COMMISSION STAFF WORKING DOCUMENT EVALUATION Accompanying the document Proposal of a Council Regulation establishing the nuclear decommissioning assistance programme of the Ignalina nuclear power plant in Lithuania for the period 2028-2034, and repealing Regulation (EU) 2021/101
Date: 2025-09-03
Institutions: Directorate-General for Energy, European Commission
Subjects: EU programme, Lithuania, Utena county, decommissioning of power stations, nuclear policy, nuclear power station, nuclear safety, principle of additionality, radioactive waste, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 3.9.2025  SWD(2025) 255 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION            Accompanying the document Proposal of a Council Regulation establishing the nuclear decommissioning assistance programme of the Ignalina nuclear power plant in Lithuania for the period 2028-2034, and repealing Regulation (EU) 2021/101 {COM(2025) 476 final} - {SWD(2025) 256 final}  
 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ..................................... 3 

1.1.  Scope and context ......................................................................................................... 3 
1.2.  Lessons learnt from previous programme..................................................................... 6 

2.  THE OBJECTIVES ..................................................................................................... 8 

2.1.  Challenges for the programme in the next MFF ........................................................... 8 
2.2.  Objectives of the programme in the next MFF ............................................................. 9 
2.2.1.  General objectives .............................................................................................................. 9 

2.2.2. 

Specific objectives ............................................................................................................. 9 

3.  PROGRAMME STRUCTURE AND PRIORITIES ................................................. 10 

4.  DELIVERY MECHANISMS OF THE INTENDED FUNDING ............................ 11 

4.1.  Policy option 1 – Discontinuation of the Ignalina programme ................................... 12 
4.2.  Policy option 2 – Ignalina programme implemented via shared management 

instruments .................................................................................................................. 13 
4.3.  Policy option 3 – Ignalina programme as dedicated spending programme ................ 14 
4.4.  Policy options benchmark ........................................................................................... 15 

5.  HOW WILL PERFORMANCE BE MONITORED AND EVALUATED? ............ 15 

5.1.  Programming, monitoring, reporting and evaluation .................................................. 15 
5.2.  Performance indicators ............................................................................................... 15 
5.3.  Preliminary evaluation criteria .................................................................................... 16 

1 

 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

CPMA 

EBRD 

ECA 

EVM 

IIDSF 

INPP 

KPI 

MFF 

NPP 

RBMK 

Central Project Management Agency (Lithuania) 

European Bank for Reconstruction and Development 

European Court of Auditors 

Earned Value Management 

Ignalina International Decommissioning Support Fund 

Ignalina Nuclear Power Plant 

Key Performance Indicator 

Multi-annual Financial Framework 

Nuclear Power Plant 

Реактор Большой Мощности Канальный / Reaktor Bolshoy 
Moshchnosti Kanalnyy (“High Power Channel-type Reactor”) is a 
class of graphite-moderated nuclear power reactor designed and 
built by the Soviet Union (e.g. Chernobyl nuclear power plant, 
Ignalina nuclear power plant) 

2 

 
 
 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1. 

Scope and context 

The present ex-ante evaluation relates to the Ignalina programme (the ‘programme’) whereby the 
European Union (EU) provides financial support to Lithuania to decommission the two RBMK-
1500 reactors of the Ignalina nuclear power plant (NPP) located near the town of Visaginas, cf. 
Figure 1. The decommissioning of these reactors – same model as in Chernobyl – is a first-of-a-
kind activity entailing technological challenges such as the dismantling of graphite cores and the 
subsequent management of important amounts of irradiated graphite. 

Figure 1 – Ignalina nuclear power plant site. 

The programme originated in the context of the negotiations for accession to the European Union 
of  Lithuania,  which  took  the  commitment  to  close  and  subsequently  decommission  the  two 
Soviet-designed  nuclear  reactors  by  a  commonly  agreed  date.  As  an  act  of  solidarity,  the 
European  Union  committed  itself  to  provide  financial  assistance  for  the  decommissioning  of 
Ignalina Nuclear Power Plant. The closure commitment of Lithuania as well as the commitment 
of  the  EU  to  provide  financial  support  was  foreseen  in  the  Lithuania's  Accession  Treaty1 
(Lithuania acceded in 2004). 

Lithuania has fulfilled its accession treaty commitment to close its reactors in a timely manner2. 
Based on the provisions of Lithuania's Accession Treaty3, the Council of the European Union has 
adopted as of 2006 successive Regulations4,5 for the implementation of the decommissioning. 

1  
2  
3  

OJ L 236, 23.9.2003, p. 33 and p. 944. 
Ignalina NPP Unit 1 was shut down in 2004 and Unit 2 was shut down in 2009. 
Article 3.1 ‘Recognising that the decommissioning of the Ignalina Nuclear Power Plant is of a long-term nature 
and  represents  for  Lithuania  an  exceptional  financial  burden  not  commensurate  with  its  size  and  economic 
strength, the Union shall, in solidarity with Lithuania, provide adequate additional Community assistance to the 

3 

IgnalinaNPPLithuania 
 
 
 
This  ex-ante  evaluation  is  carried  out  in  preparation  of  the  next  MFF,  and  it  is  based  on  the 
lessons  learnt  and  progress  achieved  so  far.  The  assessment  of  policy  options  is  not  strictly 
required for an ex-ante evaluation. However, a main purpose of this evaluation is to examine if 
the existing instrument should be: 

(i) 

(ii) 

discontinued in the next MFF, or 

merged into other shared management instruments, or 

(iii) 

continued as a dedicated programme. 

Originally and until 2013, the European Union assistance was designed to support Lithuania both 
in  its  efforts  to  shut  down  and  decommission  the  concerned  reactors,  but  also  to  address  the 
consequences of early closure of its nuclear power plant installation. The assistance covered thus 
actions such as enhancement of security of supply and energy efficiency. This changed as of the 
MFF 2014-2020, when the scope of the programme was restricted to decommissioning activities 
only, i.e. on safety related measures. The disposal of spent fuel and radioactive waste in a deep 
geological repository was never part of the programme. This shift from financing a complex mix 
of  energy  and  decommissioning  projects  towards  a  dedicated  and  focused  effort  on  the 
decommissioning programme resulted in increased effectiveness and efficiency. 

For the MFF 2021-2027, the programme objectives were specified as follows: 

a.  dismantling  and  decontamination  of  the  reactor  shafts  top  and  bottom  zones  in 

accordance with the decommissioning plan; 

b. 

the  design  for  the  dismantling  and  decontamination  of  the  reactor  shafts  central  zones 
(graphite cores);  

c.  safe management of the decommissioning and legacy waste up to interim storage or to 
disposal  (depending  on  the  waste  category),  including  the  completion  of  the  waste 
management  infrastructure  where  necessary,  in  accordance  with  the  decommissioning 
plan;  

d.  downgrading of radiological hazards. 

Under the implementing procedures6 of the MFF 2014-2020 the baseline (decommissioning plan) 
of  the  programme  was  set  out  up  to  the  respective  end-state  and  specific  objectives  were 
provided. 

The European Union financial assistance has been implemented by indirect management7 since 
its inception. It has been made available through pillar-assessed entrusted entities in the form of 
contributions to: 

decommissioning effort beyond 2006.’ Article 3.2 ‘The Ignalina Programme will be, for this purpose, seamlessly 
continued  and  extended  beyond  2006.  Implementing  provisions  for  the  extended  Ignalina  Programme  shall  be 
decided […] and enter into force, at the latest, by the date of expiry of the current Financial Perspective. […]’ 
Article  3.4 ‘For  the  period  of  the  next  Financial  Perspectives,  the  overall  average  appropriations  under  the 
extended  Ignalina  Programme  shall  be  appropriate.  Programming  of  these  resources  will  be  based  on  actual 
payment needs and absorption capacity.’ (2003 Act of  accession, Protocol No 4 on the Ignalina nuclear power 
plant in Lithuania (OJ L 236, 23.9.2003)). 
Council Regulation (EC) No 1990/2006 of 21 December 2006 on the implementation of Protocol No 4 on the 
Ignalina nuclear power plant in Lithuania to the Act of accession of the Czech Republic, Estonia, Cyprus, Latvia, 
Lithuania, Hungary, Malta, Poland, Slovenia and Slovakia, "Ignalina Programme" (OJ L 411, 30.12.2006, p.10). 
Council  Regulation  (EU)  No  1369/2013  of  13  December  2013  on  Union  support  for  the  nuclear 
decommissioning assistance programme in Lithuania (OJ L 346, 20.12.2013, p.7). Council Regulation (EU) No 
101/2021 January 2021on Union support for the nuclear decommissioning assistance programme in Lithuania. 
Commission  Implementing  Decision  of  7.8.2014  on  the  rules  of  application  for  the  nuclear  decommissioning 
assistance programmes for Bulgaria, Lithuania and Slovakia for the period 2014-2020, C(2014) 5449 final. 

4 

5  

6  

4 

 
 
(i) 

the  Ignalina  International  Decommissioning  Support  Fund  (IIDSF)  managed  by  the 
European Bank for Reconstruction and Development (EBRD) since 2001; 

(ii) 

the Central Project Management Agency (CPMA) since 2003. 

The total financial assistance from the European Union to Lithuania for the decommissioning of 
the  concerned  reactors  as  well  as  for  mitigation  measures  in  the  energy  sector  until  the  end  of 
2027  will  sum  up  to  EUR  2.2  billion.  Thereof,  EU  assistance  earmarked  for  decommissioning 
activities of the two reactors until the end of 2027 will sum up to EUR 1.9 billion. 

The  current  final  decommissioning  plan  (baseline)  was  approved  by  Lithuanian  government  in 
2020, and it is under revision in line with the national legislative framework. The plan sets out 
the  schedule  (covering  a  timespan  longer  than  the  MFFs)  and  the  cost  estimates  for  the 
decommissioning  activities  until  the  accomplishment  of  a  well-established  end-state.  Funding 
provided  in  the MFF 2021-2027  is  fit for  effective  and  efficient  accomplishment  of the  related 
objectives.  

The EU budget should enable a Europe that is safe and secure, and this is a dimension where the 
Ignalina programme has contributed so far and may further contribute. The main positive impact 
to  be  achieved  is  indeed  the  progressive  decrease  of  the  level  of  radiological  hazard  for  the 
workers,  the  public  and  the  environment,  in  Lithuania  but  also  in  the  EU  as  a  whole  and  to 
achieve  these  goals  nuclear  decommissioning  and  waste  management  are  key  processes  of  a 
modern, clean and circular economy. 

Like  all  existing  EU  instruments,  the  programme  needs  to  undergo  the  EU  value  added  test  in 
line  with  the  requirements  set  out  by  the  EU  Financial  Regulation  2024/25098  and  the  Better 
regulation guidelines9. As reflected in the list of options, consideration is hereby given whether 
the  programme  remains  indispensable  or  whether  there  is  scope  for  merging  programmes  or 
modifying  them  with a view  to  budgetary  flexibility and/or simplification,  which  are other  key 
principles underpinning the next MFF.  

The Ignalina programme attracted the attention of both the European Parliament and the Council 
of the European Union in the past. Both bodies intervened specifically on the  programme after 
the publication of the dedicated ECA Special Report10. 

The  European  Parliament11  underlined  that  nuclear  safety  is  of  prime  importance,  not  only  for 
Lithuania but for the population in the whole Union and its neighbourhood and called upon the 
Commission  to  perform  a  thorough  assessment  of  the  needs  for  continuation  of  the  dedicated 
funding  programme  for  nuclear  decommissioning  in  Lithuania  beyond  2020.  It  underlined 
furthermore that the closure of Ignalina nuclear power plant was a condition placed by the Union 
on  the  accession  of  Lithuania  in  exchange  for  Union  support  for  its  closure,  decommissioning 
and mitigation of the social and economic impacts (as defined in Protocol No. 4 of the Accession 
Treaty1).  

The  Council12  also  recalled  that  the  early  closure  and  subsequent  decommissioning  of  the  two 
Soviet-designed nuclear reactors in Lithuania was one of the conditions for accession to the EU. 

7  

8  

Article 60, Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council of 23 September 
2024 on the financial rules applicable to the general budget of the Union (recast), OJ L, 2024/2509, 26.9.2024. 
Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council of 23 September 2024 on 
the financial rules applicable to the general budget of the Union (recast), OJ L, 2024/2509, 26.9.2024. 
Better regulation guidelines, Commission staff working document, SWD(2021)305 final. 

9  
10   ECA Special Report 22/2016 – EU nuclear decommissioning assistance programmes in Lithuania, Bulgaria and 

Slovakia: some progress made since 2011, but critical challenges ahead. 

11   Committee  on  Budgetary  Control  "Report on  the  Court  of  Auditors’  special  reports  in  the  context  of  the 2015 

12 

Commission discharge" (2016/2208(DEC)). 
Council conclusions on the ECA Special Report No 22/2016, adopted by the Council at its 3511th meeting held 
on 13 December 2016 (document n° 15534/16 ATO 68). 

5 

 
 
It further underlined the fact that this condition entailed a significant financial burden based on 
which the  EU  agreed  to  provide  financial assistance. It  also  underscored the  need  for  adequate 
supporting actions for the decommissioning of Ignalina nuclear power plant to ensure successful 
completion of the decommissioning processes whilst maintaining a high level of nuclear safety. 
Finally, it noted that any potential new EU funding beyond 2020 should include clear rules and 
the right incentives to pursue decommissioning, with regard to both financing and timing. 

The  decommissioning  activities  have  steadily  progressed.  Nuclear  safety  remains  of  prime 
importance and the boundary conditions have not changed. 

1.2.  Lessons learnt from previous programme 

An  interim  evaluation  of  the  programme  was  conducted  in  line  with  the  Better  Regulation 
guidelines. The interim evaluation considered and assessed the results and impacts, the efficiency 
of the use of resources and its Union added value.  The evaluation focused on the period 2021-
2024 and considered, where relevant, also the previous financial framework (2014-2020). 

For the interim evaluation the Commission gathered relevant information and data by extensively 
involving key stakeholders (i.e. Ministries, implementing bodies, decommissioning operators).  

The main conclusions of the programme interim evaluation were: 

Coherence with EU policies. The programme is coherent with EU policies aiming at ensuring 
the  highest  level  of  nuclear  safety.  The  EU  support  ensures  that  the  immediate  dismantling 
strategy in Lithuania is steadily pursued and prevents that undue burden is transferred to future 
generations, while for historical reasons it partially derogates to the ultimate responsibility of the 
Member  State  to  ensure  adequate  financial  resources  for  nuclear  decommissioning  and 
radioactive waste management. 

Progress.  In  line  with  expectations  set  for  the  MFF  2021-2027,  Lithuania  has  progressed 
effectively  and  efficiently  in  the  decommissioning  of  its  reactors  in  line  with  the  baseline 
(decommissioning plan); however, some delays are emerging due to challenges and setbacks due 
to the programme's complexity. 

Safety. The analysis demonstrated that substantially improved levels of safety are going to be 
achieved  at  the  site  as  a  result  of  the  Union  funding  in  this  MFF.  All  spent  fuel  was  removed 
from  the  reactor  building  and  safely  stored  in  a  state-of-the-art  facility.  Legacy  and 
decommissioning waste  materials are being treated and conditioned for disposal, in preparation 
for dismantling the irradiated graphite from the reactors' core, which is a first-of-a-kind project of 
unprecedented scale. 

Financial  scope.  The  decommissioning  plan  frames  the  scope,  schedule,  and  budget  of  the 
programme. The plan is currently being revised with specific focus on the schedule, as a result of 
the conceptual design of the most critical project, i.e. the dismantling of reactor cores.  

National  contribution.  The  achieved  levels  of  national  contribution  appear  fit  to  sustain 
proper  efficiency  based  on  an  adequate  level  of  accountability  at  national  level  which  is 
inducing economy-seeking behaviour on the part of beneficiary. Nonetheless, the definition of a 
minimum threshold for national contribution is a necessary but not a sufficient condition to set 
incentives  for  timely  and  efficient  decommissioning.  To  this  end,  the  explicit  transfer  of  risks 
(cost overruns, delays) to the Member State would have a greater impact. This practice has been 
already introduced to a certain extent under the current MFF where possible. 

Governance. The governance setup has ensured effective and efficient implementation of the 
programme  and  compensated  for  the  uncertainties  mentioned  on  the  national  contribution 
aspects. Main factors of success were clear definitions of roles and responsibilities as well as a 

6 

 
strengthened  monitoring  framework.  The  analysis  has  also  identified  areas  for  further 
improvement such as: 

(i) 

increased  involvement  of  the  Member  State  for  increased  ownership  together  with 
stronger accountability of the decommissioning operator (final beneficiary); 

(ii) 

streamlining of procedures to enhance the timeliness of the management cycle; 

(iii) 

increased inter-comparability with other programmes' performance. 

Objectives.  The  interim  evaluation confirmed that the  general objective13  and the main specific 
objectives  of  the  programme  remain  valid  in  the  current  MFF.  Nevertheless,  some  of  the 
expected  results,  milestones,  target  dates,  as  well  as  the  corresponding  performance  indicators 
should be adapted in line with the latest updates of the decommissioning plan to enable effective 
monitoring for the period 2028-2034. 

Knowledge  gain.  Finally,  the  interim  evaluation  highlighted  that  the  experience  gained  so  far 
from the projects implemented under the programme provides a solid base of knowledge in the 
EU  for  conducting  ongoing  and  future  decommissioning  activities.  This  EU  co-funded 
programme  may  aim  at  becoming  a  solid  benchmark  for  governance  related  issues  and 
management  practices  such  as  cost  estimation  methodologies  or  planning,  and  persisting 
technological  challenges  such  as  the  dismantling  of  graphite-moderated  reactors  and  the 
subsequent management of important amounts of irradiated graphite. 

13   The  general  objective  of  the  programme  is  to  assist  the  Member  State  concerned  in  implementing  the  steady 
process  towards  the  decommissioning  end  state  of  the  concerned  NPP  in  accordance  with  its  respective 
decommissioning plan, whilst maintaining the highest level of safety. 

7 

 
 
 
 
2.  THE OBJECTIVES  

2.1.  Challenges for the programme in the next MFF  

The  key  aim  in  nuclear  decommissioning  is  the  progressive  removal  of  hazards  inherently 
associated with the concerned installations. This process is stepwise in nature, mainly because the 
removal  of  major  batches  of  radioactive  materials  is  obtained  over  several  stages.  The  safety 
measures and associated cost evolve likewise. 

At this point in time the decommissioning operator is focussing on dismantling activities. After 
the removal of the spent nuclear fuel from the Chernobyl-type reactor buildings, dismantling and 
decontamination works are progressing in the reactor buildings upper and bottom zones.  

The programme is on track to accomplish the specific objectives with the funding provided in the 
current MFF and a clear trend towards increasing efficiency was observed during the monitoring 
activities and confirmed by independent experts. However, important challenges remain both of 
technical and technological nature, as well as of financial nature for the next financial period in 
relation to dismantling of the reactor cores. 

Safety challenges 

Progress  in  the  implementation  of  the  programme  has  led  already  to  an  important  decrease  in 
radiological hazard to the general public but some important milestones are still ahead. With the 
funds already  provided, the  spent  nuclear  fuel  was  removed  from  the reactor-buildings  and  the 
dismantling works on the reactor  building top and bottom zones did start. In parallel, all waste 
management  routes  have  to  be  completed  under  the  next  MFF  either  for  interim  storage  or 
disposal. 

The  technical  challenges  for  the  decommissioning  of  the  Ignalina  nuclear  power  plant  are 
especially  complex  due  to  its  first-of-a-kind  nature  especially  in  respect  to  the  dismantling  of 
irradiated graphite and to the fact that a large percentage of the equipment is contaminated. The 
Ignalina  nuclear  power  plant  is  the  first  Chernobyl-type  reactor  to  be  decommissioned 
worldwide. This means there is no predecessor or experience that the decommissioning operator 
can  rely  on.  Open  questions  remain  in  particular  with  regard  to  the  management  of  irradiated 
graphite  waste.  Some  useful  experience  can  be  derived  from  other  graphite moderated reactors 
which are currently shut down but none of these has though been completely decommissioned to 
date.  It  is  worth  noting  that  in  all  cases  (France,  Spain,  and  Italy)  SAFSTOR14  strategies  have 
been favoured.  

In  this  respect  the  programme  holds  a  high  potential  for  the  development  of  innovative 
technologies and solutions for the dismantling, conditioning and storage of irradiated graphite. 

The  availability  of  financing  in  a  timely  manner  would  prevent  delays  or  even  possible 
discontinuation  of the  decommissioning process.  This  is  a crucial  element  for  ensuring  nuclear 
safety and the protection of the workers and the EU citizens. In case of insufficient funding, safe 
maintenance  would  be  compromised,  and  loss  of  unique  expertise  would  render  the  whole 
decommissioning process more risky, difficult and costly. 

14  

SAFe STORage is one of the options for nuclear decommissioning of a shutdown plant. During SAFSTOR the 
de-fuelled plant is monitored for up to sixty years before complete decontamination and dismantling of the site, 
to a condition where nuclear licensing is no longer required. During the storage interval, some of the radioactive 
contaminants of the reactor and power plant will decay, which will reduce the quantity of radioactive material to 
be removed during the final decontamination phase. 

8 

 
 
 
 
Social challenges 

The  social  impact  in  the  region  of  Visaginas  caused  by  the  shutdown  of  the  reactors  was 
considerable, because  the  Ignalina  nuclear  power  plant was the main economic operator in this 
remote  region  at  the  border  between  Lithuania,  Latvia,  and  Belarus.  After  the  shutdown  the 
Ignalina NPP workforce has declined from 4 500 employees in 2003 (INPP in operation) to about 
1 500 employees in 2024. 

In pursuing the decommissioning programme, the Ignalina NPP is still the major employer and 
contracting  authority  in  the  region.  However,  the  decommissioning  programme  has  a  limited 
duration, therefore the social challenges need to be anticipated and addressed by Lithuania. When 
doing  so,  Lithuania  should  consider  a  series  of  guidance  documents  such  as  the  Council 
Recommendation  towards  climate  neutrality15,  recommendations  on  the  National  Energy  and 
Climate  Plans  (NECPs),  the  European  Quality  Framework  for  anticipation  of  change  and 
restructuring16,  and  the  Proposal  for  a  Regulation  establishing  a  European  Fund  for  economic, 
social  and  territorial  cohesion,  agriculture  and  rural,  fisheries  and  maritime,  prosperity  and 
security17. 

Other available EU instruments may be deployed in the region ensuring this way synergies and 
complementarities.  

2.2.  Objectives of the programme in the next MFF 

2.2.1.  General objectives 

The  main  general  objective  of  the  programme  in  the  next  MFF  will  be  to  assist  Lithuania  in 
managing the radiological safety challenges of the decommissioning of the Ignalina nuclear 
power plant. 

As  for  the  current  MFF,  the  main  general  objective  will  be  complemented  by  the  aim  to 
disseminate  knowledge  on  the  decommissioning  process  (generated  by  the  programme)  to  all 
EU  Member  States  and  beyond,  thus  enhancing  the  EU  added  value  of  the  programme.  The 
programme  will  develop  explicit  knowledge  products  on  decommissioning  and  waste 
management governance issues, managerial best practices, and technological challenges. 

Finally,  a  key  policy  objective  remains  further  increase  of  Member  State's  ownership  of  the 
decommissioning and waste management processes. 

2.2.2.  Specific objectives 

The  specific  objectives  need  to  be  adapted  to  the  actual  progress  of  the  decommissioning 
programme,  the  related  challenges,  and  the  need  to  foster  knowledge  sharing  and  potential 
synergies. 

The decommissioning programme covers a timespan longer than the current and next MFFs and 
is properly defined in terms of scope, budget, and timeline within the decommissioning plan. The 

15   Council  Recommendation  of  16  June  2022  on  ensuring  a  fair  transition  towards  climate  neutrality,  2022/C 

243/04, OJ C 243, 27.6.2022, pp. 35–51. 

17  

16   Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social  Committee  and  the  Committee  of  the  Regions,  EU  Quality  Framework  for  anticipation  of  change  and 
restructuring, COM(2013) 882 final. 
Proposal  for  a  Regulation  of  the  European  parliament  and  of  the  Council  establishing  the  European  Fund  for 
economic, social and territorial cohesion, agriculture and rural, fisheries and maritime, prosperity and security for 
the  period  2028-2034  and  amending  Regulation  (EU)  2023/955  and  Regulation  (EU,  Euratom)  2024/2509, 
COM(2025) 565 final. 

9 

 
 
abovementioned  challenges  are  identified  in  the  decommissioning  plan  and  have  to  be  tackled 
based on priorities dictated by radiological safety. 

The disposal of spent fuel and radioactive waste in a deep geological repository is excluded from 
the  scope  of  the  programme  and  has  to  be  developed  by  each  Member  State  in  its  national 
programme for the management of spent fuel and radioactive waste as required by the relevant 
directive18.  

The  following  specific  objectives  reflect  the  need  to  progress  in  the  removal  of  radiological 
hazards: 

I.  Dismantling of reactor shafts: 

1.  completion of dismantling and decontamination of top and bottom zones (called 

R1 and R2); 

2.  completion of Steam Drum Separators dismantling; 
3.  graphite cores (called R3):  

a.  dismantling technology engineered and licensed; 
b.  dismantling equipment installed and operational;  
c.  dismantling and decontamination  of the  reactor shafts  central zone  in 
accordance  with  the  decommissioning  plan;  progress  has  to  be 
measured  by  the  quantity  and  type  of  materials  removed  as  well  as 
through earned value); 
reactor waste interim storage facility in operation. 

d. 

II. 

III. 

The  Ignalina  nuclear  power  plant  (INPP)  reorganisation  and  proportionate  reduction  of 
workforce  (employees)  involved  in  the  decommissioning  programme.  In  view  of  the 
scheduled dismantling activities and considering the choice of the INPP to outsource the 
full dismantling of reactor shaft central zones, the reduction of the workforce involved in 
the decommissioning activities shall be at least one third compared to the number of full 
time equivalent  (FTE)  at the  end  of  2024.  Progress has to  be measured  with respect to 
specific Key Performance Indicators approved in the implementing work programmes. 

Safe management of the decommissioning and legacy waste up to interim storage or  to 
disposal  (depending  on  the  waste  category),  including  the  completion  of  the  waste 
management  infrastructure,  and  near  surface  repository.  It  has  to  be  accomplished  in 
accordance  with  the  decommissioning  plan,  in  its  final  revision.  Progress  has  to  be 
measured  by  the  quantity  and  type  of  waste  safely  stored  or  disposed  of,  as  well  as 
through earned value. 

IV.  Downgrading  of  radiological  hazards.  Progress  has  to  be  measured  through  the  safety 
assessments  of  the  activities  and  the  facility,  identifying  ways  in  which  potential 
exposures  could  occur  and  estimating  the  probabilities  and  magnitude  of  potential 
exposures. 

3.  PROGRAMME STRUCTURE AND PRIORITIES 

The legal basis for the programme is Lithuania's Accession Treaty. Protocol No 4 and Article 56 
of  the  2003  Act  of  Accession  (AA)1  state  that  "the  decommissioning  of  the  Ignalina  Nuclear 
Power  Plant  with  two  1  500  MW  RBMK-type  reactor  units  inherited  from  the  former  Soviet 
Union  is  of  an  unprecedented  nature  and  represents  for  Lithuania  an  exceptional  financial 
burden  not  commensurate  with  the  size  and  economic  strength  of  the  country"  and  that  this 
decommissioning is of a long-term nature. 

18   Council Directive 2011/70/Euratom of 19 July 2011 on establishing a Community framework for the responsible 

and safe management of spent fuel and radioactive waste, OJ L 199, 2.8.2011, p. 48–56. 

10 

 
 
The  actions  to  be  funded  post-2027  will  be  derived  from  the  latest  version  of  the 
decommissioning plan and are responding to the safety objectives. Having achieved the complete 
defueling of the reactors (which accounts for 99% of radioactivity removed), dismantling of the 
graphite  cores  has  the  highest  priority  in  the  next  stage  as  it  represents  the  next  in  line  major 
removal of radiological hazard. It is also a first-of-a-kind activity that will serve as a benchmark 
for  decommissioning  programmes  in other Member  States (Germany,  Spain,  France,  Italy)  and 
worldwide (Russia, UK, Ukraine, US). Additionally, the safe management of decommissioning 
and legacy waste (e.g. bituminised waste) needs to be finalised, i.e. up until the interim storage or 
disposal depending on the waste category. 

In order of importance, the priorities for the programme are: 

(i) 

(ii) 

sharper  focus  on  safety  (nuclear  safety,  protection  of  workers,  public,  and  the 
environment); 

incentivised and enhanced performance through increased ownership and optimisation of 
workforce; 

(iii) 

dissemination of knowledge for the EU nuclear decommissioning market; 

(iv) 

simplification and synergies; 

(v) 

solidarity. 

Based  on  the  good  practice  already  established,  the  focus  of  the  assistance  programme  is  on 
decommissioning only, and it should further focus on activities strictly related to the achievement 
of the main safety objectives and to the delivery of EU added value, i.e. removal of radiological 
hazards and creation of relevant knowledge. The decommissioning plan will continue to serve as 
the baseline, defining the precise scope for EU assistance. At the same time, taking into account 
the ECA's recommendations19, incentives to pursue decommissioning should be embedded in the 
funding  mechanism,  including  time  limitations  and  appropriate  levels  of  national  contribution 
from the beneficiary Member State. Accordingly, in order to accomplish the programme general 
and  specific  objectives avoiding  cost  overrun and  undue  delays,  the  Ignalina  NPP  envisages  to 
reorganise their  staff,  aiming  at  a  reduction  of  the  workforce  involved in  the  decommissioning 
activities;  the  target  is  a  reduction  of  at  least  one  third  compared  to  the  number  of  full  time 
equivalent at the end of 2024. 

The  solidarity  principle  is  enshrined  in  the  Lithuania's  Accession  Treaty,  calling  the  Union  to 
support the Member State in dealing with this Soviet era legacy.  This  aspect deserves the right 
level  of  political  attention,  because  it  underpinned  the  agreements  between  Lithuania  and  the 
Union  when  the  decision  to  shut-down  the  Ignalina  nuclear  power  plant  earlier  than  initially 
planned was taken. 

Hence, it is important that the programme be prioritised for further EU support in the next MFF 
(2028-2034) as it has the potential for achieving notable EU-added value both in terms of safety 
and knowledge gain. 

4.  DELIVERY MECHANISMS OF THE INTENDED FUNDING 

The  interim  evaluation  showed  that  the  performance  monitoring  framework  for  the  Ignalina 
programme  is  generally  in  line  with  best  practice,  given  that  a  results-based  performance 
monitoring  is  in  place.  In  this  respect  the  programme  could  be  improved  by  linking  additional 
funding to the achievement of pre-defined targets. 

The  programme  seeks  to  ensure  strong  national  ownership  of  project  implementation  through 
early  buy  in  and  strong  Member  State  involvement.  Member  State  is  involved  early  in  the 
development of the projects or programmes and has input at key phases.  

11 

 
The current programme offers a fully multi-annual framework for programming and has in place 
an annual cycle for programming and commitments.  

The following three policy options should be considered in assessing the impact of the  Ignalina 
programme in the next MFF: 

(i) 

Policy option 1 – Discontinuation of the Ignalina programme; 

(ii) 

Policy option 2 – Ignalina programme implemented via shared management instruments; 

(iii) 

Policy option 3 – Ignalina programme as dedicated spending programme. 

4.1. 

Policy option 1 – Discontinuation of the Ignalina programme  

Under Option 1 the implementation of the provisions of the Accession Treaty would end in 2027. 
No further financial EU assistance would be provided and consequently Lithuania would have to 
guarantee safe completion of the decommissioning programme with own national resources.  

In case of insufficient funding,  there is a risk of rendering the whole decommissioning process 
more risky, difficult and costly as well as result in possible safety implications and risk of loss of 
unique expertise. 

Compared to the Bohunice (SK) and Kozloduy (BG) programmes where  significant decrease in 
radiological  hazard  to  the  general  public  was  accomplished  and  the  funding  for  programmes 
completion  fully  committed,  the  Ignalina  programme  is  evidently  at  an  earlier  stage  of  this 
process and further important milestones need to be met before achieving the same level of risk 
reduction. 

Given  that  a  national  policy  and  programme  are  in  place  in  application  of  Council  Directive 
2011/70/Euratom,  key  safety  objectives  were  met  already,  and  the  national  economy  appears 
generally fit for bearing future charges (though with certain negative impact), the discontinuation 
option may appear viable in some respect. 

However, in such a scenario the Union would have no more leverage on the timely execution of 
the remaining safety actions within the timescale set out in the approved decommissioning plan. 
There  is  a  high  risk  that  the  necessary  funding  for  the  programme  will  not  be  provided  in 
accordance  with  the  plan,  with  obvious  delays  in  the  progressive  decrease  of  the  level  of 
radiological hazard. 

Moreover, the discontinuation of the Ignalina programme could seriously harm the reputation of 
the EU in Lithuania as they had to shut down the Ignalina nuclear power plant on request of the 
EU  at  the  time  of  the  accession  negotiations.  Lithuania  was  relying  on  Union  support  for  the 
decommissioning as well as for measures mitigating the important effects to its economy due to 
the  loss  of  inland  energy  production19.  Lithuania  communicates  regularly  that  it  counts  on  EU 
solidarity regarding the completion of decommissioning of the Ignalina nuclear power plant. 

These  risks  should  be  assessed  also  in  view  of  the  increased  programme's  effectiveness  and 
efficiency obtained during the current and past MFF. 

19  

Ignalina NPP Unit 2 accounted for 25% of Lithuania's installed electricity generating capacity and supplied about 
70% of Lithuania's electrical demand. 

12 

 
 
4.2. 

Policy option 2  – 
management instruments 

Ignalina  programme 

implemented  via 

shared 

Cohesion  policy  is  the  Union's  main  investment  policy,  aiming  to  strengthen  economic,  social 
and territorial cohesion and reduce disparities among regions. It is a major driver of job creation, 
sustainable growth and innovation in Europe's diverse regions.  

As a result of a performance audit on the Ignalina programme, in 2016 the ECA recommended20 
discontinuing  the  dedicated  spending  programme  after  2020  and  considering  access  to  other 
instruments for nuclear decommissioning activities. This recommendation was made with the aim 
to  create  the  right  incentives  to  pursue  decommissioning  and  adhere  to  the  strict  rules  on  co-
financing  applicable  under  other  instruments.  The  Commission  partially  accepted  this 
recommendation holding over its prerogative to decide based on an impact assessment (replaced 
by  this  ex-ante  evaluation)  in  line  with  the  requirements  of  the  financial  regulation  and  better 
regulation agenda with regard to proposals of new initiatives. 

It  is  worth  recalling  that  in  preparation  of  the  MFF  2014-2020  the  Ignalina  programme  was 
already revised to exclude all measures which were not strictly related to the decommissioning of 
the  concerned  facilities.  As  a  consequence,  support  to  energy  related  projects was  taken  out  of 
programme as they could be supported through other EU funded measures. 

Currently,  decommissioning  of  nuclear  power  stations  is  explicitly  excluded  from  other 
instruments,  which  are  mostly  geared  to  growth  objectives.  Therefore,  a  possible  funding  of 
decommissioning  under  share management  instruments  would  lead  to  a  fundamental  change in 
their philosophy.  

The  inclusion  of  the  decommissioning  programme  under  other  instruments  may  bring  the 
following benefits:  

(i) 

simplification and reduction of administrative burden; 

(ii)  well-established, proven and cross-cutting management and control systems; 

(iii) 

increased  Member  State's  ownership  of  the  decommissioning  programme,  with  clear 
requirements for national contributions; 

(iv) 

budgetary flexibility transferred to the Member State. 

In other words, implementation under the shared management mode could increase the Member 
State's  ownership  of  the  decommissioning  programme  and  would  allow  the  Member  State  to 
prioritise decommissioning projects among other eligible projects.  

However, these advantages are offset by two substantial drawbacks:  

(i)  making  decommissioning  an  eligible  activity  under  shared  management  programmes, 
will  create  a  precedence  that  goes  against  the  principles  set  by  the  Council  Directive 
2011/70/Euratom on the safe and responsible management of radioactive waste and spent 
fuel,  whereby  the  costs  for  the  management  of  these  materials  shall  be  borne  by  those 
who generated those materials; and 

20   Recommendation  5:  dedicated  funding  programmes  for  nuclear  decommissioning  in  Lithuania,  Bulgaria  and 
Slovakia should be discontinued after 2020. If a clear need for the use of EU funds beyond 2020 is established, in 
one or more of the three Member States, any future EU funding proposed by the Commission and agreed by the 
legislator should include the right incentives to pursue decommissioning, including by being time limited and by 
being  based  on  appropriate  levels  of  Member  State  co-financing.  One  way  to  do  this  would  be  to  consider 
widening access to the European Structural and Investment Funds to allow nuclear decommissioning activities to 
be covered, fulfilling these conditions. 

13 

 
 
(ii) 

shifting  of  budget  between  priorities  is  possible  during  the  entire  lifetime  of  the 
programme, therefore there is a risk of de-prioritisation of decommissioning in favour of 
other activities. 

In  the  case  of  Lithuania,  a  possible  inclusion  of  decommissioning  under  shared  management 
instruments would result in  a relevant percentage  of its allocation being concentrated solely on 
one area and one region. This would be disproportionate vis-à-vis other priority areas and other 
regions in Lithuania that are equally in need for reducing disparities. 

4.3. 

Policy option 3 – Ignalina programme as dedicated spending programme 

Safety  remains  at  the  heart  of  the  Union  policy  priorities.  The  fundamental  need  of  safety  has 
been the basis for the  Ignalina  programme since its  inception, i.e.  since  the pre-accession time. 
Clearly  this  need  is  still  the  main  driver  for  continuing  the  Ignalina  programme  under  nuclear 
safety policies. 

As  a  result  of  the  programme  interim  evaluation  the  current  governance  setup  has  proven  to 
ensure effective and efficient implementation of the programme. Main factors of success are the 
clear definitions of roles and responsibilities as well as the strengthened monitoring framework. 

The  Member  State  appoints  a  Programme  Coordinator  to  be  responsible  for  the  programming, 
coordination and monitoring of the decommissioning programme, thus ensuring at national level 
the  comprehensive  oversight  of  the  programme  and  enhancing  access  to  information  by  the 
Commission in its supervisory role.  

A Committee with monitoring and reporting functions  is in place, co-chaired by a Commission 
representative  and  the  Programme  Coordinator.  The  Committee  is  well  equipped  with  a 
dashboard  of  key  performance  indicators  and  detailed  targets,  in  order  to  steer  the  Ignalina 
programme  through  a  well-informed  assessment  and  decision-making  process.  The  detailed 
objectives  and  indicators  (proposed  by  the  Member  State  and  approved  by  the  Commission) 
provide quantitative information to measure progress towards the specific objectives. Moreover, 
the Earned Value Management (EVM) methodology enhances the Commission's supervision on 
both effectiveness and efficiency with a positive trickle-down effect at national level. 

Beside the described programme governance structure, a specific steering mechanism was set for 
the governance of the project for reactor cores dismantling (R3D project), given the relevance of 
the  activity  both  in  terms  of  cost  and  schedule,  and  its  first-of-a-kind  nature.  Dedicated 
coordination  meetings  are  co-chaired  by  the  Commission  representative  and  the  Programme 
Coordinator to follow up and monitor the project, to steer or take decisions  on strategic  issues, 
and to ensure proper project risk management. 

From  a  legal  viewpoint,  the  base  for  the  continuation  of  the  programme  in  Lithuania  is  well 
identified.  Nonetheless  the  analysis  and  the  benchmark  have  also  identified  areas  for  further 
improvement to be achieved in the establishment of a new Regulation for the next MFF, should 
this policy option be selected.  

In  particular  on  the  EU  co-financing  issue,  a  well-defined  co-financing  rate  was  set  and 
accomplished during the current MFF. Likewise, further increase of Member State's ownership as 
well as stronger incentives can be devised in a dedicated spending programme, such as limitation 
in  time  for  the  funding.  Finally,  the  Ignalina  NPP  should  reorganise  their  work  structure  to 
optimise the decommissioning workforce. 

The  Ignalina  programme  is  currently  implemented  by  the  EBRD  as  well  as  by  the  national 
agency  (CPMA).  The  implementation  via  the  national  agency  was  established  upon  request  by 
Lithuania  in  view  of  increasing  ownership.  Continuing  the  implementation  of  the  programme 
through  the  established  entrusted  entities  would  ensure  stability  in  the  safe  decommissioning 
process. 

14 

 
The progress achieved under the dedicated programme was significant. The existing monitoring 
tools ensured that any occurring issue were addressed in a timely manner, however improvements 
are needed to increase the programme implementation efficiency.  

4.4. 

Policy options benchmark 

The risks associated to policy option 1 (discontinuation) are: EU would waive leveraging on the 
safety objectives of the programme as well as on exploiting the knowledge gained in favour of 
other  EU  Member  States;  moreover,  from  a  political  standpoint,  the  solidarity  principle 
underpinning the programme thus far would be disregarded by the Union with negative effect on 
the European sentiment in Lithuania. 

Policy  options  2  and  3  are  mainly  differentiated  in  terms  of  theme  (cohesion  vs.  safety)  and 
delivery mechanism (merge with other programmes vs. dedicated spending programme). 

Both  solutions  are  fit  for  addressing  the  substantial  needs  of  increased  ownership  by  the 
beneficiary Member State and of stronger incentives to pursue decommissioning in a timely and 
efficient manner. However, policy option 3 responds more effectively to the needs of: 

(i) 

EU leveraging on the safety objectives; 

(ii)  maximising knowledge gain for the decommissioning of nuclear reactors across the EU 

and beyond. 

5.  HOW WILL PERFORMANCE BE MONITORED AND EVALUATED? 

The nuclear decommissioning programme is complex and long-lasting (flowing through several 
subsequent  MFFs).  Objectives  are  thus  specifically  defined  for the  short  term  (e.g.  year,  MFF) 
under the framework of a multiannual programme aimed at accomplishing the general objective. 

5.1. 

Programming, monitoring, reporting and evaluation 

Under policy option 3 the programming, monitoring and control system will be further improved 
and streamlined with respect to the existing one; lessons learnt from the interim evaluation will 
be used in order to ensure continuous improvement. 

As far as programming is concerned the multiannual nature of the decommissioning programme 
will  be  reflected  in  the  adoption  of  a  multiannual  work  programmes,  submitted  by  the 
Programme Coordinator. 

The Commission would continue entrusting the implementation of the programme's budget to the 
pillar-assessed entrusted entities (indirect management). 

A Committee with monitoring and reporting functions is in place, co-chaired by the Commission 
representative and Programme Coordinator. Entrusted entities (EBRD, CPMA) monitor on a day-
to-day basis. In addition, the Commission services closely follow project implementation through 
desk and on-the-spot reviews on a biannual basis. 

Presently  the  regular  programming,  monitoring  and  control  cycle  is  supplemented  by  thematic 
verifications based on risk reviews. This practice will continue in the next MFF. 

5.2. 

Performance indicators 

The  present  Regulation  has  defined  SMART  (Specific,  Measurable,  Achievable,  Relevant,  and 
Time-bound)  specific  objectives  for  the  progress  to  be  achieved  in  the  funding  period;  those 
specific  objectives  have  been  further  detailed  with  targets  and  indicators  within  the  detailed 
implementation procedures6. 

15 

 
Several  output-based  physical  progress  indicators  are  suitable  both  for  defining  specific 
objectives  and  for  monitoring  the  performance  (i.e.  effectiveness)  of  decommissioning 
programmes;  for  example,  amounts  of  systems  dismantled,  materials  released  from  regulatory 
control, radioactive waste processed, conditioned and stored or disposed of. 

Another important category of indicators is project-based; for example, milestones i.e. significant 
events in a project properly budgeted and scheduled. Moreover, project management techniques 
are essential such as critical path analysis and the Earned Value Management that provide robust 
project-based  KPIs  enabling  the  managers  to  control  delays  and  cost-increases.  Accordingly, 
these indicators are used to assess the efficiency of the process. 

The combination of output-based and project-based indicators has proven to have a high potential 
for  programmes  such  as  nuclear  decommissioning.  Output-based  indicators  put  very  specific 
activities under the spotlight; the information they provide is sharp and clear, but also limited in 
that  the  full  picture  is  not  covered.  Complementarily,  the  Earned  Value  Management  KPIs 
provide  a  complete  view  of  the  progress  of  individual  projects/work  packages  and  can  be 
aggregated to inform the general state of play of the overall programme, both time-wise and cost-
wise. 

Such set of indicators (fully quantitative) enables control on short-term as well as on long-term 
challenges, providing the managers (up to supervisory organisations) the tools to enact corrective 
or mitigation measures at the earliest time possible.  

The  programme  interim  evaluation  has  shown  that  this  comprehensive  toolkit  of  performance 
indicators has supported effective and efficient implementation as demonstrated by the deeds, i.e. 
accomplishments. Therefore, the performance monitoring and evaluation for the future MFF can 
be  profitably  built  on  both  the  existing  system  and  the  lessons  learnt  to  ensure  continuous 
improvement. 

Under  policy  option  3  other  indicators  are  needed  to  reflect  safety  related  achievements  in  an 
even stricter manner and to match with the new explicit EU-wide knowledge sharing objective. 

Progressive  and  stepwise  removal  of  radiological  hazards  posed  by  the  facilities  under 
decommissioning  will  have  to  be  measured  based  on  the  safety  cases  prepared  by  the 
decommissioning licence holder. 

As far as the EU-wide knowledge sharing objective is concerned, the following key items should 
be  monitored  without  prejudice  to  the  competitive  advantage  of  the  decommissioning  licence 
holder having created such know-how: 

(i)  decommissioning cost estimates and estimations methodologies; 

(ii)  radiation protection and industrial safety issues; 

(iii)  identification of proven processes; 

(iv)  irradiated graphite management (from dismantling to storage). 

5.3. 

Preliminary evaluation criteria 

For the programme, the main EU co-financed endeavour for the next MFF period (2028-2034) is 
the dismantling of the two reactor graphite cores, including all preparatory tasks. This activity is 
a true first-of-a-kind one, therefore the schedule and the budget are subject to uncertainties which 
call for a strict monitoring and control (and fully justify the Union solidarity). 

Given  the  above,  the  current  cycle  of  programme  evaluations  should  be  maintained,  i.e.  an 
interim evaluation has to be scheduled as well as the mandatory final evaluation. 

16