has  integrated, 
comprehensive and nationally harmonized accrual financial accounting systems in place. 

As regards article 14(1), a multiannual overview is planned to be a part of the annual medium 
term projections (in August 2025). 

2. Independent fiscal institutions 

The Danish Ministry of Economic Affairs assesses that measures are already in place to meet 
overall requirements for independent fiscal institutions. The Danish Economic Councils (DEC) 
are established by an ordinary law, namely the DEC Act (Lov om det økonomiske råd). The 
Danish Ministry of Economic Affairs is currently examining to what extent further measures 
are needed to meet all requirements of the Council Directive 2024/1265/EU.  

The DEC Act details the principles for the appointment of new members of the chairmanship 
on the DEC website, including in relation to independence and professional competence, in 
accordance with Article 8a(3). The chairmanship’s responsibility for DEC reports is enshrined 
in law: the Chair chooses the topics of individual reports and proposes adjustments to economic 
policy. S/he is bound to working “objectively, neutrally, and entirely independently and must 
not  represent  or  convey  the  views  of  any  other  stakeholders”,  but  only  the  Director  of  the 
Secretariat of the DEC is formally prohibited from being a member of the Danish Parliament 
and must be independent of business enterprises, employers' and employees' organizations, as 
well as environmental organizations. It is specified at www.dors.dk that the secretariat serves 
only the chairmanship of the Economic Councils and has no duties related to any ministry or 
minister. 

The  funding  of  the  secretariat  is  guaranteed  by  the  Danish  Finance  Act  Section  10.11.09. 
Regarding access to information, Section 31 of the Danish Public Administration Act, states 
that “to the extent that an administrative authority is entitled to disclose information, it must, 
upon request from another authority, share the information if it is relevant to the requesting 
authority’s function”. This principle applies to the DEC. Furthermore, the legislative comments 
to the 2011 amendment (LF 167 2011/1) state that “to carry out its work, the [DEC] secretariat 
will have access to the resources and data necessary to perform the task”. 

There is no explicit provision in the current legislation for the DEC to be subject to regular 
external evaluations by independent evaluators, but the structure of the DEC allows to gather 
biannual feedback on the chairman’s activity. Moreover, the DEC was thoroughly reviewed by 
the European Fiscal Board in 2024. The Danish Ministry of Economic Affairs indicates that a 
future legal amendment could more explicitly mandate regular external evaluations if deemed 
necessary.  

9 

 
 
Regarding  IFI  tasks,  the  DEC  currently  prepares  macroeconomic  forecasts  with  which  it 
assesses the government forecasts as stipulated by the DEC Act. Differences must be explained 
publicly by the Ministry of Finance but are maintained to reflect differing views on economic 
assessments  and  policy  needs.  Additionally,  the  DEC  monitors  compliance  with  country-
specific  numerical  fiscal  rules,  assesses  the  consistency,  coherence  and  effectiveness  of  the 
national  budgetary  framework  and  participates  in  Parliament  hearings  and  discussions. 
However, these three practices are not enshrined in law. Finally, tasks related to Article 8a(5)(c) 
have not yet been implemented and there is no timeline for their implementation. 

While the Ministry of Finance and the Ministry of Economic Affairs submit comments on the 
chairmanship’s assessments which are publicly available on the DEC website along with the 
latter’s opinion, the Ministry of Economic Affairs assesses that the legal requirement of the 
DEC act for the Comply or Explain principle (Section 3a) still is too narrow for the directive’s 
requirements.  

3. Medium-term budgetary frameworks 

The  Danish  Ministry  of  Economic  Affairs  considers  that  measures  are  already  in  place 
regarding the MTBF requirements of the Directive 2024/1265/EU. 

Governments'  economic  policies  in  general  are  outlined  in  medium-term  plans,  typically 
covering a time horizon of 5 to 9 years. In these medium-term plans, revenues and expenditures 
are projected based on the government's policies complying with the fiscal framework of the 
Budget Law. 

4. Reporting on disaster- and climate-related fiscal risks 

The Danish Ministry of Economic Affairs does not give indications on specific legal steps to 
transpose the amendments to Article 9(2)(d) and Article 14(3) of the Directive into national 
law.  

Denmark  considers  the  macro  fiscal  risks  from  climate  mitigation,  but  this  practice  is  not 
enshrined in law. Fiscal policy risks are continuously analysed in connection with the medium-
term  projections  and  medium-term  plans.  For  example,  the  implications  for  revenue  from 
energy taxes were analysed in the government’s 2030 plan from November 2023. Additionally, 
the Danish Council on Climate Change is an independent body of experts that advises on how 
the  transition  to  a  low-carbon  society  can  be  done  in  a  cost-effective  manner.  The  Danish 
Ministry of Economic Affairs also reports that Danish risk assessments cover the negative and 
positive impact of many risks. In general, fiscal policy in Denmark is planned with a running 
room for manoeuvrability in case of negative shocks. 

5. Clarification amendments 

The Danish Ministry of Economic Affairs assesses that amendments to Articles 2, 3, 4, 5, 6 
and 7 are already addressed by existing legislation.  

10 

 
 
 
 
5 

Implementation of the main provisions of the Directive in GERMANY 

Germany reports the state of play with regard to the transposition of the amended Directive, 
albeit not always article by article. 

1. Statistics, accounting, transparency 

As concerns Article 3(1), Germany  considers that  the legal  basis for data collection for the 
determination of data to be transmitted in the EU budget procedure is the Finance and Personnel 
Statistics Act (FPStatG). It also reports that the European System of National Accounts (ESA, 
Regulation (EU) 549/2013) is referenced both in the legal text (e.g. in paragraphs 2, 3, 5, 9a, 
12) and in the respective explanations of the last two amendments to the law. 

As concerns Article 3(2), Germany considers that the data to be published according to the 
amendments are already partially released in Germany (Monthly Report of the Bundesbank, 
Statistical Section). It also reports that the future quarterly publication of deficit data by level 
has been initiated at the Federal Statistical Office and is planned to be implemented by the end 
of the year.  

As concerns Article 14(1), Germany reports that the Federal Statistical Office identifies and 
classifies  bodies  and  funds  that  do  not  form  part  of  the  regular  budgets  but  are  part  of  the 
general government based on section 2(3) of the FPStatG. It also reports that, since December 
2013, a list of all governmental funds, institutions, and enterprises has been published based 
on  the  FPStatG.  The  Stability  Council  advises,  in  accordance  with  section  51(1)  of  the 
Budgetary Principles Act (Haushaltsgrundsätzegesetz, HGrG), twice a year on the overall and 
macroeconomic and fiscal conditions for the preparation of the budgetary and financial plans 
for the federal government, states and municipalities. To this end, according to section 52(1) 
of the HGrG, the federal government and the states, through their finance ministries, provide 
the Stability Council with the information it needs to fulfil its tasks. The published Stability 
Council  decision  documents  include  the  impacts  of  the  aforementioned  governmental 
institutions and funds on the budget balances and the debt levels of the federal government, the 
states and municipalities. 

2. Independent fiscal institutions 

Germany reports that Section 8 of the Stability Council Act (StabRatG) sets the framework for 
the  Independent  Advisory  Board  of  the  Stability  Council  (the  Advisory  Board)  and  that  its 
mandate  is  defined  in  Section  1  of  its  Rules  of  Procedure,  which  also  enshrines  its 
independence (in connection with section 2 of the Rules of Procedure). It also reports that the 
Advisory Board fulfils only part of the tasks for IFIs mentioned in Article 8a of the Directive. 
Germany  mentions  that  the  necessary  changes  to  align  the  regulations  with  the  reformed 
Stability and Growth Pact (SGP) are in preparation. As the government only recently came into 
office, it is not yet in a position to specify what changes are being considered.  

Germany  reports  that  the  Joint  Economic  Forecast  (JEF)  is  established  as  an  independent 
institution  via  the  Act  and  Regulation  on  the  Preparation  of  the  Federal  Government's 
Macroeconomic Forecasts (EgVG and EgVV) and that, according to Sections 1 and 2 of the 
EgVV, JEF’s task is to endorse the federal government's macroeconomic forecast. 

Regarding the comply-or-explain principle in Article 8a(6) of the Directive, Germany reports 
that the regulations establishing these two institutions also specify this principle (Section 2 of 
EgVV and Section 7(a)(6) of the Stability Council Rules of Procedure). Germany also reports 

11 

 
 
that  the  requirement  for  the  Advisory  Board  to  undergo  regular  external  evaluations  in 
accordance with Article 8a(4)(e) of the Directive is also considered to be addressed in these 
regulations. The corresponding external evaluations of the JEF research institutes are reported 
to be provided by the Leibniz Senate. 

3. Medium-term budgetary frameworks 

Germany reports that the requirements for the medium-term budgetary framework are set out 
in particular in section 9(4) of the Rules of Procedure of the Stability Council. 

4. Reporting on disaster- and climate-related fiscal risks 

Germany reports that, since July 2024, the Federal Climate Adaptation Act (KAnG), which 
regulates the corresponding reporting requirements, has been in force in Germany, referring in 
particular to Section 4 of this Act. 

5. Clarification amendments 

Germany considers that the clarifications do not require any legislative measures. 

12 

 
 
 
 
6 

Implementation of the main provisions of the Directive in ESTONIA 

Estonia’s fiscal framework was established through the State Budget Act that has been in place 
since 2014 and amended on several occasions, most recently in 2024. The authorities indicate 
their intention to revise the State Budget Act before the end of 2025 in order to transpose the 
new  and  clarified  requirements  of  Directive  2011/85/EU.  However,  the  process  is  still  at 
preparatory stages with the scope of changes yet to be determined. 

1. Statistics, accounting, transparency 

According to the assessment by the authorities, the State Budget Act already covers most of 
the  new  and  clarified  requirements.  The  autorities  do  not  provide  detailed  information  on 
specific requirements. 

2. Independent fiscal institutions 

Estonia’s Fiscal Council is an advisory body that monitors Estonia’s compliance with national 
fiscal  rules,  assesses  the  macroeconomic  and  budgetary  forecasts  underpinning  the  state 
budget, and engages in the public debate on budgetary and related matters. The Council was 
established in 2014. 

According  to  information  provided  by  the  authorities,  the  legislative  changes  to  ensure 
compliance with Articles 2 and 8a of the amended Directive 2011/85/EU are planned to be 
completed  by  the  end  of  2025.  However,  the  scope  of  necessary  changes  is  still  being 
determined and no detailed information is therefore provided. 

3. Medium-term budgetary frameworks 

Estonia’s fiscal planning has multi-annual orientation since 2014 and is centred on the State 
Budget  Strategy  document  covering  a  four-year  period.  The  authorities  consider  that  the 
national medium-term budgetary framework needs to be redefined due to changes in Directive 
2011/85/EU, which would lead to changes in the State Budget Act. As indicated above, the 
intention of the authorities is to revise the State Budget Act before the end of 2025. However, 
the scope of necessary changes is still being determined and no detailed information is therefore 
provided. 

4. Reporting on disaster- and climate-related fiscal risks 

As  part  of  the  forthcoming  review  of  Estonia’s  State  Budget  Act,  the  authorities  intend  to 
introduce before the end of 2025 new requirements in relation to reporting on disaster- and 
climate-related fiscal risks. However, no detailed information is provided. 

5. Clarification amendments 

No specific information is provided regarding clarification amendments laid down in Articles 
2, 3, 4, 5, 6 and 7 of Directive 2011/85/EU, given that identification of necessary changes is 
still ongoing. 

13 

 
 
 
 
7 

Implementation of the main provisions of the Directive in IRELAND 

The  Ministry  of  Finance  reported  that  a  new  Statutory  Instrument  (SI)  is  currently  being 
progressed to address those amendments to the Directive 2011/85/EU which the Ministry of 
Finance  assesses  are  not  already  in  place  in  existing  national  legislation.  This  statutory 
instrument  is  a  secondary  piece  of  legislation  signed  by  the  Minister  for  Finance  under  the 
powers given to the Minister by the principal Act of the Oireachtas. 

1. Statistics, accounting, transparency 

The Ministry of Finance reports that legislation is currently being progressed to bring forward 
the amended changes to the statistical, public accounting and transparency requirements of the 
Directive (Articles 3 and 14(1) of Directive 2011/85/EU) through the introduction of the new 
SI  into  domestic  legislation.  The  revised  Directive  includes  requirements  related  to  the 
reporting of annual fiscal data and updates the obligations of General Government bodies to 
publish information on bodies and funds which that do not form part of the regular budgets but 
are part of the general government. This includes sub-sectors of General Government (Article 
14(1)). 

2. Independent fiscal institutions 

The  Ministry  of  Finance  assesses  that  the  existing  Fiscal  Responsibility  Act  2012  already 
covers several of the measures in relation to Articles 2 and 8a of Directive 2011/85/EU. Article 
8 of the Fiscal Responsibility Act outlines all the relevant duties and functions of IFAC (as 
covered  under  Article  8a(4)  of  the  revised  Directive),  from  the  independent  assessments  of 
official forecasts to their timely publications.  

The Ministry of Finance also reports that the Act contains a detailed Schedule that outlines 
inter  alia  membership,  remuneration,  staffing,  funding,  appearances  before  parliamentary 
committees, premises and procedure and quorum for IFAC. The Ministry of Finance does not 
provide an assessment of the alignment of the provisions of this Schedule with the Directive.  

The SI described above will include the requirement for IFAC to be subject to regular external 
evaluations by independent evaluators, to assess the consistency, coherence and effectiveness 
of the national budgetary framework and will include the comply and explain principle. 

3. Medium-term budgetary frameworks 

The Ministry of Finance reports that the SI will introduce provisions that promote transparency 
and clarification around the Medium-Term Budgetary Framework in line with Articles 2, 9 and 
10 of the Directive. It will re-state the requirement to publish a regularly updated document 
containing all elements of the medium-term budgetary framework.  

The Ministry of Finance will not introduce legislative changes in relation to Article 11 as it 
assesses that no provision of the current legislation under review limit the Government’s ability 
to update the Medium-Term Budgetary Framework. 

4. Reporting on disaster- and climate-related fiscal risks 

The Ministry of Finance reported that the new SI will include a subsection specifically aimed 
at addressing the disaster and climate-related risks associated with Articles 9(2)(d) and 14(3). 
This section outlines the responsibility around contingent liabilities from climate change, and 
the fiscal costs incurred due to disasters and climate-related shocks. It specifies requirements 

14 

 
 
around both the reporting of the fiscal indicators such as the macrofiscal risks from climate 
change  and  its  environmental  and  distributional  impacts.  It  is  important  to  note  that  the 
proposed  text  will  include  the  words  “to  the  extent  possible”  indicating  the  reality  that  a 
framework to assess such risk is progressing but has not been finalised yet. 

5. Clarification amendments 

The Ministry of Finance reports that the new SI will address the clarification amendments laid 
down in Articles 2, 3, 4, 5 and 6 of Directive 2011/85/EU.  

It assesses that the Medium-Term Budgetary Framework, along with current legislation (Fiscal 
Responsibility Act 2012 and The Ministers and Secretaries (Amendment) Act 2013), already 
provides  requirements  to  monitor  the  consistency  of  Annual  Budget  legislation  (as  covered 
under Article 7 of the Directive). 

15 

 
 
 
 
8 

Implementation of the main provisions of the Directive in GREECE 

Greece  is  transposing  the  amending  Directive  2024/1265/EU  via  an  amendment  of  Law 
4270/2014, under preparation and to be adopted by July 2025.  

1. Statistics, accounting, transparency 

Regarding transposing Article 3(1) of the Directive relating to public accounting systems, the 
authorities consider no transposition measure to be necessary.  

Regarding transposing Article 3(2) of the Directive relating to public availability of fiscal data, 
the  authorities  report  that  the  amendment  of  Law  4270/2014  will  assign  to  the  Hellenic 
Statistical Authority the responsibility for the timely publication of quarterly deficit and debt 
data for each sub-sector of the general government.  

Regarding  transposing  Article  14(1)  of  the  Directive  relating  to  publishing  information  on 
bodies  and  funds  that  do  not  form  part  of  the  regular  budgets  in  the  context  of  budgetary 
processes, the authorities plan to slightly amend Law 4270/2014, specifically Article 44 on the 
national medium-budgetary framework (MTBF) and Article 53 on the annual budget to align 
wording with the text of the Directive. 

2. Independent fiscal institutions 

Regarding  transposing  Articles  8a(1)  of  the  Directive  relating  to  the  legal  establishment  of 
independent  fiscal  institutions  (IFIs),  8a(3)  relating  to  the  nomination  and  appointment  of 
members to IFIs, and 8a(4)(a) relating to IFIs not taking instructions the authorities consider 
no transposition measure to be necessary. 

Regarding transposing Article 8a(4)(b) of the Directive relating to IFIs public communication, 
the  authorities  consider  the  legal  framework  currently  in  force  to  partially  account  for  the 
provision.  While  authorities  remark  that  there  are  no  restrictions  to  HFISC's  freedom  to 
communicate its work or its views through any means, they are planning to further strengthen 
HFISC’s capacity to communicate publicly about their assessments and opinions in a timely 
manner. The  planned amendments  include provisions on  an  explicit mandate for the timely 
public communication of all actions that HFISC undertakes in the context of its responsibilities 
and  the  establishment  of  a  new  department  -  under  the  HFISC  President  -  which  will  be 
responsible, inter alia, for the communication of HFISC work at the national and international 
level. 

Regarding transposing Article 8a(4)(c) of the Directive relating to the resourcing of IFIs, the 
authorities  consider  no  transposition  measure  to  be  necessary  as  regards  adequate,  stable 
financing, as they consider the legal framework currently in force to already account for the 
provision.  As  regards  human  resource  needs,  transposition  measures  are  foreseen.  On 
financing, Article 13 of Law 4270/2014 states that the budget of the HFISC is prepared by the 
HFISC based on the estimated operational cost and only requires that the budget is aligned with 
standard budgetary principles like annual duration, unity and universality. No other restriction 
is imposed, and the Ministry of Finance is not authorised to amend the draft budget prepared 
by the HFISC or to  ask  the HFISC for an amended draft: Article 54 of Law 4270/2014,  as 
amended by article 34(9) of Law 4484/2017, explicitly exempts the HFISC from the Ministry 
of Finance's authorisation to enter into a dialogue with independent authorities in cases where 
the draft budget submitted by these authorities is not aligned with the targets of the medium-
term budgetary framework or with the instructions that have been provided by the Ministry of 
Finance. The authorities argue that this implies that the draft budget submitted by the HFISC 

16 

 
 
must be accepted, even if it is not in line with the medium-term targets. On human resources, 
the authorities report that the amendment of Law 4270/2017 will include an increase in the 
HFISC’s staff positions compared to what the current legislation foresees, with draft legislation 
providing for a ceiling increase to 26 staff. The ceiling in force provides for 20 staff, with 13 
staff employed as of 18 June 2025. In addition, the new legislation introduces the possibility 
for HFISC to cover part of its special scientific staff positions through three-year contracts that 
can be renewed once. The legislation clarifies that this possibility will exist until the HFISC 
has covered all its staff positions through permanent staff or staff with open-ended contracts. 

Regarding transposing Article 8a(4)(d) of the Directive relating to IFIs’ access to information, 
the authorities are planning to strengthen existing provisions through the amendment of Law 
4270/2014. New provisions will include references to the fact that the provision of information 
must be timely and will streamline the process of information sharing by explicitly providing 
access  to  the  HFISC  to  a  number  of  administrative  databases,  including  to  the  Financial 
Management Information System for the general government, to the Management Information 
System of the revenue administration, to the IT system of the single Pension Fund and to the 
IT system of the Ministry of Labour in which employers submit information on recruitments, 
dismissals and other information related to wage labour. Finally, the new provisions are going 
to expand the authorisation for memoranda of understanding that the HFISC can enter into, 
beyond the Ministry of Finance, to include additional entities like the revenue administration, 
the Public Debt Management Agency, the Hellenic Statistical Authority, the Bank of Greece, 
as well as the single Pension Fund. 

Regarding  transposing  Article  8a(4)(e)  of  the  Directive  relating  to  external  evaluations,  the 
authorities  are  planning  to  strengthen  existing  provisions  through  the  amendment  of  Law 
4270/2014. Independent evaluations foreseen by Article 12(2) will continue to be required on 
a regular basis (every five years) and to be conducted by independent reviewers. 

Regarding  transposing  Article  8a(5)(a)  of  the  Directive  relating  to  tasks  of  the  IFIs,  the 
authorities  are  planning  to  strengthen  existing  provisions  through  the  amendment  of  Law 
4270/2014. It will be clarified that the endorsement of macroeconomic forecasts by the HFISC 
will  apply  to  all  budgetary  planning  documents  (annual  and  multi-annual),  namely  to  the 
national  MTBF, to  medium-term  fiscal structural plans, to  the Draft Budgetary Plan, to  the 
draft  Budget  submitted  to  Parliament  in  late  November,  as  well  as  to  the  preliminary  draft 
Budget that is submitted to Parliament in early October of each year. 

Regarding  transposing  Article  8a(5)(b)  of  the  Directive  relating  to  tasks  of  the  IFIs,  the 
authorities consider no transposition measure to be necessary. 

Regarding  transposing  Article  8a(5)(c)  of  the  Directive  relating  to  tasks  of  the  IFIs,  the 
authorities  report  that  the  amendment  of  Law  4270/2014  will  assign  to  the  HFISC  the 
responsibility of undertaking tasks in accordance with Articles 11, 15(3) and 23 of Regulation 
2024/1263/EU and Article 3(5) of Council Regulation (EC) 1467/97. 

Regarding  transposing  Article  8a(5)(d)  of  the  Directive  relating  to  tasks  of  the  IFIs,  the 
authorities  report  that  the  amendment  of  Law  4270/2014  will  assign  to  the  HFISC  the 
responsibility of performing assessments of the consistency, coherence and effectiveness of the 
national budgetary framework and of publishing its results. 

Regarding  transposing  Article  8a(5)(e)  of  the  Directive  relating  to  tasks  of  the  IFIs,  the 
authorities  are  planning  to  strengthen  existing  provisions  through  the  amendment  of  Law 
4270/2014.  The  scope  of  the  participation  of  the  HFISC’s  President  to  Parliamentary 
discussions will be broadened by deleting a reference in Article 2(6) limiting the scope to the 

17 

 
 
context  of  HFISC  publications.  Additionally,  a  new  provision  will  explicitly  define  the 
participation in Parliamentary hearings and discussions as a responsibility of the HFISC. 

Regarding  transposing  Article  8a(6)  of  the  Directive  relating  to  the  comply-or-explain 
principle, the authorities report that the amendment of Law 4270/2014 will require the Ministry 
of  Finance  to  either  accept  the  assessments  and  opinions  of  the  HFISC  and  take  action  to 
comply with them, or present within two months public explanations of its position. 

Regarding transposing Article 4(6) of the Directive relating to ex post evaluation of forecasts, 
the authorities are planning to strengthen existing provisions through the amendment of Law 
4270/2014,  including  Article  2(5).    The  amendment  will  explicitly  include  the  ex  post 
evaluation of macroeconomic and budgetary forecasts for both annual and multiannual fiscal 
planning under the responsibilities of the HFISC. The HFISC will be responsible for publishing 
the results of these evaluations, which should be duly taken into account in the context of future 
macroeconomic  and  fiscal  projections.  The  new  legislation  will  also  oblige  the  Ministry  fo 
Finance  to  take  measures  if  the  ex  post  evaluation  of  macroeconomic  forecasts  reveals 
significant bias. 

3. Medium-term budgetary frameworks 

Regarding transposing Article 9(2)(a) of the Directive relating to national budgetary objectives 
over the medium term, the authorities report that the amendment of Law 4270/2014 will ensure 
objectives’ consistency by introducing the net expenditure path that is set by the Council as a 
national numerical fiscal rule, as well as by introducing the provision that this net expenditure 
path  will  be  binding  for  both  the  national  MTBF  and  for  annual  budgets.  The  upcoming 
legislation will also maintain national budgetary objectives over the medium-term (Article 43 
of Law 4270/2014, as amended by Article 119 of Law 4964/2022). 

Regarding  transposing  Article  9(2)(c)  of  the  Directive  relating  to  describing  medium-term 
policies,  the  authorities  report  that  the  amendment  of  Law  4270/2014  will  specify  that 
envisaged reforms and investments that have an impact on general government finances and 
on sustainable and inclusive growth are included among the medium-term policies for which 
estimates  of  budgetary  impact  must  be  provided  in  the  context  of  the  national  MTBF.  The 
provision will apply not only to new policy interventions, but also to already enacted policies, 
for which updated estimates of their budgetary impact will have to be provided. 

Regarding transposing Article 10 of the Directive relating to the consistency of annual budget 
legislation with the national budgetary objectives, the authorities report that, with respect to 
national budgetary objectives over the medium-term other than the net expenditure path, the 
upcoming  legislation  will  include  provisions  that  specify  the  need  for  the  provision  of 
explanations in cases where annual budgets depart from these objectives. 

The authorities do not consider the amended Article 11 of the Directive to include any new 
substantial requirement that would have to be transposed into national legislation. 

4. Reporting on disaster- and climate-related fiscal risks 

Regarding transposing Article 9(2)(d) of the Directive relating to assessing envisaged policies 
according  to  their  likely  impact  on  medium-term  and  long-term  sustainability  of  the  public 
finances  and sustainable and inclusive growth, the authorities  report that the amendment  of 
Law 4270/2014 will specify that the documentation submitted as part of the national MTBF 
should include, inter alia, an assessment of the impact of envisaged policies on medium-term 
and long-term fiscal sustainability, as well as on sustainable and inclusive growth and on the 

18 

 
 
distribution of income. In addition, the provision will clarify that this assessment should take 
into  account,  to  the  extent  possible,  macroeconomic  and  fiscal  risks  as  a  result  of  climate 
change  and  its  environmental  impact,  including  information  on  the  methodology  and 
assumptions  used.  Finally,  the  new  provisions  will  include  the  assignment  of  a  new 
responsibility to the Hellenic Fiscal Council, which will analyse the macroeconomic and fiscal 
developments  that  affect  economic  growth  in  relation  to  risks  and  implications  of  climate 
change. 

Regarding transposing Article 14(3) of the Directive relating to publishing relevant information 
on  contingent  liabilities,  the  authorities  report  that  the  amendment  of  Law  4270/2014  will 
explicitly add the impact of climate change and natural disasters to the list of main sources of 
risk for the budgetary projections that have to be assessed and information on which has to be 
reported  in  the  budget  documentation.  Such  sources  of  risk  also  include  standard  forms  of 
contingent liabilities. The new provision will specify that the budget report should describe the 
methodology used for assessing the impact of climate change and natural disasters, as well as 
that information on fiscal costs incurred due to natural disasters should be taken into account. 

5. Clarification amendments 

Regarding  transposing  the  amended  Article  2  of  the  Directive  relating  to  definitions,  the 
authorities  do  not  consider  Article  2(1)(a)  and  2(1)(c)  to  necessitate  any  changes  to  the 
domestic legal framework and plan to address Articles 2(1)(e) and 2(1)(h) with the planned 
amendment of Law 4270/2014. 

Regarding transposing the amended Article 4(1) of the Directive relating to macroeconomic 
and budgetary forecasts, the authorities consider no transposition measure to be necessary. 

Regarding transposing Article 5(b) of the Directive relating  to  establishing  numerical  fiscal 
rules promoting the adoption of a medium-term fiscal planning horizon, the authorities report 
that the amendment of Law 4270/2014 will introduce compliance with the net expenditure path 
set by the Council as a national fiscal rule. 

Regarding  transposing  Article  6(2)  of  the  Directive  relating  to  escape  clauses  to  numerical 
fiscal rules, the authorities report that the amendment of Law 4270/2014 will establish escape 
clauses that will mirror the general escape clause and the national escape clause of Regulation 
2024/1263/EU. 

Regarding transposing Article 7 of the Directive on the consistency of annual budget legislation 
with  numerical  fiscal  rules,  the  authorities  are  planning  to  strengthen  existing  provisions 
through the amendment of Law 4270/2014. Article 34, setting out principles for fiscal planning, 
will  be  amended  to  reflect  the  changes  in  national  fiscal  rules  as  a  result  of  Regulation 
2024/1263/EU,  while  it  will  also  explicitly  state  that  the  general  principles  apply  both  to 
multiannual and to annual budgetary planning. 

19 

 
 
 
 
9 

Implementation of the main provisions of the Directive in SPAIN 

The General Secretariat of the Treasury and International Financing of the Spanish Ministry of 
Economy,  Trade  and  Business  informed  on  the  implementation  of  the  Council  Directive 
Amending the Council Directive on Budgetary Frameworks. For most parts, Spain considers 
that it already fulfils the provisions of the amended Directive. 

1. Statistics, accounting, transparency 

Spain considers that there is no need to change the current Spanish national legislation as it 
already addresses the relevant provisions of the amended Directive. Specifically, Article 125(2) 
of Budgetary Law 47/2003 vests the General Comptroller (IGAE) with the authority to compile 
the  national  accounts  of  the  General  Government  sector,  stipulating  that  this  task  must  be 
executed  in  accordance  with  the  European  System  of  Accounts.  Spain  also  reports  that  it 
already  publishes  quarterly  data  on  debt  and  deficit  for  all  subsectors  separately,  including 
social security funds, as set out by Regulation (EC) No 549/2013. 

2. Independent fiscal institutions 

Spain  considers  that  existing  national  legislation  on  independent  fiscal  institutions  already 
covers all the amendments introduced in the Directive according to the following: 

-  Article 8a(1) is said to be covered by Organic Law 6/2013 on the establishment of the 

Independent Authority for Fiscal Responsibility (AIReF). 

-  Article 8a(3) is said to be covered by Articles 24.1 and 24.2 of the Organic Law and 
was further  reinforced via Royal  Decree 215/2014  approving  the Organic Statute of 
AIReF. 

-  Article 8a(4)(a) is said to be covered by Article 7.1 of the Organic Law. 
-  Article 8a(4)(b) is said to be covered by Article 5.4 of the Organic Law and Articles 

4.4 and 9 of the above-mentioned Royal Decree. 

-  Article 8a(4)(c) is said to be covered by Articles 7.1 and 11.2 of the Organic Law. 
Spain refers to sufficient economic and human resources to perform its duties, 
including through adequate and stable funding. 

-  Article 8a(4)(d) is said to be covered by Article 4.2 of the Organic Law, which 

stipulates that economic-financial information concerning the public administrations 
shall be made available to AIReF. Spain also refers to Ministerial Order 
HAP/1287/2015, which details the information that the Ministry of Finance will make 
permanently available to AIReF, including data from the Central Administration, 
Social Security, Autonomous Communities, and Local Corporations, setting the rules 
for how AIReF gets the financial information it needs to perform its tasks. 

-  Regarding Article 8a(4)(e) Spain does not report any legal provision requiring AIReF 
to undergo regular external evaluations by independent evaluators but refers instead to 
such evaluations taking place in practice.  

-  Article 8a(5)(a) is said to be covered by the above-mentioned Article 14.1 of the 

Organic Law. 

-  Article 8a(5)(b) is said to be covered by Article 17 of the above-mentioned Organic 

Law and by Article 17 of Organic Law 2/2012. 

-  Article 8a(5)(c) is said to be covered by Article 14.1 and 14.2 of the above-mentioned 

Organic Law. 

20 

 
 
-  Article 8a(5)(d) is said to be covered by Article 14.3 of the above-mentioned Organic 

Law. 

-  Article 8a(5)(e) is said to be covered by Article 24.8 of the Organic Law and by 

Article 25(b) of the above-mentioned Royal Decree. 

-  Regarding Article 8a(6) on the comply-or-explain rule, Spain considers it to be 

covered by Article 11.1 (b) of Royal Decree 215/2014. 

3. Medium-term budgetary frameworks 

Spain  considers  that  existing  national  legislation  already  incorporates  the  clarifications 
included in the amendment of article 9 of the Directive and that, therefore, it is not necessary 
to introduce major legal changes except for those needed to include climate-related risks. 

Regarding  Article  9.2(a)  Spain  refers  to  Article  15  and  29.2(a)  of  the  Organic  Law  2/2012 
which  establishes  the  procedure  for  setting  the  medium-term  fiscal  objectives  and  that  the 
medium-term  budgetary  plan  will  cover  at  least  three  years  and  will  include  relevant 
macroeconomic and fiscal variables. 

Regarding Article 9.2(c) Spain refers to Article 29.2 (b) and (d). It also refers to four cross-
cutting reports accompanying the General State Budget that the Spanish government publishes. 
These cross-cutting reports of the Budget highlight the contribution of spending programmes 
to  specific  areas  or  objectives  of  public  interest,  in  whose  achievement  several  budgetary 
policies typically participate: i) Gender Impact  Report; ii) Alignment Report of the General 
State  Budget  with  the  Sustainable  Development  Goals  of  the  2030  Agenda;  iii)  Alignment 
Report of the General State Budget with the Ecological Transition; and iv) Impact Report on 
Childhood, Adolescence, and Family. 

As regards Article 10, Spain considers it to be covered by Article 29.1  and 29.4 of Organic 
Law 2/2012. 

4. Reporting on disaster- and climate-related fiscal risks 

As regards Article 9.2(d) Spain reports that it is currently assessing how best to transpose this 
article of the Directive into national legislation. 

As regards Article 14.3 Spain refers to Articles 14.5(k) and 15.3(e) of Order HAP/2105/2012 
implementing the information supply obligations stipulated in the Organic Law 2/2012. Spain 
also refers to the fact that IGAE reports on the fiscal cost of disasters and climate change. 

5. Clarification amendments 

As regards Article 4.1 on the realism of the annual and multiannual macroeconomic and fiscal 
forecasts, Spain considers that there is no need to change existing legislation as Royal Decree 
337/2018 of May 25 on the requirements applicable to macroeconomic and budgetary forecasts 
already includes several articles and recitals that address the amendments to Article 4.1. 

As regards Article 4.6 on independent ex-post evaluations of forecasts, Spain refers to Article 
8 in  Royal  Decree 337/2018, where it is  stated that the Ministry of Economy  and the State 
Secretary for Budget of the Ministry of Finance at least once a year shall conduct an ex post 
evaluation  of  the  forecasts  of  the  main  macroeconomic  and  budgetary  variables,  analysing 
possible deviations of the forecast from the actual outturn. Spain also considers that the General 
Comptroller (IGAE), an entity that is formally attached to the State Secretary for Budget but 

21 

 
 
enjoys full functional autonomy, is fully competent to undertake the ex-post evaluation referred 
to in Article 4.6 of the Directive. However, Spain does not refer to any legal provision where 
this  evaluation  task  is  officially  conferred  to  IGAE.  It  remains  thus  unclear  how  the 
independent ex-post evaluation of the macroeconomic forecast is ensured. 

As regards Article 5(b) of the Directive, Spain reports that its provisions are already covered 
by Organic Law 2/2012, particularly via Articles 15 and 29.2. These articles ensure that annual 
and medium-term fiscal and debt targets are aligned with EU recommendations on multiannual 
budgetary objectives. Legal provisions in both articles ensure that fiscal stability and public 
debt targets are set both annually and over the medium-term horizon. 

As regards Article 6.1 of the Directive, Spain reports that its provisions are already covered by 
current legislation (in particular Article 17 of Organic Law 2/2012), according to which the 
Spanish Independent Fiscal Institution and IGAE have to publish reports on the compliance 
with  the  fiscal  rules,  including  through  issuing,  if  needed,  recommendations  for  the 
Government.  

As  regards  Article  6.2  of  the  Directive,  Spain  reports  full  alignment  of  current  national 
legislation, which already specifies a limited number of circumstances under which the national 
escape clause can be activated.  

As regards Article 7 of the Directive, Spain reports that the amendment of its provisions does 
not necessitate any changes in Spanish legislation.  

As regards Article 14.1, Spain considers that the provisions are covered by existing legislation, 
namely Organic Law 2/2012, Ministerial Order 2015 and Royal Decree 337/2018. 

22 

 
 
 
 
10 

Implementation of the main provisions of the Directive in FRANCE 

The main elements of the French national fiscal framework are established by the Organic Law 
on Public Finance Laws of 1 August 2001 (the organic law). At the time of the reporting, the 
authorities identify national legislation covering most of the amended directive provisions. The 
authorities  also  indicate  that  some  legal  changes  would  be  needed  to  ensure  the  full 
transposition  of  the  provisions  but  the  process  and  timeline  envisaged  for  the  legislative 
changes have not been communicated. 

1. Statistics, accounting, transparency 

The authorities indicate that the national statistical office (INSEE) has been using ESA2010 
since 2014 and that according to the organic law, accrual accounting is the public accounting 
system.  Moreover, they  explain that the  reference to  national  budgetary  objectives over the 
medium-term is set in the Constitution and the organic law. The authorities do not indicate any 
need to take specific measures to implement the clarification amendments laid down in Article 
14(1) of the directive and provide references to existing legislation. 

With respect to the amended provisions of Article 3(2), the authorities provide links to various 
datasets  considered  to  fulfil  these  requirements  and  point  out  that  the  organic  law  sets  a 
requirement to annex to the draft multiannual programming law a report indicating the annual 
deficit and debt at aggregate and sectoral level. 

2. Independent fiscal institutions 

France’s Haut Conseil des Finances Publiques (HCFP) was established by the organic law. The 
authorities report that HCFP’s mandate is to monitor the government’s compliance with fiscal 
rules, endorse the macroeconomic forecasts that underpin the budget and assess the existence 
or termination of circumstances underpinning the activation of escape clauses, among other 
responsibilities.  

According to the authorities, the procedure to appoint the members of the HCFP is transparent 
and based on relevant  experience and competence and the HCFP does  not  take instructions 
from budgetary authorities or from any other public or private body. According to the organic 
law, the HCFP prepares opinions on a defined list of budgetary laws and makes them public. 
The HCFP cannot issue opinions on other subjects than those defined in law. The access to the 
relevant information is set in the same law. 

Regarding resources of the HCFP, the authorities report that the president of the independent 
body,  also  president  of  the  national  audit  office,  decides  upon  and  manages  the  financial 
resources that the independent body needs in order to accomplish its tasks.  

The  authorities  indicate  that  there  is  currently  no  legal  provision  for  regular  external 
evaluations  of  the  HCFP  performed  by  independent  evaluators.  Until  the  organic  law  is 
amended to refer to the annual progress report (APR) instead of the stability programme, the 
French authorities commit to refer to the HCFP to endorse the macroeconomic forecasts of the 
APR (Article 8a(5)(a)). Moreover, the authorities have pledged to refer to the HCFP to ensure 
that  the  national  medium-term  fiscal  structural  plan  and  the  APR  are  compliant  with  the 
preventive and corrective arm regulations (Article 8a(5)(c)). These commitments are set in the 
Action plan for Public Finances. 

Legislative changes to ensure compliance with the remaining requirements in Article 8a of the 
amended Directive 2011/85/EU are planned without a clear timeline, notably regarding the IFI 
task  to  assess  the  consistency,  coherence  and  effectiveness  of  the  national  budgetary 

23 

 
 
framework, and the IFI tasks ensuing from the preventive and corrective arm regulations. In 
the authorities’ view, the provision for the IFI to participate in regular hearings and discussions 
at the national Parliament upon request would not need to be transposed in national legislation. 

3. Medium-term budgetary frameworks 

The  authorities  consider  that  the  current  provisions  of  the  organic  law  cover  the  relevant 
requirements  of  the  amended  directive.  The  authorities  also  refer  to  the  production  of  the 
national medium-term fiscal structural plan and of the annual progress report, which include 
references to reforms and investments. The authorities make reference to the ministerial letter 
of 17 June 2021 for the analysis of the impact of the envisaged reforms on long-term fiscal 
sustainability. No reference is provided for the impact of the envisaged policies on sustainable 
and inclusive growth.  

In the authorities’ view, the organic law covers the provisions of Article 10, namely to ensure 
consistency of the annual budget with the national budgetary objectives over the medium term 
and to duly explain any departures of the annual budget from the MTBF in force. 

4. Reporting on disaster- and climate-related fiscal risks 

The  authorities  do  not  elaborate  on  their  intentions  to  ensure  the  transposition  of  the  new 
climate-related provisions of the amended directive while the legal references and explanations 
provided explain the process to produce the multiannual revenue and expenditure projections. 

5. Clarification amendments 

Overall, the authorities consider that the provisions laid down in Articles 2, 3, 4, 5, 6 and 7 of 
Directive 2011/85/EU are already covered in the organic law or by practices. 

24 

 
 
 
 
11 

Implementation of the main provisions of the Directive in CROATIA 

 The  Croatian  authorities  report  that  discussions  are  ongoing  regarding  the  transposition  of 
Council Directive 2024/1265/EU. According to preliminary estimates, most amendments are 
expected  to  impact  the  Budget  Act  and  the  Fiscal  Responsibility  Act.  No  information  is 
provided on the nature of the proposed changes or a specific timeline for transposition. 

25 

 
 
 
 
 
 
 
12 

Implementation of the main provisions of the Directive in ITALY 

The Italian authorities report that a parliamentary enquiry into the reform of the economic and 
financial programming and budgetary procedures in the context of the revised EU economic 
governance  framework  was  concluded  in  October  2024.  In  line  with  national  practice  for 
similar reforms, an in-depth analysis involving the Parliament with the technical support from 
the  Ministry  of  the  Economy  and  Finance  (MEF),  as  well  as  inputs  from  independent 
institutions is currently underway to assess the impact of the revised EU economic governance 
framework  on  national  legislations,  particularly  national  Law  No.  243/2012  and  Law  No. 
196/2009. While the information reported identifies the texts to be amended, it does not detail 
the transposition process. 

1. Statistics, accounting, transparency 

The  Italian  authorities  indicate  that  the  national  legislation,  in  particular  Article  19  of 
Legislative Decree No. 118/2011 and Article 38-bis of Law No. 196/2009, is already aligned 
with the amendments to Article 3(1) of the Directive.  

Regarding  amended  Article  3(2)  of  the  Directive,  the  Italian  authorities  report  that  the 
requirement to ensure timely and regular public availability of fiscal data for all sub-sectors of 
general government as set out under Regulation (EU) 549/2013 should not require significant 
adjustments to the national legislation. 

The authorities report that Article 31-bis of national Law No. 196/2009 already provides for a 
specific annex to the draft budget law detailing the State's off-budget operations and requires 
public  administrations  to  publish  relevant  information  for  which  they  are  responsible. 
Evaluations are ongoing to assess whether amendments to the current national provisions are 
needed to comply with the amendments to Article 14(1) of the Directive. 

2. Independent fiscal institutions 

The  Italian  authorities  highlight  that  Article  16  of  Law  No.  243/2012,  establishing  the 
Parliamentary Budget Office (UPB), already complies with the definition of independent fiscal 
institutions under revised Article 2(2)(h) of the Directive.  

Regarding Article 8a of the Directive, the authorities report that the current national legislation 
–  notably  Chapter  VII  of  Law  No.  243/2012  and  Article  10-ter  of  Law  No.  196/2009  –  is 
broadly aligned with the revised EU economic governance framework on the role, functions 
and  characteristics  of  the  UPB.  In  particular,  the  authorities  note  that  the  current  national 
primary legislation and administrative practices are consistent with the expanded tasks set out 
in Regulation 2024/1263/EU and Regulation 2024/1264/EU, referenced under Article 8a(5)(c) 
of  the  Directive.  The  Italian  authorities  report  that  the  process  of  transposing  into  national 
primary legislation the requirement for independent fiscal institutions to be subject to regular 
external evaluations by independent evaluators, as stipulated in Article 8a(4)(e), is currently 
underway. 

The authorities also report that appropriate amendments and additions to the Memorandum of 
Understanding  (MoU)  between  the  MEF  and  the  UPB  are  expected,  without  providing  a 
timeline  for  debate  and  adoption.  The  current  version  of  the  MoU  outlines,  inter  alia,  the 
institutional steps for the endorsement of macroeconomic forecasts in the planning documents 
that will need to be updated to reflect the provisions of the revised EU economic governance 
framework and changes in the national programming cycle and related tools. 

26 

 
 
3. Medium-term budgetary frameworks 

The Italian authorities highlight that the provisions in Chapter I of Law No. 243/2012 and Titles 
I and III of Law No. 196/2009 are compliant with amended Article 2 of the Directive.  

The following  legislative changes are planned in  order to  comply with  the requirements on 
medium-term budgetary frameworks under the revised Articles 9 and 10 of the Directive:  

•  The  requirement  for  national  medium-term  budgetary  objectives  to  align  with 
Regulation 2024/1263/EU, as set out under revised Article 9(2)(a) of the Directive, will 
be addressed through the reform of Title III of Law No. 196/2009.  

•  The  amendment  to  Article  9(2)(c)  of  the  Directive  will  be  implemented  through 

revisions to Title III of Law No. 196/2009. 

•  The requirement under  revised Article 10 of the Directive to adequately explain any 
deviation from national medium-term budgetary targets will be transposed into national 
legislation as part of the reform of the rules under Chapter III of Law 243/2012 and 
under Title III of Law 196/2009. 

The Italian authorities state that no changes in the national legislation are necessary to comply 
with revised Article 11 of the Directive.  

4. Reporting on disaster- and climate-related fiscal risks 

The Italian authorities note that several analytical projects have been launched at national level 
to  assess  contingent  liabilities  associated  with  catastrophic  risks,  which  will  inform  the 
development of appropriate methods for disseminating information but give no indication on 
the legal transposition of the amendments to Article 9(2)(d) and Article 14(3) of the Directive. 
Additionally, several regulatory measures have recently been adopted or are under discussion 
to  strengthen  administrative  and  financial  preparedness  in  managing  natural  disasters  and 
extreme events. These include specific provisions for post-disaster reconstruction, dedicated 
funds to distinguish between emergency response and recovery phases and the extension of 
insurance obligations, which took effect in March 2025 for larger firms, related to certain types 
of catastrophic events. 

5. Clarification amendments 

The Italian authorities note that the national legislation is already compliant with amendments 
laid down in Articles 2, 3(3), 4(1), 4(6), 5(a), 6(1)(b) and 7 of the Directive. The extension of 
the  medium-term  fiscal  planning  horizon  under  Article  5(b)  of  the  Directive  will  require 
amendments  to  national  Law  No.  196/2009.  Amendments  to  Article  6(2)  introducing  a 
reference to Regulation 2024/1263/EU in relation to escape clauses, will require adjustments 
of national Law No. 243/2012 - in particular Article 6 - which will be addressed in the context 
of the reform of the rules governing national instruments and the programming cycle. 

27 

 
 
 
 
13 

Implementation of the main provisions of the Directive in CYPRUS 

to  update 

Cyprus  plans 
its  Fiscal  Responsibility  and  Budgetary  Framework  Law 
[Νo.20(Ι)/2014] to ensure implementation of Council Directive 2024/1265/EU. The authorities 
did not share a timeline for these amendments. 

1. Statistics, accounting, transparency 

Regarding transposing Article 3(1) of the Directive relating to public accounting systems, the 
authorities  plan  to  ensure  continued  alignment  with  the  European  System  of  National  and 
Regional Accounts in force.  

Regarding transposing Articles 3(2) of the Directive relating to public availability of fiscal data 
and 14(1) relating to publishing information on bodies and funds that do not form part of the 
regular budgets in the context of budgetary processes, the authorities consider that the national 
legislation in force ensures compliance. 

2. Independent fiscal institutions 

Regarding transposing Articles 2(1)(h) of the Directive relating to the definition of independent 
fiscal  institutions  (IFIs),  8a(1)  of  the  Directive  relating  to  the  legal  establishment  of  IFIs, 
Article 8a(3) relating to the nomination and appointment of members to IFIs, 8a(4)(a) relating 
to  IFIs  not  taking  instructions,  8a(4)(b)  relating  to  IFIs’  public  communication,  8a(4)(d) 
relating to IFIs’ access to information, and 8a(5)(a) and 8a(5)(b) of the Directive relating to 
tasks of the IFIs, the authorities consider that the national legislation in force (i.e. PART III of 
law Νo.20(Ι)/2014) ensures compliance.  

Also  with  a  view  to  enable  the  Cypriot  Fiscal  Council,  the  FCC,  to  communicate  (Article 
8a(4)(b)),  the  legal  framework  foresees  a  minimum  number  of  staff  of  three  for  the  FCC 
(Article  26(1)  of  law  Νo.20(Ι)/2014).  The  authorities  consider  this  also  relevant  for  the 
transposition of Article 8a(4)(c), which is further strengthened by a new law, published in the 
Official Gazette on 4 April 2025, that releases any staff positions that were previously frozen 
by  other  legislation.  As  regards  the  FCC’s  budget  provision,  the  authorities  report  that  the 
Ministry  of  Finance  expresses  openness  to  reflect  on  strengthening  the  existing  standard 
procedure of requesting funds. 

The  authorities  point  out  that  provisions  relating  to  Article  8a(4)(d),  i.e.  Articles  30(1)  and 
30(3)  of  law  Νo.20(Ι)/2014,  are  very  strict,  requiring  any  entity  to  provide  any  necessary 
information to the Fiscal Council. Any inefficiencies in this procedure are to be reported. 

Regarding transposing Articles 8a(5)(c) and 8a(5)(d) of the Directive relating to tasks of the 
IFIs, the authorities indicate that they plan to assess and, if necessary, strengthen existing legal 
requirements. Assessing the consistency, coherence and effectiveness of the national budgetary 
framework is already codified as an IFI task (Article 19 of law Νo.20(Ι)/2014). 

Regarding  transposing  Article  8a(6)  of  the  Directive  relating  to  the  comply-or-explain 
principle, the authorities indicate that they plan to assess and, if necessary, strengthen existing 
legal requirements. The current national law foresees that, in the event the FCC disagrees with 
the macroeconomic forecasts of the Government, reconciliation discussions take place and in 
case  of  continued  disagreement,  the  Government  has  to  publicly  announce  its  position, 
justifying the lack of support (Articles 30(1) and 30(3) of law Νo.20(Ι)/2014). 

The authorities consider it necessary to amend the national legal framework to transpose Article 
8a(4)(e) of the Directive relating to external evaluations. 

28 

 
 
3. Medium-term budgetary frameworks 

The authorities plan to align the national law with Article 2(1)(e) of the Directive relating to 
definitions by aligning a range of provisions. 

The  authorities  consider  it  necessary  to  amend  the  national  legal  framework  to  transpose 
Articles 9(2)(a) of the Directive relating to national budgetary objectives over the medium term 
and 9(2)(c) relating to describing medium-term policies. 

Regarding transposing Articles 10 of the Directive relating to the consistency of annual budget 
legislation  with  the  national  budgetary  objectives  and  11  relating  to  updating  medium-term 
budgetary  plans  to  reflect  new  policy  priorities,  the  authorities  consider  that  the  national 
legislation in force ensures compliance (Articles 48, 51 and 54 of law Νo.20(Ι)/2014). 

4. Reporting on disaster- and climate-related fiscal risks 

Regarding transposing Article 9(2)(d) of the Directive as regards disaster- and climate-related 
fiscal  risks,  the  authorities  plan  to  assess  whether  an  amendment  of  the  national  legal 
framework is necessary. 

Regarding transposing Article 14(3) of the Directive relating to publishing relevant information 
on contingent liabilities, the authorities plan not to strengthen existing legal requirements but 
to clarify existing provisions with guidance on the reporting preparation and presentation. The 
Cypriot framework for the management of financial risks foresees reporting on any fiscal risk 
identified, including disaster- and climate-related fiscal risks (Article 58 of law Νo.20(Ι)/2014).  

5. Clarification amendments 

The  authorities  consider  it  necessary  to  amend  the  national  legal  framework  to  transpose 
Articles 2 of the Directive relating to definitions, 5(a) and (b) relating to establishing numerical 
fiscal rules, and 6(2) relating to escape clauses to numerical fiscal rules, requiring amendments 
to Articles 41, 42 and 43 of law Νo.20(Ι)/2014. 

Regarding transposing Article 3 of the Directive relating to public accounting systems and the 
public availability of fiscal data, the authorities consider it necessary to align the existing legal 
framework  while  pointing  out  that  many  of  the  requirements  of  the  amended  Directive  are 
already reflected in the national legislation in force. 

Regarding transposing Articles 4(1) and 4(6) of the Directive relating to macroeconomic and 
budgetary forecasts, and 7 on the consistency of annual budget legislation with numerical fiscal 
rules, the authorities consider that the national legislation in force ensures compliance. 

On Article 4(6), they point out that the mandate of the FCC is enshrined in Article 18(1) of law 
Νo.20(Ι)/2014, and that it has the power to provide an a priori and a posteriori public evaluation 
of the public fiscal policy according to Article 19(c). 

29 

 
 
 
 
14 

Implementation of the main provisions of the Directive in LATVIA 

The cornerstone of Latvia’s national fiscal framework is the Fiscal Discipline Law that was 
adopted in 2013 and amended in 2024. As of April 2025, the authorities were examining the 
need to amend the Fiscal Discipline Law as well as other legal acts to transpose the amending 
Directive 2024/1265/EU and preparing legislative changes to ensure compliance with article 2 
and 8a of the amended Directive. The legislative changes are expected to be completed by the 
end of 2025 and will concern the Fiscal Discipline Law as well as other regulations. 

1. Statistics, accounting, transparency 

The authorities are examining whether any specific measures would be needed to implement 
the clarification amendments laid down in Articles 3(1) and 14(1) of Directive 2011/85/EU. 

With respect to the amended provisions in Article 3(2), the authorities point out that Latvia’s 
public  sector  accounting  maturity,  which  measures  the  degree  of  compliance  with  the 
International Public Sector Accounting Standards (IPSAS), is assessed as high. 

Furthermore, the authorities are working on more extensive publication of fiscal data, including 
in response to Eurostat’s recommendations. 

2. Independent fiscal institutions 

Latvia’s Fiscal Discipline Council (FDC) was established by the Fiscal  Discipline Law and 
began operating on 1 January 2014. FDC’s mandate is to monitor the government’s compliance 
with  fiscal  rules,  endorse  the  macroeconomic  forecasts  that  underpin  the  budget,  assess  the 
adequacy of the fiscal security reserve and assess the sustainability of national fiscal policy, 
among other responsibilities. 

According to information provided by the authorities, legislative changes to ensure compliance 
with Article 2 and 8a of the amended Directive 2011/85/EU are planned to be completed by 
the end of 2025 and will concern the Fiscal Discipline Law as well as other regulations. 

The authorities point out that in practice the FDC already supports functioning of the renewed 
European  fiscal  framework,  having  provided  an  opinion  on  Latvia’s  Medium  Term  Fiscal 
Structural  Plan,  as  well as  on  the  first  Annual  Progress  Report  in  2025, which  are  publicly 
available on the webpages of the FDC and Ministry of Finance. Similarly, the FDC attended in 
April 2025 a discussion at the European Affairs Committee of Latvia’s Parliament (the Saeima) 
and was invited to the Cabinet of Ministers to discuss Progress Report 2025.  

Regarding resources of the FDC, the authorities inform that the budgetary framework in Latvia 
was  set  for  three  years,  and  this  provides  stability  of  resources.  No  specific  information  is 
provided with respect to remaining requirements in Article 8a. 

3. Medium-term budgetary frameworks 

The  authorities  consider  that  current  provisions  of  the  Fiscal  Discipline  Law  already 
comprehensively cover the relevant requirements in the amended directive. Should any gaps in 
national legislation be identified during the implementation process, the authorities will apply 
necessary changes. No specific information is provided with respect to individual amended and 
clarified requirements of Directive 2011/85/EU. 

30 

 
 
4. Reporting on disaster- and climate-related fiscal risks 

The authorities do not elaborate on their intentions to amend the existing national laws in order 
to transpose the new requirements concerning reporting on disaster- and climate-related fiscal 
risk. 

Also as regards compiling and publishing such information, the authorities do not have tools 
yat  allowing  them  to  make  an  assessment  of  the  direct  medium-  and  long-term  impact  on 
general government finances of macrofiscal risks from climate change and its environmental 
and distributional impacts. At the same time, they are researching publicly available analytical 
tools and databases that would be suitable for Latvia’s public financial management system 
with a view to setting up such monitoring and reporting systems. In parallel, the authorities are 
working on a green budgeting tagging methodology. In their assessment, the green budgeting 
methodology,  once  completed,  could  be  useful  in  formulating  rules  for  the  reporting  on 
climate-related contingent liabilities. 

5. Clarification amendments 

The authorities are examining whether any specific measures would be needed to implement 
the clarification amendments laid down in Articles 2, 3, 4, 5, 6 and 7 of Directive 2011/85/EU. 
Overall, the authorities consider that these provisions are already well covered in the Fiscal 
Discipline  Law,  the  Law  on  Budget  and  Financial  Management  and  in  relevant  national 
regulations, but do not provide detailed information. 

31 

 
 
 
 
15 

Implementation of the main provisions of the Directive in LITHUANIA 

Lithuania’s fiscal framework was established in 2014 through the Constitutional Law on the 
Implementation of the Fiscal Treaty and the National Audit Law. As of April 2025, the fiscal 
framework is undergoing a comprehensive review with the aim to align national numerical and 
procedural  fiscal  rules  with  the  EGR,  including  transposing  the  amending  Directive 
2024/1265/EU  into  national  law,  and  to  simplify  the  national  fiscal  rules.  According  to  the 
authorities, this comprehensive review will involve changes to  the  abovementioned laws as 
well  as  to  the  Seimas  (national  Parliament’s)  Statute  and  possibly  to  other  legal  acts.  The 
deadline for the finalisation of the review process is set for 31 December 2025. 

1. Statistics, accounting, transparency 

The authorities do not provide specific information on possible changes to the national laws 
and regulations due to new and clarified requirements in the areas of statistics, accounting, and 
transparency. 

2. Independent fiscal institutions 

Since  1  January  2015,  Lithuania’s  National  Audit  Office  acts  as  an  Independent  Fiscal 
Institution  (NAO  FI),  monitoring  compliance  with  the  fiscal  discipline  rules  and  preparing 
opinions  and  reports.  One  of  the  tasks  of  NAO  FI  concerns  assessment  and  approval  of 
macroeconomic forecasts. 

According  to  the  authorities,  the  comprehensive  review  of  Lithuania’s  fiscal  framework 
mentioned  above  will  strengthen  the  role  of  NAO  FI  through  transposing  requirements  in 
Articles 2 and 8a of the amended Directive, including by implementing the “comply or explain” 
principle. No specific information is provided with respect to remaining requirements in Article 
8(a). 

3. Medium-term budgetary frameworks 

As part of the comprehensive review of Lithuania’s fiscal framework, the authorities intend to 
enhance budget orientation towards a multi-year perspective. Part of the move towards mid-
term  budgeting  has  already  materialised  by  adopting  in  2024  a  revised  Law  on  the  Budget 
Structure, which entered into force in 2025, and through the approval of the first three-year 
budget for 2025-2027. No specific information is provided with respect to specific new and 
clarified requirements in Directive 2011/85/EU. 

4. Reporting on disaster- and climate-related fiscal risks 

As part of the comprehensive review of Lithuania’s fiscal framework, the authorities are also 
addressing new requirements on reporting disaster and climate related fiscal risks. However, 
no information is provided on possible legal amendments to transpose the new requirements. 

5. Clarification amendments 

No specific information is provided regarding clarification amendments laid down in Articles 
2, 3, 4, 5, 6 and 7 of Directive 2011/85/EU. 

32 

 
 
 
 
16 

Implementation of the main provisions of the Directive in LUXEMBOURG 

In their reply, the authorities of Luxembourg provide references to existing legal provisions 
and to a memorandum of understanding, indicating that they ensure the transposition of certain 
provisions  of  the  amended  Directive.  The  authorities  also  indicate  that  reflection  and 
consultations with relevant stakeholders are ongoing or planned, in order to determine how the 
national legislation would need to be amended to ensure full transposition of the amendments 
to the Directive on national budgetary frameworks. 

1. Statistics, accounting, transparency 

The  authorities  report  that  the  transposition  of  the  provisions  of  Articles  3(1)  and  14(1)  is 
ensured by Law of 12 July 2014 on coordination and fiscal governance and respectively by the 
accounting  law  on  the  budget,  accounting  and  State  treasury.  For  the  full  transposition  of 
Article  3(2),  consultations  are  taking  place  with  the  national  statistics  office  regarding  the 
publication of quarterly deficit data by subsectors. 

2. Independent fiscal institutions 

When providing information on existing provisions and arrangements for independent fiscal 
institutions,  the  authorities  refer  to  the  Law  of  12  July  2014  on  coordination  and  fiscal 
governance and to the memorandum of understanding (MoU) between the Ministry of Finance 
and the National Council for Public Finances. 

According to the first assessment by the Ministry of Finance, all the provisions of Article 8a 
with two exceptions are transposed. The memorandum of understanding covers the access to 
information, the capacity to communicate publicly and the comply-or-explain principle, while 
the Law of 12 July 2014 ensures the transposition of the other IFI provisions. The provision 
that  the  independent  fiscal  institutions  are  subject  to  regular  external  evaluations  by  an 
independent  evaluator  and  the  provision  for  the  independent  fiscal  institution  to  participate 
upon invitation in regular hearings and discussions at the national Parliament are not transposed 
and the authorities do not  give any indication on their plans in  this respect.  The  authorities 
report that they will assess the need to make changes to the national legislation to ensure that 
the national IFI can perform the tasks set in the preventive and corrective arm regulations. 

3. Medium-term budgetary frameworks 

The  authorities  report  that  discussions  are  ongoing  on  possible  amendments  to  the  national 
fiscal framework in relation to the provisions for the medium-term budgetary framework. The 
legal references provided reflect the first assessment of the Ministry of Finance of the existing 
national  legislation  with  respect  to  the  amendments  to  the  Directive.  In  particular,  the 
authorities  indicate  that  the  provisions  of  Article  9(2)(a)  are  fulfilled  by  provisions  of  the 
national  budget  law  (Law  of  8  June  1999  as  amended).  The  national  budget  law  already 
includes references to macrofiscal risks, but not to reforms and investments. The authorities 
are analysing whether the transposition of Article 10 would require any changes in the national 
legislation  under  possible  amendments  to  the  national  fiscal  framework  in  relation  to  the 
provisions for the medium-term budgetary framework. 

33 

 
 
4. Reporting on disaster- and climate-related fiscal risks 

The  authorities  indicate  that  there  are  no  specific  references  to  reporting  on  disaster  and 
climate-related fiscal risks in the national legislation in force, but that discussions are ongoing 
at national level, without any information on the timeline. 

5. Clarification amendments 

The  authorities  outline  existing  acts  that  are  considered  to  ensure  the  transposition  of  the 
clarification  amendments  brought  to  the  provisions  of  Directive  2011/85/EU  and  beyond. 
These acts include the Law of 12 July 2014 on coordination and fiscal governance that ensures 
the  use  of  ESA2010  and  establishes  the  escape  clauses  that  apply  to  the  country-specific 
numerical  fiscal  rules.  The  national  budget  law  of  8  June  1999  (as  amended)  transposes 
Article 4(1)  on  the  realism  of  annual  and  multiannual  macroeconomic  forecasts  and 
explanations of deviations from the Commission's forecasts. Reflection is ongoing to ensure 
the consistency of national fiscal rules with the new preventive arm Regulation 2024/1263/EU 
and of the annual budget legislation with the country-specific numerical rules in force. 

34 

 
 
 
 
17 

Implementation of the main provisions of the Directive in HUNGARY 

The Hungarian authorities report that discussions are ongoing regarding the tasks and potential 
legislative  changes  to  be  undertaken  to  comply  with  the  amendments  to  the  Directive. 
Following expert consultation, a timeline will be established and proposals for changes in the 
national legislation will be shared where relevant. No information is provided on the legislative 
texts  likely  to  be  amended,  the  nature  of  the  proposed  changes,  or  a  specific  timeline  for 
transposition. 

35 

 
 
 
 
18 

Implementation of the main provisions of the Directive in MALTA 

The Fiscal Responsibility Act of 8 August 2014 (FRA) sets requirements for the national fiscal 
framework in Malta. The Maltese authorities report specific amendments to the FRA that are 
being considered to ensure compliance with the amended Directive. However, no information 
is provided on the timeline for the adoption of these amendments. 

1. Statistics, accounting, transparency 

The  Maltese  authorities  report  that  the  FRA  already  addresses  requirements  on  statistics, 
accounting and transparency of the amended Directive.  

Regarding Article 3(2) of the Directive, the authorities refer to Article 39(4) of the FRA which 
requires that all general government units and extra-budgetary units maintain a proper system 
of  accounts  and  provide  timely  data  to  the  Ministry  responsible  for  finance.  Article  39(5) 
further obliges the Ministry to compile general government data in accordance with statistical 
requirements. General government data includes the central government, the extra budgetary 
units which are classified as forming part of this sector, as well as the local councils. 

Regarding Article 14(1) of the Directive, the authorities refer to Article 3(a) of the FRA which 
obliges  the  government  to  disclose  at  the  time  of  the  budget  presentation  any  significant 
changes  in  the  accounting  standards,  policies  and  practices  affecting  or  likely  to  affect  the 
computation  of  the  prescribed  fiscal  indicators.  Article  3(a)  of  the  FRA  also  requires 
publication  of  data  on  all  claims  and  commitments  made  by  the  general  government  with 
potential budgetary implications. 

2. Independent fiscal institutions 

Articles 13(3)(a) and Articles 42 to 61 of the FRA already establishes the Fiscal Council as an 
independent institution with a monitoring role, including the assessment and endorsement of 
macroeconomic and fiscal forecasts. 

Regarding Articles 2 and 8a(4)(e) of the Directive, the Maltese authorities report that national 
legal provision are considered to ensure that the Fiscal Council is subject to regular external 
evaluations by external evaluators. The Government is also considering how such evaluations 
should  be  financed  in  order  not  to  disrupt  the  normal  working  of  the  independent  fiscal 
institutions. 

3. Medium-term budgetary frameworks 

The Maltese authorities report plans to replace the current Medium-Term Fiscal Strategy with 
a Medium-Term Fiscal Structural Plan (MTFSP). This plan will be submitted at the start of 
each legislature and updated every four years and will be the main national instrument ensuring 
medium-term  fiscal  discipline  and  coordination.  The  MTFSP  is  reported  to  meet  the 
requirements under Articles 9 to 11 of the Directive. 

The proposed MTFSP will: 

• Set out the fiscal trajectory, investment and reform commitments; 

• Be based on macroeconomic and fiscal forecasts, with reference to debt sustainability 

and climate risks; 

• Define expenditure ceilings consistent with the net expenditure path; and 

• Serve as the central reference document for multi-annual fiscal planning. 

36 

 
 
4. Reporting on disaster- and climate-related fiscal risks 

The Maltese authorities report to be considering explicit provisions for the inclusion of disaster- 
and climate-related fiscal risks within the MTFSP. The authorities are considering introducing 
provisions in  the proposed FRA  amendments  is  contemplating  an  assessment of such risks, 
aligned with Articles 9(2)(d) and 14(3) of the Directive. 

5. Clarification amendments 

The Maltese authorities report changes under consideration aim to modernise and simplify 
the FRA in line with the clarified provisions of the Directive and the reformed EU economic 
governance framework. Changes under consideration include: 

• Updating definitions in Article 2 of the FRA to align with Regulation (EU) 2024/1263, 
including terms such as “net expenditure path”, “technical guidance”, and “reference 
trajectory”; 

• Replacing the structural balance and MTO rules with a single operational fiscal rule based 
on the net expenditure path (revised Article 8 of the FRA); 

• Removing references to obsolete rules, such as the 1/20th debt reduction rule (Article 9) and 
medium-term budgetary objectives (Articles 10 and 11); and 

• Linking automatic correction mechanisms to procedures under Regulation (EU) 2024/1264 
(as foreseen in revised Article 11). 

37 

 
 
 
 
19 

Implementation of the main provisions of the Directive in THE NETHERLANDS 

In  The  Netherlands,  the  Ministry  of  Finance  and  the  Ministry  of  the  Interior  and  Kingdom 
Relations  have  brought  forward  an  explanatory  memorandum  and  legislative  proposal  to 
amend  the  Dutch  Sustainable  Public  Finances  Act  to  transpose  the  amending  Directive 
2024/1265/EU. Following its approval by the Council of Ministers (Ministerraad) on 14 March 
2025, and the positive advice of the Council of State (Raad van State), the proposal will be 
treated in Parliament (no concrete timeline provided). 

1. Statistics, accounting, transparency 

Regarding transposing Article 3(1) of the Directive relating to public accounting systems, the 
Dutch authorities plan to ensure continued alignment with the European System of National 
and Regional Accounts in force.  

Regarding transposing Articles 3(2) of the Directive relating to public availability of fiscal data 
and 14(1) relating to publishing information on bodies and funds that do not form part of the 
regular budgets in the context of budgetary processes, the Dutch authorities do not indicate a 
need for implementing measures.  

2. Independent fiscal institutions 

Regarding  transposing  Article  8a(1)  of  the  Directive  relating  to  the  legal  establishment  of 
independent fiscal institutions (IFIs), the Dutch authorities plan to introduce a new provision 
in the Sustainable Public Finances Act, Article 2a(1), designating the Central Planning Bureau 
(CPB) and the Advisory Division as independent fiscal institutions for the tasks arising from 
the Directive. 

Regarding  transposing  Article  8a(3)  of  the  Directive  relating  to  the  nomination  and 
appointment  of  members  to  IFIs,  the  Dutch  authorities  do  not  see  a  need  for  implementing 
measures.  

Regarding transposing Article 8a(4)(a) of the Directive relating to IFIs not taking instructions, 
the  Dutch  authorities  plan,  in  relation  to  the  tasks  of  IFIs  described  in  Article  8a(5)  of  the 
Directive, to amend the Sustainable Public Finances Act to clarify independence of the CPB 
from the Minister of Economic Affairs, as the CPB is part of the Ministry of Economic Affairs. 
The Dutch authorities further explain that Article 4 of the Protocol for the Policy Assessment 
Agencies states that a minister or state secretary cannot give instructions to the CPB regarding 
the  research  methods  or  the  contents  of  its  reports.  The  Advisory  Division,  as  part  of  the 
Council of State, is independently legally anchored under the Constitution. 

Regarding transposing Article 8a(4)(b) of the Directive relating to IFIs’ public communication, 
the  Dutch  authorities  do  not  consider  there  to  be  a  need  for  implementing  measures.  They 
further  clarify  that  they  consider  independent  fiscal  institutions  to  not  be  required  to  take 
instructions regarding the tasks arising from the Directive, including on communication. 

Regarding transposing Article 8a(4)(c) of the Directive relating to the resourcing of IFIs, the 
Dutch  authorities  do  not  consider  there  to  be  a  need  for  implementing  measures.  The  CPB 
budget  is  part  of  the  Ministry  of  Economic  Affairs’  budget,  with  no  more  than  20%  of  the 
CPB's budget coming from external assignments. The budget for the Advisory Division, for 
which the Minister of the Interior and Kingdom Relations is politically responsible, while the 
Council  of  State  administers  its  budget/budget  section,  is  governed  by  Article  4.4(4)  of  the 
Government  Accounts  Act  2016,  which  ensures  respect  for  the  Advisory  Division's 
constitutional  position.  The  Dutch  authorities  did  not  indicate  whether  they  plan  any 
implementing measures addressing the IFIs’ human resourcing needs. 

38 

 
 
Regarding transposing Article 8a(4)(d) of the Directive relating to IFIs’ access to information, 
the  Dutch  authorities  plan  to  amend  the  Sustainable  Public  Finances  Act  to  include  a  new 
Article 2b(4) which obliges the Minister of Finance to provide IFIs with adequate and timely 
access to the information required for the tasks arising from the amended Directive. They also 
point to work agreements between the Ministry of Finance and the Advisory Division which 
have  been  established  to  ensure  a  smooth  and  timely  process.  These  agreements  cover 
deadlines  for  the  submission  of  budget  documents  (both  in  spring  and  August),  essential 
variables  that  must  be  included,  political  and  administrative  consultations,  processes  and 
publication  arrangements.  As  the  Dutch  authorities  point  out,  some  practices  of  advanced 
information sharing are customary rather than legally anchored. 

Regarding  transposing  Article  8a(4)(e)  of  the  Directive  relating  to  external  evaluations,  the 
Dutch  authorities  do  not  consider  there  to  be  a  need  for  implementing  measures.  External 
evaluations of the CPB are conducted regularly (every three to five years) by an independent 
advisory board (CPC) with budget by the CPB, according to Article 5 of the Protocol for the 
Policy Assessment Agencies. For this purpose, it commissions external evaluators. The Dutch 
authorities  note  that  the  Advisory  Division  will  commission  an  independent  third  party  to 
evaluate the tasks it performs as an  IFI but  do not  clarify whether such  evaluations  will be 
legally anchored.  

Regarding transposing Article 8a(5) of the Directive relating to tasks of the IFIs, the Dutch 
authorities  plan  to  introduce  new  Articles  2a(1)  and  2b(1)(a)-(f)  to  the  Sustainable  Public 
Finances Act. They explain that for flexibility, the task distribution between the two IFIs is 
outlined  in  the  explanatory  memorandum  rather  than  the  legislative  proposal.  Regarding 
transposing Article 8a(5)(c), from 1 May 2032, IFIs can be requested to provide an opinion on 
the macroeconomic forecast and macroeconomic assumptions underlying the net expenditure 
path.  Regarding  transposing  Article  8a(5)(d),  the  Dutch  authorities  intend  to  determine  and 
codify the exact  implementation  of this task at  a later stage, taking customary practice as a 
starting  point.  Regarding  transposing  Article  8a(5)(e),  the  Dutch  authorities  plan  to  legally 
anchor the practice of IFIs providing technical briefings on request to members of the Senate 
and House of Representatives regarding reports issued within the framework of independent 
fiscal oversight, but they do not outline how the task of participation in regular hearings and 
debates in the national parliament more generally is legally anchored. 

Regarding  transposing  Article  8a(6)  of  the  Directive  relating  to  the  comply-or-explain 
principle, the Dutch authorities plan to introduce a new Article 2b(2) to the Sustainable Public 
Finances  Act  to  anchor  for  IFIs  in  general  the  practice  of  the  Advisory  Council  issuing  an 
assessment at least twice a year, to which the government has to respond. 

Regarding transposing Article 4(6) of the Directive relating to ex post evaluation of forecasts, 
the Dutch authorities explain that the CPB’s forecasts are evaluated by the Central Planning 
Commission  (CPC),  an  independent  body  that  is  functionally  autonomous  from  the  CPB, 
though they do not explain the legal basis for such evaluations.  

3. Medium-term budgetary frameworks 

Regarding transposing Article 9(2)(a) of the Directive relating to national budgetary objectives 
over  the  medium  term,  the  Dutch  authorities  do  not  consider  there  to  be  a  need  for 
implementing measures.  

Regarding  transposing  Article  9(2)(c)  of  the  Directive  relating  to  describing  medium-term 
policies, the Dutch authorities explain that the proposed Article 2c of the Sustainable Public 
Finances Act establishes that the Minister of Finance is responsible for ensuring compliance 

39 

 
 
with this Article. They point to the European budgetary documents as containing analysis of 
policy  measures  –  specifically  reforms  and  investments  –  and  their  contribution  to  the 
sustainability  of  public  finances,  as  well  as  how  they  contribute  to  economic  growth,  but 
without drawing a link to legal anchoring. 

Regarding transposing Article 10 of the Directive relating to the consistency of annual budget 
legislation  with  the  national  budgetary  objectives,  the  Dutch  authorities  consider  their 
framework aligned. 

Regarding  transposing  Article  11  of  the  Directive,  the  Dutch  authorities  affirm  that  a  new 
cabinet always has the option to revise the budgetary frameworks upon taking office. 

4. Reporting on disaster- and climate-related fiscal risks 

Regarding transposing Articles 9(2)(d) of the Directive relating to assessing envisaged policies 
according to their likely impact on the sustainability of the public finances and sustainable and 
inclusive growth and 14(3) relating to publishing relevant information on disaster and climate-
related  contingent  liabilities  and  fiscal  costs,  the  Dutch  authorities  plan  to  introduce  a  new 
Article 2c to the Sustainable Public Finances Act assigning a duty to comply with these Articles 
to the Minister of Finance. They also point to Article 2(11) (Article 2(5) in the amended Act), 
which establishes that the Minister of Finance bases medium- and long-term budgetary policy 
on independent studies regarding the sustainability of public sector finances. 

5. Clarification amendments 

Regarding transposing the amended Article 2 of the Directive, the Dutch authorities consider 
their framework compliant. 

Regarding transposing the amended Article 4(1) of the Directive relating to macroeconomic 
and  budgetary  forecasts,  the  Dutch  authorities  consider  their  framework,  which  requires 
adopting  CPB  forecasts  unaltered  for  budgetary  purposes,  compliant  (new  Article  2a(3) 
replacing Article 2(10) and Article 2(2)(c) of the Sustainable Public Finances Act). 

Regarding transposing Article 5(b) of the Directive, the authorities state that the Sustainable 
Public Finances Act legally anchors trend-based budgetary policy while considering the Treaty 
Values. 

The Dutch authorities do not elaborate whether and how Article 7 of the Directive is transposed. 
However, they mention, as regards numerical fiscal rules, Article 2(2) of the Sustainable Public 
Finances  Act,  through which  the cabinet must make clear agreements  for the entire cabinet 
term  about  the  maximum  amount  that  may  be  spent  in  a  single  year  (the  expenditure 
framework) and the extent to which taxes and premiums may be adjusted each year for policy 
reasons (the revenue framework). A set of budgetary rules has been established (Appendix 1 
of the 2025 Budget Memorandum for the budgetary rules of the Schoof cabinet). 

Article 6(2) of the Directive relating to escape clauses to numerical fiscal rules does not apply, 
as no escape clauses are foreseen. 

40 

 
 
 
 
20 

Implementation of the main provisions of the Directive in AUSTRIA 

Austria explains that the transposition timeline is affected by the new government having come 
into office only on 3 March 2025. Therefore, the specific amendments are still under discussion 
and  have  yet  to  be  finalized,  but  Austria  reports  its  intention  to  initiate  all  necessary 
implementation processes in due time to meet the deadline. 

1. Statistics, accounting, transparency 

Austria  reports  that  it  has  already  implemented  significant  parts  of  the  statistical  and 
transparency  requirements  through  the  Gebarungsstatistik-Verordnung  2014  (GebStat-VO 
2014)  and  the  Bundesstatistikgesetz  2000,  which  enable  the  collection  and  publication  of 
deficit and debt data. Austria is discussing an amendment to the GebStat-VO 2014 and/or the 
Bundeshaushaltsgesetz  2013  (BHG  2013).  Article  14(1)  requirements  are  said  to  be  met 
through existing reporting practices in the Strategy Report and public accounting frameworks. 

2. Independent fiscal institutions 

Austria considers that the independence of the Fiscal Council is currently ensured under the 
Fiskalrat- und Produktivitätsratgesetz 2021 (FPRG 2021) in alignment with the Directive.  It 
reports that a legislative amendment to the FPRG 2021 is being discussed, without, however, 
specifying  what  amendments  are  being  considered,  as  negotiations  are  still  ongoing.  The 
second Austrian IFI, the Austrian Institute for Economic Research (WIFO), is not explicitly 
mentioned. Similarly, due to the still ongoing negotiations, Austria does not report on how the 
performance  of  all  the  compulsory  tasks  (existing  and  new)  of  the  independent  fiscal 
institutions is to be ensured. 

3. Medium-term budgetary frameworks 

Austria considers that the core elements of the medium-term budgetary framework are already 
covered by paragraphs 13 and 14 of the BHG 2013, the Österreichischer Stabilitätspakt 2012 
and  the  Schuldenbremsenverordnung.  Austria  reports  that  adaptations  to  ensure  full 
compliance  with  the  amended  Directive  are  under  discussion,  without,  however,  specifying 
what amendments are being considered, as negotiations are still ongoing. 

4. Reporting on disaster- and climate-related fiscal risks 

Austria reports that it is being discussed to introduce a new legal provision in the BHG 2013 
and  the  ÖStP  2012  to  explicitly  address  the  fiscal  sustainability  impacts  of  climate  and 
distributional effects as required by Article 9(2)(d). Furthermore, to implement Article 14(3), 
new  legal  obligations  are  under  discussion  to  ensure  the  publication  of  climate-related 
contingent liabilities in the BHG 2013 and the amended ÖStP 2012. 

5. Clarification amendments 

Austria  considers  that  ESA  2010  definitions  and  sector  assignment  are  already  covered  in 
national  law through the GebStat-VO 2014, BHG 2013, ÖStP 2012 and Voranschlags- und 
Rechnungsabschlussverordnung  2015  (VRV  2015).  For  Article  6(2),  the  ÖStP  2012  and 
Schuldenbremsenverordnung are said to already regulate escape clauses. Article 7 is said to be 
met in practice through paragraphs 2 and 13 of the BHG 2013 and Article 15(2) of ÖStP 2012, 
while  explicit  linkages  to  fiscal  rules  are  reported  to  be  under  discussion  for  forthcoming 
amendments. 

41 

 
 
42 

 
 
 
 
21 

Implementation of the main provisions of the Directive in POLAND 

The  EU  policy  coordination  division  of  the  Ministry  of  Finance  informed  on  the 
implementation process of Directive 2024/1265/EU. Legislative change is chiefly linked to the 
adoption of the new Fiscal Council Act establishing a first Fiscal Council in Poland in January 
2025 which will start its functions in January 2026.  

1. Statistics, accounting, transparency 

The Ministry of Finance reports that Poland has a public sector accounting system  in place 
which comprehensively and consistently covers all subsectors of the general government and 
which gathers information necessary to generate data for ESA purposes. The accounting system 
is subject to internal controls and independent audits as transposed in the Act on accounting. 
All public sector entities are required to apply the provisions of the act on accounting. 

The Ministry does not provide information on the transposition of the amendment to Article 
14(1). 

2. Independent fiscal institutions 

The Fiscal Council Act, published on 13 January 2025, establishes the Fiscal Council which 
will enter into force on 1 January 2026.  

Council  members  will  be  selected  based  on  professional  expertise  in  public  finances, 
macroeconomics, and budgetary management. They will have to hold at least a Masters degree 
and  have  10+  years  of  experience  in  two  of  the  three  following  fields:  public  finances, 
macroeconomy  or  finance  management.  Additionally,  Chair  candidates  will  need  at  least  a 
Ph.D. in social sciences in the field of economics and finance or legal sciences. Appointments 
will be organised through public calls, and selection reports made public. Candidates will then 
appear at public hearings before a competent Sejm Committee and final appointments are made 
by the Sejm with Senate consent (Articles 10–11). The first Director will be appointed by the 
Minister of Finance. Their appointment procedure was published according to Article 24 of the 
new Act. 

Council member are prohibited from being affiliated to a political party (at present and in the 
last four years) and owning excessive shares in companies (Article 16). The Act (Article 7) 
also  requires  that  all  documents  produced  by  the  Council  be  published,  especially  those 
stemming  from  the  Council's  mandate.  Operational  resources  are  ensured  by  the  Council 
having  been  established  as  a  budget  unit  (Article  22  and  25  of  the  Act)  and  access  to 
information by the Council’s right to request data relevant to its tasks from units and bodies of 
the general government. If these fail to present the data, the Council can publish this fact or 
notify the supervisory institution (Article 6). Finally, every 3 years, an external evaluation will 
be performed by either an independent body with expertise in public finance, macroeconomy 
or finance management of public finance units, or by another IFI or organisation with a unit 
dedicated to IFIs (Article 28).  

The  Ministry  of  Finance  reports  that  the  mandate  of  the  Council  laid  out  in  Article  4  is 
consistent with Article 8a of the Council Directive 2024/1265/EUand subject to the comply or 
explain mechanism, whereby it has two months to explain deviation from the Fiscal Council’s 
opinion.  The  Fiscal  Council  will  assess  the  Ministry  of  Finance  forecast  by  explaining 
differences  with  the Commission  forecast.  It plays a role in  the stabilizing  expenditure rule 

43 

 
 
(SER) where it can advise setting the correction value in the SER differently than planned by 
Article 112a of the Public Finance Act. This opinion, delivered on the Minister’s request, must 
focus  on  long-term  sustainability  and  macroeconomic  impact.  Beyond  the  Directive,  the 
Council  also  advises  on  activating  national  escape  clauses  and  gives  opinions  on  draft 
government  documents,  their  impact  on  sustainability  of  public  finances  and  the 
macroeconomic situation at the request of the Ministry of Finance.  

3. Medium-term budgetary frameworks 

Following  amendments  introduced  by  Directive  2024/1265/EU,  the  Fiscal  Council  Act 
introduced multiannual macroeconomic assumptions to the preparation of the draft budget act 
(Article  35  (10(a-b)).  The  medium-term  fiscal-structural  plan  (MTP)  is  the  main  Polish 
document for medium term budgetary objectives, containing the net expenditure path and target 
levels of deficit and debt (Article 35(2) of the Fiscal Council Act), which are fully aligned with 
country‑specific numerical fiscal rules (as supervised by the Fiscal Council). The Ministry of 
Finance does not report the level of detail of the plan, nor the inclusion of its medium term 
impact. 

4. Reporting on disaster- and climate-related fiscal risks 

The  Ministry  of  Finance  did  not  report  on  the  disaster-  and  climate-related  fiscal  risks 
requirements of Directive 2024/1265/EU. 

5. Clarification amendments 

Articles 2-7 are reported as fully transposed by the Polish Ministry of Finance.  

44 

 
 
 
 
22 

Implementation of the main provisions of the Directive in PORTUGAL 

The Portuguese authorities report that they intend to transpose the amendments to the Directive 
into national law notably through amendments to the national Budgetary Framework Law and 
to the Statutes of the Public Finance Council (CFP). While the information reported identifies 
the  texts  to  be  amended,  it  does  not  include  details  on  the  proposed  changes  or  a  specific 
transposition timeline. 

1. Statistics, accounting, transparency 

The Portuguese authorities report that the collection of accrual accounting data and information 
needed to generate accrual-based statistics in a comprehensive and coherent manner across all 
general government sub-sectors is underway. The authorities further note that the current public 
accounting systems cover all sub-sectors of general government and contain the information 
needed to generate accrual data, complying with the provisions of amended Article 3(1) of the 
Directive. The compilation of public accounting data is monitored by an internal control system 
and the Court of Auditors, which have online access to datasets. 

The Portuguese authorities also report that the timely and regular public availability of fiscal 
data for all sub-sectors of general government as set out by Regulation 549/2013/EU, required 
under Article 3(2) of the Directive, is already ensured.  

Regarding Article 14(1)  of the Directive, the authorities indicate that the budgetary process 
includes all the bodies and funds that form part of the general government, as established under 
Article 2 of the national Budgetary Framework Law. Exceptions concern the bodies and funds 
that have ceased activity, which are published in the State Budget Report. 

2. Independent fiscal institutions 

The Portuguese authorities report that the CFP was established by Law No. 22/2011, following 
the 5th amendment to the previous Budgetary Framework Law (Law No. 91/2011). Article 7 
of the national Budgetary Framework Law in force (No. 151/2015, as amended) sets out the 
mandate of the CFP and states that the composition, powers, organisation and functioning of 
the CFP and the status of its members are defined by law. The CFP Statutes were approved by 
Law No. 54/2011, as amended by Law No. 82-B/2014.  

The Portuguese authorities report that amendments to the CFP Statutes are planned to comply 
with the requirements under Article 8a(4)(e) of the Directive, which provides that independent 
fiscal institutions shall be subject to regular external evaluations by independent evaluators. 
The information reported does not address other paragraphs of Article 8a of the Directive. 

3. Medium-term budgetary frameworks 

The Portuguese authorities report that they plan to amend the national Budgetary Framework 
Law in order to incorporate references to “national budgetary objectives over the medium term” 
as set out under the provisions of revised Article 2(e), Article 9(2)(a) and Article 9(2)(c) of the 
Directive, and to integrate the requirement to “duly explain any departure” of the annual budget 
from the national budgetary objectives over the medium-term, as set out under amended Article 
10 of the Directive. 

45 

 
 
4. Reporting on disaster- and climate-related fiscal risks 

The Portuguese authorities report that amendments to the national Budgetary Framework Law 
are  planned  to  incorporate  the  legal  provisions  and  set  out  the  rules  to  be  followed  for  the 
reporting under  amended  Article 9(2)(d) and Article 14(3) of the Directive, with  regards to 
considering the macro fiscal risks from climate change and its environmental and distributional 
impacts  in  the  sustainability  assessment  of  public  finances,  and  publishing  information  on 
disaster-  and  climate-related  contingent  liabilities  and  on  the  fiscal  costs  incurred  due  to 
disasters  and  climate-related  shocks.  The  authorities  do  not  indicate  a  timeline  for  these 
amendments. 

5. Clarification amendments 

The  Portuguese  authorities  report  that  the  Budgetary  Framework  Law  will  be  amended  to 
present the legal provisions related to the clarification amendments laid down in Articles 2, 3, 
4, 5, 6 and 7 of the Directive. 

46 

 
 
 
 
23 

Implementation of the main provisions of the Directive in ROMANIA 

The Romanian authorities report that amendments to the Fiscal-Budgetary Responsibility Law 
no. 69/2010, as amended by Law no. 377/2013 and republished, are currently being prepared 
to  ensure  transposition  of  the  Directive.  No  information  is  provided  on  the  legislative  texts 
likely  to  be  amended,  the  nature  of  the  proposed  changes,  or  a  specific  timeline  for 
transposition. 

47 

 
 
 
 
24 

Implementation of the main provisions of the Directive in SLOVENIA 

Slovenia is transposing the amending Directive 2024/1265 mainly via two legal acts: the new 
Fiscal Rules Act, which entered into force on 9 April 2025, and an amendment of the Public 
Finance Act, which entered into force on 14 June 2025. 

1. Statistics, accounting, transparency 

The Slovenian authorities report that changes to Article 2 of the Directive as regards the use of 
the  European  system  of  national  and  regional  accounts  in  the  European  Union  (ESA)  are 
transposed with Article 2 of the Fiscal Rules Act and Article 9p of the amended Public Finance 
Act. 

The Slovenian authorities report that Article 3 of the Directive relating to public accounting 
systems and public availability of fiscal  data has been transposed  (Article 9t(1), introduced 
through the recent amendment, and Article 89 of the Public Finance Act). 

The  Slovenian  authorities  report  that  Article  14(1)  of  the  Directive  relating  to  publishing 
information on bodies and funds that do not form part of the regular budgets in the context of 
budgetary processes is transposed with the amended Public Finance Act, Article 9t(2). 

2. Independent fiscal institutions 

The Slovenian authorities report that Article 8a of the Directive relating to independent fiscal 
institutions is transposed with the Fiscal Rules Act as regards the functioning of the Slovenian 
Fiscal Council (Articles 7 to 10) and Article 9r of the amended Public Finance Act. 

3. Medium-term budgetary frameworks 

The Slovenian authorities report that Article 9 of the Directive relating to the medium-term 
budgetary framework is transposed with Article 5(1) of the Fiscal Rule Act and Article 9s of 
the amended Public Finance Act. 

The Slovenian authorities report that Article 10 of the Directive (relating to the consistency of 
annual  budget  legislation  with  the  national  budgetary  objectives)  is  transposed  with  Article 
13(3) of the amended Public Finance Act. 

The Slovenian authorities consider Article 11 of the Directive relating to updating medium-
term budgetary plans to reflect new policy priorities transposed with Article 11(6) of the Fiscal 
Rule Act. 

4. Reporting on disaster- and climate-related fiscal risks 

The  Slovenian  authorities  report  that  Article  9(2)(d)  of  the  Directive  (relating  to  assessing 
envisaged  policies  according  to  their  likely  impact  on  medium-term  and  long-term 
sustainability  of  the  public  finances  and  sustainable  and  inclusive  growth)  is  partially 
transposed  with  Article  9s(6)  of  the  amended  Public  Finance  Act.  Moreover,  they  plan  to 
include more specifications into the amendment of the national Regulation on Development 
Planning Documents and Procedures for the Preparation of the State Budget Proposal that will 
be prepared in 2025. 

The  Slovenian  authorities  indicate  that  Article  14(3)  of  the  Directive  relating  to  publishing 
relevant information on contingent liabilities is transposed with Article 9t(2) of the amended 
Public Finance Act. 

48 

 
 
5. Clarification amendments 

Regarding  transposing  the  amended  Article  2  of  the  Directive  relating  to  definitions,  the 
Slovenian authorities indicate that no transposition beyond enshrining the use of the ESA is 
planned. 

The Slovenian authorities indicate that  amendments to Article 4 of the Directive relating to 
fiscal  planning and forecasts  are  transposed with  Article 7(2)(5) of the Fiscal  Rule Act  and 
Articles 9r, 9s and 9š of the amended Public Finance Act. 

Regarding transposing Article 5(b) of the Directive relating  to  establishing  numerical  fiscal 
rules  promoting  the  adoption  of  a  medium-term  fiscal  planning  horizon,  the  Slovenian 
authorities more generally point to Article 5 having been transposed with Articles 3(1), 5(1) 
and 5(3) of the Fiscal Rule Act. 

Regarding  transposing  Article  6(2)  of  the  Directive  relating  to  escape  clauses  to  numerical 
fiscal rules, the Slovenian authorities more generally point to Article 6 having been transposed 
with Articles 2, 3, 7(1), 11(1) to 11(4) and12(1) of the Fiscal Rule Act. 

Slovenian authorities report that Article 7 of the Directive on the consistency of annual budget 
legislation with numerical fiscal rules is transposed with Article 13(3) of the amended Public 
Finance Act. 

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25 

Implementation of the main provisions of the Directive in SLOVAKIA 

Slovakia’s fiscal framework was established by the Act on the general government budget rules 
and amending certain other acts of 23 September 2004 (523/2004), by the Constitutional Law 
on  Budgetary  Responsibility  of  8  December  2011  (493/2011)  and  by  Act  583/2004  on 
budgetary rules of local  government. The Slovak authorities indicate that Act 523/2004 has 
been amended in 2024 in reaction to the new EU economic governance framework. In their 
reply, the Slovak authorities provide references to existing legal provisions and practices and 
indicate  their  intention  to  amend  by  the  third  quarter  of  2025  the  manual  for  the  rules  of 
budgetary frameworks to address the gaps that they have identified. 

1. Statistics, accounting, transparency 

The Slovak authorities report four different legal and non-legal acts covering the provisions for 
statistics and public accounting: (i) Act 523/2004 in force, (ii) Act 540/2001 in force, (iii) the 
measure  of  the  Slovak  Ministry  of  Finance  No.  017353/2017-352  on  the  submission  of 
accounting  information  and  data  in  force  and  (iv)  informs  that  the  Ministry  of  Finance 
publishes data according to the special SDDS standard or in the SDDS Plus standard on its 
website.  

In  the  Slovak’s  authorities’  interpretation,  the  amendments  to  the  Directive  transparency 
provision are covered by existing acts and practices, namely the Constitutional Act 493/2011, 
Act 523/2004 and the publication and update of relevant information on public administration 
entities on the website of the Slovak Statistical Office.  

The Slovak authorities indicate that existing acts, measures and practices cover the changes to 
the Directive provisions for statistics, public accounting and transparency. 

2. Independent fiscal institutions 

The Slovak authorities provide a list of existing acts and practices aimed to demonstrate the 
transposition of the Directive provisions for independent fiscal institutions: the Constitution of 
the Slovak Republic, the Act on the general government budget rules and amending certain 
other  acts  of  23  September  2004  (523/2004),  the  Constitutional  Law  on  Budgetary 
Responsibility of 8 December 2011 (493/2011), the Act 583/2004 on budgetary rules of local 
government  and  various  acts  on  the  registration  of  residence  of  citizens,  higher  education, 
employment  services,  old-age  and  supplementary  pension  savings,  social  services,  etc.  The 
authorites also make reference to the Statute of the Council for Budgetary Responsibility and 
provide  internet  links  to  the  published  assessments,  opinions  and  macroeconomic  and 
budgetary forecasts of the Council. 

The  Slovak  authorities  indicate  that  changes  to  the  manual  for  the  rules  for  budgetary 
frameworks  MF/012286/2020-421-part  I,  point  1,  letter  c)  are  under  preparation  with  an 
approval date planned for the third quarter of 2025.  

3. Medium-term budgetary frameworks 

The Slovak authorities make reference to two existing acts aimed to show how the transposition 
of the Directive provisions for medium-term budgetary frameworks is ensured: the Act on the 
General  Government  Budget  Rules  and  amending  certain  other  acts  of  23  September  2004 
(523/2004)  and  the  Constitutional  Law  on  Budgetary  Responsibility  of  8  December  2011 
(493/2011). 

50 

 
 
The  Slovak  authorities  indicate  that  the  changes  to  the  manual  for  the  rules  for  budgetary 
frameworks MF/012286/2020-421-part II, point 1 first sentence and letters b) and c) and to part 
II point 2 are under preparation with an approval date planned for the third quarter of 2025. 

4. Reporting on disaster- and climate-related fiscal risks 

The  Slovak  authorities  refer  to  two  existing  acts  and  a  measure  aimed  to  show  how  the 
transposition of the new Directive provisions set in Article 9(2)(d) and Article 14(3) is ensured: 
the  Act  on  the  general  government  budget  rules  and  amending  certain  other  acts  of  23 
September  2004  (523/2004)  and  the  Constitutional  Law  on  Budgetary  Responsibility  of  8 
December 2011 (493/2011). The measure of the Ministry of Finance of the Slovak Republic 
no.  25755/2007-31  (Table  10)  establishes  the  details  of  individual  financial  statements  for 
budegtary organisations, territorial units, State funds, municipalities, etc.  

The  Slovak  authorities  indicate  that  the  changes  to  the  manual  for  the  rules  for  budgetary 
frameworks  MF/012286/2020-421-part  II,  point  1  point  (c)  are  under  preparation  with  an 
approval date planned for the third quarter of 2025.  

5. Clarification amendments 

The Slovak authorities outline existing acts that are considered to ensure the transposition of 
the clarification amendments brought to the provisions of Directive 2011/85 and beyond. The 
list of acts includes the Act on the general government budget rules and amending certain other 
acts of 23 September 2004 (523/2004), the Constitutional Law on Budgetary Responsibility of 
8 December 2011 (493/2011), Act 540/2001, Act 583/2004, Act 345/2024, the measure of the 
Slovak Ministry of Finance No. 017353/2017-352 on the submission of accounting information 
and data are published by the Ministry of Finance according to the special SDDS or SDDS Plus 
standard on its website. In addition to these acts, the Slovak authorities provide links to the 
statutes of the Council for Budget Responsibility, of the Committee for Tax Forecasts and of 
the Committee for Macroeconomic Forecasts and links to the macroeconomic and tax forecasts 
and their assessemnts as published on the website of the Ministry fo Finance.  

The  authorities  also  signal  that  the  changes  to  the  manual  for  the  rules  for  budgetary 
frameworks MF/012286/2020-421-part I, point 1 letters a) and (c) are under preparation with 
an approval date planned for the third quarter of 2025. 

51 

 
 
 
 
26 

Implementation of the main provisions of the Directive in FINLAND 

The  Finnish  Ministry  of  Finance  reported  on  the  ongoing  reforms  to  the  Finnish  fiscal 
framework ahead of the transposition deadline on 31 December 2025.  

Two key new acts are currently being prepared in Finland, namely a new Fiscal Policy Act and 
a new Act on the Economic Policy Council. These imply a change to the main National Fiscal 
Rule, and a change in the institution responsible for the Independent Fiscal Institution tasks 
required by European legislation.  

1. Statistics, accounting, transparency 

The Ministry reports that Statistics Finland is the main body in charge of statistics in Finland. 
It is regulated by the General Statistics Act (280/2004), Finnish statistics are collected in line 
with  European  regulation  and  integrated,  comprehensive  and  nationally  harmonised  accrual 
accounting systems are in place for the public sector. 

2. Independent fiscal institutions 

The Ministry of Finance proposes to turn the Finnish Economic Policy Council (FEPC) into 
the official Finnish IFI responsible for EU tasks going forward. NAOF is the current IFI for 
Finland, but would be replaced by the FEPC. The FEPC will henceforth be responsible for all 
IFI  tasks  mandated  by  the  Directive.  NAOF’s  only  task  regarding  EU  legislation  will 
henceforth be the ex-post evaluation of the macroeconomic forecast.  

Finland  reports  that  the  Economics  Department  of  the  Ministry  of  Finance  produces  the 
independent macroeconomic forecast for Finland as regulated by the Fiscal Policy Act (section 
2a  (6.2.2015/79)).  Lessons  from  NAOF's  ex  post  evaluation  of  the  macroeconomic  and 
budgetary  forecasts  are  systematically  integrated  into  the  Economics  department  forecast 
process.  

The new Act on the Economic Policy Council is currently under development. The FEPC is 
affiliated to the VATT Institute of Economic Research and composed of a Chair and four other 
members  which  must  present  a  high  level  of  scientific  expertise  in  economics.  They  are 
appointed by the Government on a proposal by the  Ministry of Finance based on proposals 
from the economics units of Finnish universities. Their access to information is guaranteed by 
the  Act  on  the  Openness  of  Government  activities  (621/1999)  and  the  Administrative  Act 
(434/2003) and will be reinforced by a planned Memorandum of Understanding. The FEPC’s 
resources and external evaluations have not yet been discussed.  

Finally, the Ministry of Finance reports that the new Fiscal policy Act will include a Comply 
or Explain mechanism in the context of the correction mechanism of the new national fiscal 
rule. How the comply-or-explain principle is to be applied to the other tasks will be specified 
later.  

3. Medium-term budgetary frameworks 

The Ministry of Finance reports that the MTBF requirements will be transposed through the 
new Fiscal Policy Act and amendments to the Government Decree on General Government 
Fiscal Plan (120/2014). A new government will be required to prepare a medium-term fiscal-
structural plan for its term, as well as a General Government Fiscal Plan setting the target of 
the national fiscal rule.  

52 

 
 
4. Reporting on disaster- and climate-related fiscal risks 

The Ministry of Finance reports that the disaster- and climate-related fiscal risks requirements 
of the Council Directive 2024/1265/EU will be included in the Government Decree on General 
Government Fiscal Plan which will be amended as needed.  

5. Clarification amendments 

The Ministry of Finance considers that Articles 2-4 are already fully covered. The requirements 
of Articles 5 and 7 of the Council Directive 2024/1265/EU will be taken into account in the 
formulation of the new Fiscal Policy Act. The Ministry of Finance did not report on Article 6 
as Finland does not plan to have an escape clause for their newNational Fiscal Rule.  

53 

 
 
 
 
 
27 

Implementation of the main provisions of the Directive in SWEDEN 

Sweden  reports  that,  every  eight  years,  a  Parliamentary  Committee  reviews  the  Swedish 
national  fiscal  framework.  As  part  of  the  latest  review,  which  took  place  in  2024,  the 
Committee assessed the need for changes due to the requirements of the amended Directive. 
The Committee submitted its report in November 2024 and Sweden reports that its assessments 
and proposals are reflected in the reporting below. Sweden also reports that the follow-up from 
the Committee’s proposals is currently ongoing in the Government Offices, with the necessary 
changes planned to be implemented in the second half of 2025 in three types of legal acts: i) 
laws  decided  on  by  parliament,  ii)  a  decree  with  instructions  for  authorities  decided  by 
government and iii) a Framework Letter decided by parliament. The latter is a code of conduct 
that is passed through parliament and is only amended after an investigation by a Parliamentary 
Committee as described above. Sweden considers that the status of the Framework Letter is a 
legal document. 

1. Statistics, accounting, transparency 

Sweden considers that the main provisions are already in place. Sweden’s accounting of public 
finances  is  reported  to  be  subject  to  ESA2010  and  supplementary  national  regulation  is 
therefore said not to be necessary. In particular, Article 3(1) is covered by Statistics Sweden 
implementing ESA2010 in 2014. The fiscal data referred to in Article 3(2) is said to be reported 
in the annual Budget Bills, leaving open the reporting on a quarterly basis. Regarding Article 
14(1),  it  is  said  to  be  covered  by  Chapter  10  of  the  Budget  Act  and  the  information  to  be 
reported in the Budget Bills. 

2. Independent fiscal institutions 

Sweden  reports  that  planned  measures  mainly  consist  of  amending  government  decrees 
regarding  instructions  to  the  Fiscal  Policy  Council  (FPC)  and  that  any  changes  to  the 
instructions  to  the  FPC  connected  to  the  national  fiscal  policy  framework  are  tied  to  the 
Parliament through the Framework Letter. Sweden reports the planned amendments for Article 
8a(1),  (4)(a)  and  (d)  and  (5)(a)-(e).  Sweden  also  reports  that  amendments  will  be  made  to 
transpose  Article  8a(4)(c),  without  specifying  which  provision  in  the  legal  base  will  be 
amended. 

Sweden reports that the following provisions are already covered by existing legal acts: 

-  Article 8a(3) by paragraph 11 of the decree with instructions for the FPC. 
-  Article 8a(4)(b) by paragraph 9 of the decree with instructions for the FPC. 
-  Article 8a(4)(e) by the Framework Letter. Sweden reports that an inquiry should be 

appointed by the 31 December 2025 at the latest. 

Regarding Article 8a(4)(c), Sweden considers that the FPC is deemed capable of performing 
its new tasks resulting from the changes in the Directive within its existing budget. 

Sweden does not report any plans regarding the transposition of Article 8a(6). 

3. Medium-term budgetary frameworks 

Sweden considers that the necessary provisions are already in place according to the following: 

-  Article 2(1)(e) by Chapter 2 and Chapter 10(6) of the Budget Act. 
-  Article 9(2)(a) by Chapter 2 of the Budget Act and by the Framework Letter.  

54 

 
 
-  Article 9(2)(b) by Chapter 9 of the Budget Act. 
-  Article 9(2)(c) in the Budget Bills. 
-  Article 9(2)(d) by Chapter 10(4) of the Budget Act and paragraphs 4-5 of the Climate 

Act. Article 10 by Chapter 2(1)(a) of the Budget Act. 

4. Reporting on disaster- and climate-related fiscal risks 

Sweden considers that the necessary provisions are already in place according to the following: 

-  Article 9(2)(d) by Chapter 10(4) of the Budget Act and paragraphs 4-5 of the Climate 

Act.  

-  Article 14(3) by paragraph 26(f) of the decree with instructions for the National Debt 

Office. 

5. Clarification amendments 

Sweden reports that planned measures consist of amendments to the Budget Act according to 
the following:  

-  Article 2 by amendments to Chapter 2(1), Chapter 9(3), and Chapter 10(6) of the 
Budget Act, with the view to adapt these provisions to the concepts in ESA 2010. 

-  Article 4(1) by amendments to Chapter 9(3) (a new section) of the Budget Act. 
-  Article 4(6) by amendments to Chapter 9(5) of the Budget Act to clarify that the 

evaluation is to be carried out by an independent body. The FPC is reported to already 
perform this task according to Paragraph 7 of the decree with instructions for the FPC. 

Sweden reports that the following provisions are already covered by existing legal acts: 

-  Regarding Article 6(2), Sweden reports that there are no exemption clauses in the 

Swedish national fiscal policy framework. 
-  Article 7 by Chapter 2 of the Budget Act. 

55