COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Bulgaria Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 8091/22 INIT; ST 8091/22 ADD 1) of 4 May 2022 on the approval of the assessment of the recovery and resilience plan for Bulgaria
Date: 2025-07-02
Institutions: European Commission, Reform and Investment Task Force
Subjects: Bulgaria, EU aid, digital transformation, economic and social cohesion, economic recovery, economic reform, energy policy, green economy, investment, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 2.7.2025  SWD(2025) 179 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of  Bulgaria Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 8091/22 INIT; ST 8091/22 ADD 1) of 4 May 2022 on the approval of the assessment of the recovery and resilience plan for Bulgaria {COM(2025) 379 final}  
 
 
Table of contents 
1.  Summary of the assessment of the plan ................................................................................................ 2 

1.1.  The principle of ‘do no significant harm’ ..................................................................................... 2 

1.2.  Green transition ............................................................................................................................. 3 

2.3 

REPowerEU .................................................................................................................................. 4 

1 

 
 
 
 
 
 
 
 
 
 
 
1.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

State aid and competition rules fully apply to the measures funded by the Recovery and Resilience 
Facility. Union funds channelled through the authorities of Member States, like the RRF funds, 
become State resources and can constitute State aid. When this is the case and State aid is present, 
these measures must be notified and approved by the Commission before Member States can grant 
the aid, unless those measures are covered by an existing aid scheme or comply with the applicable 
conditions of a block exemption regulation, in particular the General Block Exemption Regulation 
(GBER) declaring certain categories of aid compatible with the internal market in application of 
Articles 107 and 108 TFEU1. When State aid is present and it requires notification, it is the duty 
of  the  Member  State  to  notify  State  aid  measures  to  the  Commission  before  granting  them,  in 
compliance with Article 108(3) TFEU. In this respect, the State aid analysis carried out Bulgaria 
in the recovery and resilience plan cannot be deemed a State aid notification. In as far as Bulgaria 
considers that a specific measure contained in the recovery and resilience plan entails de minimis 
aid or aid exempted from the notification requirement, it is the responsibility of Bulgaria to ensure 
full compliance with the applicable rules. 

1.1. The principle of ‘do no significant harm’  

The  modified  Bulgarian  recovery  and  resilience  plan  including  the  REPowerEU  chapter  is 
expected  to  continue  to  ensure  that  no  measure  included  in  the  plan  does  significant  harm  to 
environmental objectives, within the meaning of Article 17 of the Taxonomy Regulation.   

Bulgaria’s  REPowerEU  chapter  includes  a  systematic  assessment  of  each  measure  against  the 
principle of ‘do no significant harm’ (DNSH), for each of the six environmental objectives within 
the meaning of Article 17 of the Taxonomy Regulation. The assessment follows the methodology 
set out in the Commission’s technical guidance on the application of ‘do no significant harm’ under 
the Recovery and Resilience Facility Regulation (2021/C58/01). Based on information provided 
by Bulgaria, there is either no risk of significant harm, or where a risk is identified, a more detailed 
assessment is performed demonstrating the absence of significant harm.  

While  Bulgaria’s  assessment  stresses  the  positive  impact  mainly  on  climate  objectives,  it  also 
provides  information  allowing  to  assess  that  measures  will  comply  with  the  ‘do  no  significant 
harm’ principle.  

The measures included in the REPowerEU chapter comply with the DNSH principle. None of the 
measures included in the REPowerEU chapter requires a DNSH derogation or the introduction of 
specific  DNSH  conditions  in  the  milestones  and  targets. The  investment  in  electricity  storage 

1 Commission Regulation (EU) 2023/1315 of 23 June 2023 amending Regulation (EU) No 651/2014 declaring certain 
categories  of  aid  compatible  with  the  internal  market  in  application  of  Articles  107  and  108  of  the  Treaty  and 
Regulation (EU) 2022/2473 declaring certain categories of aid to undertakings active in the production, processing 
and marketing of fishery and aquaculture products compatible with the internal market in application of Articles 107 
and  108  of 
the  Treaty,  OJ  L  167,  30.6.2023,  p.  1–90,  available  at:  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1315.  

2 

 
 
 
 
 
 
 
(investment 2) is a scale-up of the existing investment 8 of component 4, for which the assessment 
of compliance with DNSH remains unchanged. As regards the deployment of photovoltaic systems 
and electric vehicles for the provision of social services (investment 3), Bulgaria confirmed that 
only  zero-emission  vehicles  will  be  supported,  and  stated  that  the  installation  of  photovoltaic 
systems in existing buildings has the potential to reduce the use of energy, produced from non-
renewable energy sources, increase energy efficiency, and significantly reduce GHG emissions 
due  to  not  use  of  fossil  fuels  for  energy  production.  Investment  4  concerning  support  for  new 
capacities for electricity generation from  renewable sources and electricity storage was already 
included in the RRP as investment 6 of component 4 Low carbon economy; the assessment of 
compliance  with  the  DNSH  principle  remains  unchanged.  The  investment  concerning  the 
establishment of an information system on energy poor and vulnerable households (investment 1) 
is expected to pose no to very low risk for the environment.  

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation of reforms and investments projects included in Bulgaria’s REPowerEU chapter 
is expected to do a significant harm to environmental objectives within the meaning of Article 17 
of Regulation (EU) No 2020/852 (the principle of ‘do no significant harm’). This warrants a rating 
of A under the assessment criterion 2.4 of Annex V to the RRF Regulation. 

*** 

The nature and extent of the proposed modifications to Bulgaria’s recovery and resilience plan do 
not  have  a  material  impact  on  the  previous  assessment  (rating  of  A)  that  no  measure  for  the 
implementation  of  reforms  and  investment  projects  included  in  the  plan  is  expected  to  do  a 
significant harm to environmental objectives within the meaning of Article 17 of Regulation (EU) 
No 2020/852 (the principle of ‘do no significant harm’), as reflected in the previous SWD (2022) 
106 final.  

1.2. Green transition 

The  modified  recovery  and  resilience  plan  including  the  REPowerEU  measures  continues  to 
significantly contribute to the green transition, including biodiversity, as well as to the achievement 
of the Union 2030 climate targets while complying with the objective of EU climate neutrality by 
2050.  

All the measures in the REPowerEU chapter are expected to significantly contribute to the green 
transition  as  well  as  to  the  achievement  of  the  Union  2030  climate  targets  and  of  EU  climate 
neutrality by 2050.  Moreover, the measures included in the REPowerEU chapter address three out 
of the six objectives pursued by the Regulation.  

Under the REPowerEU chapter, reform 1 and investment 1 contribute to addressing energy poverty 
by  strengthening  the  governance  framework  for  energy  poverty  and  by  facilitating  the 
identification of energy poor and energy vulnerable consumers. By increasing the transparency of 
connection  procedures  for  renewables,  reform  2  is  expected  to  facilitate  and  accelerate  the 
deployment of renewables. Reform 3 contributes to addressing internal and cross-border energy 

3 

 
 
 
 
 
transmission and distribution bottlenecks by improving the functioning of the balancing market in 
Bulgaria. Furthermore, one investment is scaled up to further support grid-size electricity storage 
(investment 2) and thereby facilitate the integration of renewable energy sources. One investment 
included is contributing both to accelerating the deployment of renewable energy and supporting 
zero-emission transport by supporting the uptake of electric vehicles and the associated recharging 
infrastructure (investment 3). Finally, investment 4 which was previously included as investment 
6  in  component  4  Low  carbon  economy  contributes  to  supporting  electricity  storage  and 
accelerating the integration of renewable energy sources.    

All the new or modified measures are expected to have a long-term impact.    

Climate target 

On  the  basis  of  the  assessment  guidelines  provided  for  sub-criterion  5b,  the  measures  in  the 
modified RRP (including the REPowerEU chapter) supporting climate change objectives account 
for 49.9% of the plan’s maximum financial contribution (i.e. above the 37% required), based on 
the  methodology  for  climate  tracking  set  out  in  Annex  VI  to  the  RRF  Regulation.  The  most 
important contributions to this target are the investments in renewable energy, electricity storage, 
sustainable renovation of buildings, circular economy and sustainable mobility. Additionally, the 
proposed measures within the REPowerEU chapter supporting climate change objectives account 
for 99.5% of the chapter’s total estimated costs, based on the methodology for climate tracking set 
out in Annex VI to the RRF Regulation.   

*** 

Taking into consideration the assessment of all the measures envisaged, the modified recovery and 
resilience  plan,  including  its  REPowerEU  chapter,  is  expected,  to  a  large  extent,  to  make  a 
significant contribution to the green transition or to address the challenges resulting from it and 
ensures that at least 37% of its total allocation contributes to the climate target. At least 37% of 
the total estimated costs of the REPowerEU chapter contribute to the climate target. This would 
warrant a rating of A under criterion 2.5 of Annex V to the RRF Regulation.  

1.3. REPowerEU 

In particular, there are synergies with reform 8 of Component 4 concerning the liberalisation of 
the electricity market. 

Reform  2  on  enhancing  the  transparency  of  grid  connection  procedures  is  expected  to 
contribute to the REPowerEU objective to facilitate and accelerate the deployment of renewables. 
Reform 2 is coherent with other efforts of Bulgaria. In particular, there are synergies with reforms 
and investments in Component 4 aiming to accelerate the deployment of renewable electricity in 
Bulgaria.  

Reform  3  on  improving  the  functioning  of  the  balancing  market  and  enabling  demand-
response contributes to the REPowerEU objective to address energy transmission and distribution 
bottlenecks. Reform 3 is coherent with other efforts of Bulgaria. In particular, there are synergies 
with existing investments in electricity storage under Component 4 and the REPowerEU chapter.  

4 

 
 
 
 
 
Investment 2 on support for grid-size electricity storage (scaled-up) is expected contribute to 
the  REPowerEU  objective  of  supporting  electricity  storage  and  accelerating  the  integration  of 
renewable  energy  sources.  Investment  2  will  complement  the  existing  C4.I8  ‘National 
infrastructure  for  storage  of  electricity  from  renewables  (RESTORE)’  with  the  deployment  of 
additional electricity storage capacity. In particular, it is expected to result in additional 1500 MWh 
of usable energy capacity. Investment 2 is coherent with other efforts of Bulgaria. In particular, 
there are synergies with existing investment 8 under Component 4.  

Investment  3  concerning  the  installation  of  photovoltaic  systems  and provision  of  electric 
vehicles for social service facilities contributes to the REPowerEU objectives to support zero-
emission transport and to accelerate the deployment of renewable energy. Investment 3 is coherent 
with other efforts of Bulgaria. In particular, there are synergies with measures under Component 
4.  

Investment  4  concerning  support  for  new  capacities  for  electricity  generation  from 
renewable  sources  and  electricity  storage  contributes  to  the  REPowerEU  objectives  of 
supporting  electricity  storage  and  accelerating  the  integration  of  renewable  energy  sources. 
Investment  4  is  coherent  with  other  efforts  of  Bulgaria.  In  particular,  there  are  synergies  with 
reforms  and  investments  supporting  the  deployment  of  electricity  from  renewable  sources  in 
Component 4 and in the REPowerEU chapter.  

As part of the preparation of its REPowerEU chapter, Bulgaria made a draft version of the chapter 
public on the official website of the National Recovery and Resilience Plan.  

***  

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged  in  the  REPowerEU 
chapter, the chapter is expected, to a large extent, to contribute effectively to energy security, the 
diversification of the Union’s energy supply, an increase in the uptake of renewables and energy 
efficient, an increase of energy storage capacities or the necessary reduction of dependence on 
fossil fuels before 2030. This would warrant a rating of A under criterion 2.12 of Annex V to the 
RRF Regulation.   

5 

 
 
 
 
 
   
 
ANNEX I Updated climate tracking and digital tagging of the Recovery and Resilience 
Plan of Bulgaria 

The table below presents the detailed application of the climate tracking and digital tagging 
methodologies set out respectively in Annex VI and VII to Regulation (EU) 2021/241 in the 
modified Bulgarian recovery and resilience plan. 

Int. Field = intervention field. 

Coeff. = Coefficient for the calculation of support to climate change objectives and to digital 
transition, on the basis of Annex VI and Annex VII of the RRF Regulation. 

Revised measures are marked in yellow to distinguish them from the unchanged measures in the 
RRP. 

Measure
/ Sub-
Measure 
ID 

BG-
C[C1]-
I[I1.b] 

BG-
C[C1]-
I[I2.a] 

BG-
C[C1]-
I[I2.b] 

BG-
C[C1]-
I[I2.c] 

BG-
C[C1]-
I[I3] 

BG-
C[C1]-
I[I4] 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Climate 

Digital 

Int. 
Field 

Coeff. 
% 

Int. Field 

Coeff. 
% 

STEM centres and innovation in 
education - digitalisation 

Modernisation of educational 
infrastructures - renovated 
schools/kindergartens 

Modernisation of educational 
infrastructures - new 
schools/kindergartens 

Modernisation of educational 
infrastructures - renovated student 
residences 

Provision of digital skills trainings 
and set-up of a platform for adult 
learning 

108 

100% 

120.45 

181.63 

026 

40% 

27.99 

025ter 

40% 

61.59 

026 

40% 

116.06 

012 

100% 

Youth centres 

27.51 

099 

40% 

6 

 
 
 
 
 
 
 
  
  
 
  
 
  
  
  
  
  
  
  
  
Measure
/ Sub-
Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Climate 

Digital 

Int. 
Field 

Coeff. 
% 

Int. Field 

Coeff. 
% 

BG-
C[C2]-
I[I1.a] 

BG-
C[C2]-
I[I2.a] 

BG-
C[C2]-
I[I2.b] 

BG-
C[C2]-
I[I2.d] 

BG-
C[C2]-
I[I2.e] 

BG-
C[C3]-
I[I2.d] 

BG-
C[C3]-
I[I2.f] 

BG-
C[C3]-
I[I2.g] 

Programme to accelerate economic 
recovery and transformation through 
research and innovation - digital 
objectives 

Enhancing the innovation capacity 
of the Bulgarian Academy of 
Sciences - digital 

Enhancing the innovation capacity 
of the Bulgarian Academy of 
Sciences - quantum platform 

Enhancing the innovation capacity 
of the Bulgarian Academy of 
Sciences 

- technology transfer 

Enhancing the innovation capacity 
of the Bulgarian Academy of 
Sciences 

- trainings 

Economic Transformation 
Programme — Fund 1 Growth and 
Innovation: Grant scheme for 
information and communication 
technology and cybersecurity in 
SMEs 

Economic Transformation 
Programme - Fund 2 Green 
Transition and Circular Economy: 
Grant scheme for investments in 
renewable electricity sources for 
own use with local storage facilities 

Economic Transformation 
Programme — Fund 2 Green 
Transition and Circular Economy: 
Grant scheme for the support of 
businesses in the transition to a 
circular economy 

22.04 

021 

40% 

2.58 

0.51 

052 

100% 

021quater 

100% 

8.18 

022 

100% 

1.67 

009bis 

100% 

14.10 

010 

100% 

52.00 

033 

100% 

73.62 

047 

40% 

7 

 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
  
  
  
  
  
  
Measure
/ Sub-
Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Climate 

Digital 

Int. 
Field 

Coeff. 
% 

Int. Field 

Coeff. 
% 

BG-
C[C3]-
I[I2.h] 

BG-
C[C3]-
I[I2.i] 

BG-
C[C3]-
I[I2.j] 

BG-
C[C3]-
I[I2.k] 

BG-
C[C4]-
I[I1.a] 

BG-
C[C4]-
I[I1.b] 

BG-
C[C4]-
I[I1.c] 

Economic Transformation 
Programme — Fund 2 Green 
Transition and Circular Economy: 
Grant scheme for the support of 
businesses in the transition to a 
circular economy 

Economic Transformation 
Programme — Fund 2 Green 
Transition and Circular Economy: 
Guarantee financial instrument for 
energy efficiency and renewable 
energy 

Economic Transformation 
Programme — Fund 2 Green 
Transition and Circular Economy: 
Guarantee financial instrument for 
energy efficiency and renewable 
energy 

Economic Transformation 
Programme — Fund 3 Investments 
in Climate Neutrality and Digital 
Transformation: Equity instruments 
for climate neutrality and digital 
transformation investments 

18.41 

047bis 

40% 

37.5 

024 

40% 

37.5 

025 

40% 

30 

024 

40% 

Support for the renovation of 
building stock - residential buildings 

366.08 

025bis 

100% 

Support for the renovation of 
building stock - public buildings 

165.48 

026bis 

100% 

Support for the renovation of 
building stock - manufacturing and 
commercial buildings - buildings in 
manufacturing, trade and services, 
as well as buildings from the 
tourism sector 

105.11 

024ter 

100% 

8 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure
/ Sub-
Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Climate 

Digital 

Int. 
Field 

Coeff. 
% 

Int. Field 

Coeff. 
% 

BG-
C[C4]-
I[I2] 

BG-
C[C4]-
I[I3] 

BG-
C[C4]-
I[I4] 

BG-
C[C4]-
I[I7] 

BG-
C[C4]-
I[I8] 

BG-
C[C6]-
I[I1.a] 

BG-
C[C6]-
I[I2] 

BG-
C[C7]-
I[I1] 

BG-
C[C7]-
I[I2] 

BG-
C[C8]-
I[I1.a] 

BG-
C[C8]-
I[I1.b] 

Support for renewable energy for 
households 

11.44 

029 

100% 

Support for energy-efficient street 
lighting systems 

69.60 

026bis 

100% 

Digital transformation of the 
electricity transmission grid 

189.18 

033 

100% 

033 

40% 

Pilot project on combined heat and 
power from geothermal sources 

2.95 

032 

100% 

National infrastructure for storage of 
electricity from renewables 
(RESTORE) 

Fund to promote the technological 
and ecological transition of 
agriculture — ‘technological and 
environmental modernisation’ 
strand 

603.31 

033 

100% 

033 

40% 

192.62 

047 

40% 

020  

40%  

Digitisation of processes from farm 
to fork 

10.20 

Large-scale deployment of digital 
infrastructure 

269.59 

011 

100% 

051 

100% 

Construction, development and 
optimisation of the digital TETRA 
system and radio network 

63.66 

011 

100% 

Railways rolling stock — ERTMS 

16.62 

071 

40% 

071 

100% 

Railways rolling stock – rolling 
stock 

405.06 

072bis 

100% 

9 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Measure
/ Sub-
Measure 
ID 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Climate 

Digital 

Int. 
Field 

Coeff. 
% 

Int. Field 

Coeff. 
% 

BG-
C[C8]-
I[I5.a] 

BG-
C[C8]-
I[I6.a] 

BG-
C[C8]-
I[I6.b] 

BG-
C[C8]-
I[I10] 

BG-
C[C8]-
I[I7.a] 

BG-
C[C8]-
I[I7.b] 

BG-
C[C8]-
I[I7.c] 

BG-
C[C8]-
I[I7.d] 

BG-
C[C8]-
I[I8] 

 BG-
C[C8]-
I[I9] 

Road safety - Digitalisation 

0.64 

063 

100% 

Sofia metro line 3 – ERTMS 

19.89 

071 

100% 

Sofia metro line 3 

124.46 

073 

100% 

New rolling stock for the Sofia 
Metro 

43.16 

074 

100% 

Green mobility — Pilot scheme to 
support sustainable urban mobility - 
rolling stock 

Green Mobility — Pilot scheme to 
support sustainable urban mobility - 
integrated route systems 

Green mobility — Pilot scheme to 
support sustainable urban mobility - 
recharging points 

Green Mobility — Pilot scheme to 
support sustainable urban mobility - 
Cycling infrastructure 

Equipment for monitoring and 
maintenance of railway tracks and 
overhead lines 

39.06 

074 

100% 

2.54 

076 

100% 

2.44 

077 

100% 

5.96 

075 

100% 

99.84 

069 

40% 

Renovation of railway infrastructure 

82.83 

067 

100% 

BG-
C[C10]-
I[I1] 

Strengthening, further developing 
and building on the Unified 
Information System of Courts 

9.88 

011 

100% 

10 

 
 
 
 
 
  
  
 
 
  
  
 
 
  
  
  
  
  
  
  
  
 
 
 
 
  
  
Measure
/ Sub-
Measure 
ID 

BG-
C[C10]-
I[I2] 

BG-
C[C10]-
I[I3] 

BG-
C[C10]-
I[I4a] 

BG-
C[C10]-
I[I6] 

BG-
C[C10]-
I[I7] 

BG-
C[C10]-
I[I10] 

BG-
C[C10]-
I[I11.a] 

BG-
C[C11]-
I[I4.b] 

BG-
C[C11]-
I[I4.c] 

BG-
C[C11]-
I[I5.a] 

BG-
C[C11]-
I[I5.b] 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Climate 

Digital 

Int. 
Field 

Coeff. 
% 

Int. Field 

Coeff. 
% 

Digitalisation of key litigation 
processes in administrative justice 

3.64 

Transformation of the information 
and communication infrastructure at 
the Public Prosecutor’s Office 

Improving the quality and 
sustainability of the security 
services - digitalisation 

Supporting a pilot phase for the 
introduction of Building Information 
Modelling 

Unified Information System for 
Spatial Planning, Investment Design 
and Building Authorisation 

14.71 

25.18 

3.98 

1.76 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

Upgraded strategic planning system 

0.73 

011 

100% 

Ensuring an adequate information 
and administrative environment for 
the implementation of the recovery 
and resilience plan 

Modernisation of the Social 
Assistance Agency - energy 
efficiency 

Modernisation of the Social 
Assistance Agency - digital 
component 

3.51 

011 

100% 

1.55 

026 

40% 

1.45 

011 

100% 

Modernisation of the Employment 
Agency – energy efficiency 

0.1 

026 

40% 

Modernisation of the Employment 
Agency - digital component 

9.85 

011 

100% 

11 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
 
 
  
  
  
  
  
  
  
  
Measure
/ Sub-
Measure 
ID 

BG-
C[C11]-
I[I7] 

BG-
C[C12]-
I[I5] 

BG-
C[C12]-
I[I7.c] 

BG-
C[C13]-
I[I2] 

BG-
C[C13]-
I[I3] 

BG-
C[C13]-
I[I4] 

Measure/Sub-Measure Name 

Budget 
(EUR m) 

Climate 

Digital 

Int. 
Field 

Coeff. 
% 

Int. Field 

Coeff. 
% 

Digitisation of collections of 
museums, libraries, and archives 

National digital platform for 
medical diagnostics 

Development of outpatient care - 
Digitalisation 

Scaled-up measure: National 
infrastructure for storage of 
electricity from renewables 
(RESTORE) 

Installation of Photovoltaic Systems 
and Provision of Electric Vehicles 
for Social Services Facilities 

Support for new capacities for 
electricity generation from 
renewable sources and electricity 
storage 

23.52 

12.05 

6.65 

021bis 

100% 

095 

100% 

095 

100% 

120.66 

033 

100% 

33.09 

029 

100% 

342 

032 

100% 

* Reforms and investments in the REPowerEU chapter are not taken into account when 
calculating the plan’s contribution to the digital target requirement set by Regulation (EU) 
2021/241. 

12