REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on contingent liabilities arising from budgetary guarantees and financial assistance and the sustainability of those contingent liabilities Situation at 31 December 2024
Date: 2025-12-11
Institutions: Directorate-General for Budget, European Commission
Subjects: EU Member State, EU budget, EU expenditure, EU financial instrument, budgetary reserve (EU), financial aid, financial management, own resources, risk management, third country

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   EUROPEAN COMMISSION  Brussels, 11.12.2025  COM(2025) 781 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on contingent liabilities arising from budgetary guarantees and financial assistance and the sustainability of those contingent liabilities  Situation at 31 December 2024  
 
 
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Table of Contents 

1.  Introduction ................................................................................................................................................. 2 

2.  Analysis of the different sources of contingent liabilities ........................................................ 5 

2.1 Budgetary guarantees ......................................................................................................................................................... 5 

2.2 Provisioned loans for financial assistance to non-EU countries ................................................................. 7 

2.3 Headroom-backed loans .................................................................................................................................................... 9 

2.4 Overview of contingent liabilities at the end of 2024 ................................................................................... 12 

3.  Assessing the sustainability of EU contingent liabilities ........................................................ 13 

3.1 Assessment framework ................................................................................................................................................... 14 

3.2 Assessment of the sustainability of the provisioned contingent liabilities ........................................ 14 

3.3 Assessment of the sustainability of the headroom-backed contingent liabilities ......................... 19 

4.  Conclusions ............................................................................................................................................... 23 

5.  Annexes: ..................................................................................................................................................... 24 

Sustainability and headroom in respect of the permanent own resources ceiling ................................ 24 

Sustainability and headroom in respect of the temporary own resources ceiling ................................. 25 

 
 
 
 
 
1. Introduction 
This report is issued in accordance with the requirements of Article 256 of the Financial Regulation1 
and should be read in conjunction with: 

• 

the consolidated annual accounts of the European Union (financial year 2024)2; 

•  working document XI, which accompanies the draft EU budget for the financial year 20263 
and  which  provides  detailed  information  on  EU  budgetary  guarantees  and  provisioned 
financial assistance loans (Article 41(5) Report)4; and 

• 

the  long-term  forecast  report  on  future  inflows  and  outflows  of  the  EU  budget  (2026-
2034), which takes into consideration planned budget expenditures5.  

The  first  objective  of  this  report  is  to  provide  an  overview  of  the  amount  and  composition  of 
contingent liabilities – both provisioned6 and headroom-backed7 contingent liabilities - borne 
by the EU budget as of 31 December 20248. Contingent liabilities are potential financial liabilities 
that stem from existing binding commitments or previous contractural occurrences9. Whether or 
not these contingent liabilities result in actual calls on the EU budget, and the size of any such 
calls, will depend on future events that cannot be predicted with certainty.  

At the end-2024, the EU budget was exposed to contingent liabilities amounting to aproximately 
EUR 300 billion relating to loans (EUR 255 billion at the end of 2023). Of this EUR 300 billion, EUR 
252 billion was from loans granted to Member States. The remaining EUR 48 billion was for loans 
to non-EU countries (with EUR 42.4 billion of the EUR 48 billion comprised of loans to Ukraine), Of 
the EUR 42.4 billion in loans to Ukraine, EUR 31.1 billion  was backed by the headroom. The EU 
budget was also exposed to contingent liabilities related to budgetary guarantees amounting 
to  approximately  EUR 110 billion  (EUR 108 billion  at  the  end  of  2023).  These  budgetary 
guarantees were provided in the context of the European Fund for Strategic Investments (EFSI)10, 
InvestEU11, the External Lending Mandate (ELM)12, the European Fund for Sustainable Development 

1  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).  

2   COM(2025) 359 of 25.6.2025 
3  COM(2025) 300 of 4.6.2025. 
4  Working  document  XI  on  the  implementation  of  budgetary  guarantees,  the  Common  Provisioning  Fund  and  the 
assessment  of  the  sustainability  of  the  contingent  liabilities  arising  from  budgetary  guarantees  and  financial 
assistance pursuant to Article 41(5) of the Financial Regulation. 

5  COM(2024) 573 final of 16.7.2025. 
6   In this document the term provisioning is used in the meaning of the Financial Regulation and in particular Article 
214  thereof.  As  laid  down  by  Article  214(2),  the  provisioning  rate  needs  to  cover  net  expected  losses  plus  an 
adequate safety buffer for unexpected losses. In other circumstances provisioning (e.g. in an accounting context), 
the term might have a different meaning. 

7   ‘Headroom-backed’ means that the guarantee for related contingent liabilities is given by the EU budget headroom. 
In practice, should the related contingent liabilities materialise, potential additional amounts may be called from 
Member States over and above MFF ceilings and up to the Own Resource ceiling to cater for it. 

8   This set cut-off date aligns with the consolidated accounts of the EU and the objective of the report to assess the 
sustainability  of  incurred  contingent  liabilities  borne  by  the  EU  budget.  No  forecasts  are  made  for  contingent 
liabilities arising beyond this date as they will depend on needs, market conditions and liquidity availabilities.  
9     A separate source of contingent liabilities is represented by the ‘legal risks’. These are not covered by the present 

report. 

10  Regulation (EU) 2015/1017 of the European Parliament and of the Council of 25 June 2015 on the European Fund 
for Strategic Investments, the European Investment Advisory Hub and the European Investment Project Portal and 
amending Regulations (EU) No 1291/2013 and (EU) No 1316/2013 (OJ L 169, 1.7.2015, p. 1).  

11  Regulation (EU) 2021/523 of the European Parliament and of the Council establishing the InvestEU Programme and 

amending Regulation (EU) 2015/1017 (OJ L 107, 26.3.2021, p. 30). 

12  An overview of the relevant legislative acts and corresponding guarantee agreements between the Commission and 
the  European  Investment  Bank  is  available  in  the  Definitive  Adoption  (EU,  Euratom)  2021/417  of  the  European 
Union’s general budget for the financial year 2021 (Section III – Commission, Remarks for Item 14 20 03 02 of the 
statement of expenditure ‘External Action Guarantee for NDICI, EINS, IPA III and MFA’) (OJ L 93, 17.3.2021, p. 959). 

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(EFSD)13,  the  EFSD+14,  and  the  Ukraine  Investment  Framework  (UIF),  which  is  the  budgetary 
guarantee to support investment in Ukraine set up under the Ukraine Facility Regulation15.  

Total  contingent  liabilities  -  comprising  both  budgetary  guarantees  and  loans  -  rose  to 
EUR 410 billion in 2024, up from EUR 363 billion in 2023, representing an increase of 13%. This 
rate of increase is broadly in line with the rate of increase observed in 2023 (+16%) and lower 
than the rate of increase observed in 2022 (40%). The bulk of this increase comes from additional 
loan disbursements to Member States under the Recovery and Resilience Facility (RRF)16 and from 
financial assistance to Ukraine under the Ukraine Facility.  

Secondly, this report also presents an assessment of the long-term sustainability of contingent 
liabilities based on qualitative and quantitative factors, including stress-testing. This sustainability 
assessment is performed by comparing contingent liabilities with: 

• 

• 

the  market  value  of  existing  provisions  held  in  the  respective  compartments  of  the 
Common Provisioning Fund (CPF)17 set up by the Commission for provisioned contingent 
liabilities,  i.e.  liabilities  arising  from  budgetary  guarantees  and  financial  assistance  to 
non-EU countries; 

the  limits  of  the  own  resources  ceilings  and  the  available  headroom  for  headroom-
backed contingent liabilities.  

The main conclusion of the end-2024 sustainability analysis is that the EU budget has sufficient 
resources  to  cope  with  the  potential  materialisation  of  contingent  liabilities  incurred  as  of  31 
December 2024. There are three main reasons for this conclusion, which are set out in the bullet 
points below. 

•  For  contingent  liabilities  arising  from  budgetary  guarantees  and  financial  assistance  to 
non-EU countries, the provisioning available at the end of 2024 is adequate considering 
the requirements of the respective legal frameworks18. 

•  The EU’s financial capacity under the existing legal framework for 2026 and 2027 (i.e. the 
Own  Resources  Decision  (ORD)19  and  the  2021-2027  Multiannual  Financial  Framework 
(MFF)  Regulation20)  and  as  of  2028  the  proposed  new  ORD  and  MFF  Regulation  2028-
203421 is sufficient to to cover all headroom-backed contingent liabilities arising from debt 
issued under i) the RRF, SURE and other loans to Member States, ii) the Ukraine macro-
financial  assistance  plus  (MFA+)  instrument  and  iii)  the  Ukraine  Facility,  even  under 
extreme adverse circumstances. In other words, the headroom is well-resourced to ensure 
the robustness of the EU financial system and its creditworthiness, even under an extreme 

13  Regulation (EU) 2017/1601 of the European Parliament and of the Council of 26 September 2017 establishing the 
European Fund for Sustainable Development (EFSD), the EFSD Guarantee and the EFSD Guarantee Fund (OJ L 249, 
27.9.2017, p. 1). 

14  The EFSD+ was established by the Neighbourhood, Development and International Cooperation Instrument (NDICI) 
– Global Europe Regulation. Regulation (EU) 2021/947 of the European Parliament and of the Council of 9 June 
2021  establishing  the  Neighbourhood,  Development  and  International  Cooperation  Instrument  –  Global  Europe, 
amending and repealing Decision No 466/2014/EU and repealing Regulation (EU) 2017/1601 and Council Regulation 
(EC, Euratom) No 480/2009 (OJ L 209, 14.6.2021, p. 1). 

15  Regulation (EU) 2024/792 of the European Parliament and of the Council of 29 February 2024 establishing the 

Ukraine Facility. 

16  Regulation  (EU)  2021/241  of  the  European  Parliament  and  of  the  Council  of 12 February 2021  establishing  the 

Recovery and Resilience Facility (OJ L 57, 18.2.2021, p. 17). 

17  For  details on  the  CPF see  the Report  from  the  Commission  to  the  European Parliament and  the  Council  on  the 
Common  Provisioning  Fund  in  2024  (COM(2025)  400  final  of  6.6.2025)  and  the  accompanying  Staff  Working 
Document (SWD(2025) 100 final of 6.6.2025). 

18  See Section 3 of the Article 41(5) Report. 
19  Council Decision (EU, Euratom) 2020/2053 of 14 December 2020 on the system of own resources of the European 

Union and repealing Decision 2014/335/EU, Euratom (OJ L 424, 15.12.2020, p. 1). 

20  Council Regulation (EU, Euratom) 2020/2093 laying down the multiannual financial framework for the years 2021 

to 2027 (OJ L 433 I, 22.12.2020, p. 11). 

21  Proposal for a Council Regulation laying down the multiannual financial framework for the years 2028 to 2034 
(COM(2025)571 final); Proposal for a Council Decision on the system of own resources of the European Union and 
repealing Decision (EU, Euratom) 2020/2053 (COM(2025)574 final). 

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negative  scenario  that  combines  adverse  impacts  in  economic  conditions,  revenue  and 
expenditure.22 

The risks arising from contingent liabilities are managed and monitored through a general cross-
Commission framework including extensive measures and safeguards which the Commission can 
use to protect the EU budget from potential losses stemming from contingent liabilities23. A central 
role in that framework has been played by the Steering Committee on Contingent Liabilities24. This 
framework  was  strengthened  at  the  beginning  of  2025  through  the  Commission  Decision  (EU, 
Euratom)  2025/36925,  which  expanded  the  role  of  the  Chief  Risk  Officer  (CRO).  Operating 
independently from the Commission DGs responsible for financial operations, the CRO provides a 
critical and dedicated financial risk oversight function in respect of all financial operations, namely: 

- 

- 

- 

borrowing, debt, and the related liquidity management; 

lending operations and budgetary guarantees; 

asset  management,  including  the  management  of  the  provisions  of  the  Common 
Provisioning Fund which represent the reserves set aside to meet calls on EU budgetary 
guarantees26. 

Box 1: The 2028-2034 MFF 

The purpose of this report is to assess the sustainability of the contingent liabilities borne by 
the EU budget. Whereas the provisioned budgetary guarantees and loans are tested against the 
market value of the provisions held in the CPF, headroom backed contingent liabilities borne by 
the EU budget are assessed in a forward-looking partly by looking at the projected evolution of 
MFF  payments  and  the  own  resources  ceiling.  For  the  years  2028-2034,  the  assessment 
therefore includes the proposed own resources ceiling at 1.75% of EU gross national income 
(GNI) and the projected expenditures related to the proposal for the 2028-2034 MFF, as set out 
in  the  long-term  forecast  report  on  future  inflows  and  outflows  of  the  EU  budget 
(COM(2025)573). The resulting headroom projection constitutes the baseline against which the 
contingent liabilities borne by the budget at end-2024 are evaluated.  

The Commission presented its proposal for the next MFF on 16 July 2025. The proposal includes 
greater use of financial instruments, budgetary guarantees and loans backed by the EU budget 
to:  i)  increase  leverage;  ii),  allow  the  EU  budget  to  play  a  stronger  role  in  de-risking  private 
investment; and iii) unlock financing by institutional investors.  

On the side of budgetary guarantees and financial instruments, the proposal includes one EU 
budgetary  guarantee  for  internal  policies,  provided  for  in  the  basic  act  for  the  European 
Competitiveness  Fund  (ECF)  and  one  for  external  policies  (with  a  subceiling  for  Ukraine), 
established in the basic act for Global Europe (GE). Other programmes in internal and external 
policies may also use the guarantees provided for in the ECF and the GE. 

The  ECF  and  GE  have  been  endowed  with  a  maximum  budgetary  guarantee  amount  of 
EUR 70 billion and EUR 143 billion respectively (the latter including EUR 48 billion for budgetary 
guarantees for Ukraine financed through the Ukraine reserve). The different programmes may 

22 If there is no agreement on the legislative proposals for 2028-2034, the current own resources ceiling of 1.4% of 
EU GNI will continue to apply and in accordance with the provisions of Article 312(4) TFEU, the ‘ceilings and other 
provisions  corresponding  to  the  last  year  of  financial  framework  shall  be  extended’.  In  such  a  scenario,  thehe 
sustainability of the headroom under the permanent own resources ceilign will be assured albeit with a smaller 
policy expenditure capacity than proposed and than in the current MFF, taking into account NGEU repayment. 
23  See  paragraphs  3.2  and  4.2  of the  report  from  the  Commission  to  the  European  Parliament and  the  Council  on 
financial  instruments,  budgetary  guarantees,  financial  assistance  and  contingent  liabilities  -  situation  at  31 
December 2020 (COM(2021) 676 final of 5.11.2021). 

24  The Steering Committee on Contingent Liabilities (SCCL) met five times in 2024. 
25  Commission Decision (EU, Euratom) 2025/369 of 21 February 2025 establishing the role of the Chief Risk Officer 

overseeing the financial risks arising from the Union’s financial operations (OJ L, 2025/369, 25.2.2025). 

26   Report from the Commission to the European Parliament and the Council on the common provisioning fund in 2024 

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52025DC0400 

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gradually  use  the  entire  capacity.  The GE  maximum  amount  will  also  cover  loans  to  non-EU 
countries (e.g. macro-financial assistance, policy-based loans and Euratom). 

The Commission’s long-term budget proposal also includes the further use of loans to Member 
States and to Ukraine backed by the EU budget’s headroom. 

In the case of Ukraine, the proposed Ukraine Reserve of EUR 100 billion will be implemented in 
the form of loans and grants, with the loans to be financed by borrowing and backed by the 
headroom as in the case of, for example, the Ukraine Facility. The actual split between loans 
and grants will be decided depending on needs. 

The  Commission  also  proposes  the  greater  use  of  loans  to  Member  States,  as  part  of  the 
National and Regional Partnership Plans’ ‘Catalyst Europe’ programme. Catalyst Europe would 
provide up to EUR 150 billion in loans financed by borrowing and backed by the headroom to 
support reforms and investments. 

Finally, the Commission has also proposed a new extraordinary and temporary mechanism to 
respond to the consequences of severe crises, severe hardship or serious threats  of hardship 
affecting the EU or its Member States. This tool will provide loans to Member States backed by 
EU  borrowing  solely  for  the  period  of  the  upcoming long-term  budget  should a  severe  crisis 
occur and upon decision of the Council, after obtaining the consent of the European Parliament. 
The  borrowing  would  be  guaranteed  by  a  specific,  additional  compartment  under  the  own 
resources ceiling equal to 0.25% of EU GNI which will have the sole purpose of backing these 
loans, should the mechanism be activated. 

The  sustainability  of  future  contingent  liabilities  related  to  the  implementation  of  both  new 
instruments proposed under the next MFF, and other instruments adopted or implemented in 
2025 (i.e. the Ukraine Loan Cooperation Mechanism and the Security Action for Europe loans) 
depend  on  the  actual  take  up  of  loan  support  and  will  be  assessed  in  future  editions.  The 
sustainability of the extraordinary mechanism to respond to severe crises will only be assessed 
if and when actual financial assistance is provided under this ceiling. 

2. Analysis  of  the  different  sources  of  contingent 

liabilities  

2.1  Budgetary guarantees  

These are guarantees provided to different implementing partners under the mandates for ELM, 
EFSI, EFSD, InvestEU, EFSD+ and UIF (Ukraine Investment Facility27). Under all these instruments, 
the EU provides guarantees to implementing partners28 to cover a share of potential losses and 
costs29 resulting from their financing and investment operations (i.e. debt or equity operations). 

The six guarantee programmes have a different geographical  focus,  which influences the risks 
they bear. The EFSI and InvestEU help to overcome investment gaps within the European Union. 
The  ELM,  EFSD  and  EFSD+  form  part  of  the  European  Union’s  external  policies  and  support 
financing  and  investment in  non-EU  countries  (with  the  ELM  and  EFSD+  Investment  Window  1 
mainly  focusing  on  sovereign  counterparts,  while  the  EFSD  and  EFSD+  Open  Architecture  and 
Investment Window 4 mainly targets private operations). The UIF aims to support recovery and 

27  Regulation (EU) 2024/792 of the European Parliament and of the Council of 29 February 2024 establishing the 

Ukraine Facility https://eur-lex.europa.eu/eli/reg/2024/792/oj/eng 

28  In  2024,  the  EU  provided  budgetary  support  in  the  form  of  guarantees  to  the  EIB  Group  and  to  other  financial 
institutions (including EBRD and National Promotional Banks) under the different existing guarantee programmes. 

29  In some cases, the guarantee can also cover additional items such as funding costs and other fees. 

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reconstruction  investments  in  Ukraine  undertaken  by  the  Ukrainian  authorities,  private  sector 
companies, municipalities, state-owned enterprises or other actors. 

Table 1: State of play of budgetary guarantees (as at 31 December 2024) (EUR million)(*) 

Max. available guarantee 
signed with 
implementing partners  

Available guarantee 
related to operations 
signed by implementing 
partners with final 
recipients 

Available guarantee 
related to operations 
signed by implementing 
partners and disbursed 
to final recipients 

EFSI 

EFSD 

ELM 

InvestEU 

UIF 

EFSD+ 

Total 

25 373 

759 

25 772 

27 042 

790 

30 173 

109 909 

22 998 

667 

25 772 

11 769 

172 

11 228 

72 606 

21 033 

521 

19 184 

3 468 

132 

1 341 

45 678 

(*)  The  guarantee  signed  with  counterparts  represents  the  amount  of  the  guarantee  granted  to  the 
implementing  partner  through  the  signature  of  the  guarantee  agreement.  The  guarantee  related  to 
operations  signed  by  counterparts  includes  amounts  of  the  guarantee  in  all  operations  signed  by  the 
counterparts with the final recipients/financial intermediaries. The guarantee related to operations signed 
and disbursed includes the amounts of operations disbursed from the counterpart to the final recipient/the 
financial intermediaries. 

a) Budgetary guarantees to support investment outside the EU 

The ELM is the oldest EU budgetary guarantee. It enables the European Investment Bank (EIB) to 
undertake  financing  operations  in  riskier  environments  outside  the  EU  in  areas  such  as  the 
development of socio-economic infrastructure.  

In  2017,  the  EFSD  guarantee  was  put  in  place to  support  investments  and  improve  access  to 
finance - primarily in Africa and the ‘neighbourhood’ countries bordering the EU - and help those 
countries meet the UN Sustainable Development Goals.  

Building on the experience of both the ELM and the EFSD, the EFSD+ was set-up for the 2021-
2027 MFF period as an integrated financial package providing financing capacity to sub-Saharan 
Africa,  Asia,  the  Pacific  region,  Latin  America,  the  Caribbean  and  the  neighbourhood  and 
enlargement countries. Support under the EFSD+ is directed to investment that contributes to: (i) 
reducing  socio-economic  inequalities;  (ii)  sustainable  and  inclusive  growth;  (iii)  climate  change 
adaptation and mitigation; (iv) environmental protection and management; and (v) job creation. 

The UIF is designed to provide financing to priorities identified in the Ukraine Plan30. The UIF is 
part  of  the  Ukraine  Facility  Regulation  (UFR),  the  objective  of  which  is  to:  i)  attract  public  and 
private investments for the recovery and reconstruction of Ukraine; and ii) support Ukraine’s path 
towards EU accession31. 

30 https://enlargement.ec.europa.eu/proposal-council-implementing-decision-approval-assessment-ukraine-plan_en 
31 https://enlargement.ec.europa.eu/news/commission-endorses-ukraine-plan-paving-way-regular-payments-under-

ukraine-facility-2024-04-15_en 

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b) Budgetary guarantees to support investment within the EU 

In 2015, the EFSI was launched to remedy the problem of prolonged subdued private investment 
in the EU following the financial crisis. It takes the form of a maximum EUR 26 billion budgetary 
guarantee from the EU budget to the EIB Group, which is supplemented by an allocation from the 
EIB’s own resources of EUR 7.5 billion.  

Launched  under  the  2021-2027  MFF,  the  InvestEU  programme  aims  to  ensure  an  additional 
boost to investments fostering  economic recovery, resilience, green growth and employment in 
the EU over the 2021-2027 period. It seeks to achieve this goal by mobilising public and private 
financing sources, to provide long-term funding and support to companies and projects in line with 
the EU’s priorities in the current challenging economic and social context.  

c) Comparative analysis of budgetary guarantees  

The  six  budgetary  guarantee  programmes  vary  in  respect  of  several  features,  including  their 
different stages of implementation. While the ELM (established in 1977) has a long track record, 
the EFSI and EFSD constitution periods ended only in 2022 and 2024 respectively. At the same 
time, the investment phase of InvestEU, the EFSD+ and the UIF has started more recently. These 
different stages of implementation for the six budgetary guarantee programmes are reflected in 
the table above. For the ELM and EFSI, the figures show that almost the maximum amount of the 
guarantees have been pledged to implementing partners and the latter have committed to support 
operations up to these full amounts. Newer budgetary guarantees such as the EFSD+, InvestEU 
and UIF, by contrast, are at a much earlier stage in their ramp-up.  

The  new  budgetary  guarantees  such  as  InvestEU,  the  EFSD+  and  the  UIF  have  built  on  the 
experience of older guarantees and have similar features. However, InvestEU, the EFSD+ and the 
UIF all have more implementing partners (‘open architecture’) and a broader variety of products. 

2.2  Provisioned loans for financial assistance to non-EU countries  

The contingent liabilities under this heading arise from financial assistance provided in the form 
of  Macro-Financial  Assistance  programme  (MFA)32  loans  and  Euratom  loans  to  non-EU 
countries33.  Loans  granted  to  Ukraine  under  the  MFA+  programme  and  the  Ukraine  Facility, 
amounting  to  EUR  31.1  billion  at  the  end  of  2024,  are  backed  by  the  headroom  and  will  be 
discussed in Section 2.3. 

Financial support to non-EU countries in the form of bilateral loans from the EU has been granted 
mainly  under  the  MFA  programme,  which  targets  non-EU  countries  experiencing  a  balance-of-
payments crisis. In 2024, new MFA loans amounting to EUR 1.15 billion were disbursed34.  

In the Western Balkans Investment Framework (WBIF), arrangements to provide loans of up to 
EUR 4 billion to six enlargement candidate countries were put in place in 2024 with disbursement 
of the first instalments to commence in 2025. A separate loan facility has also been set up for 
Moldova (EUR 1.5 billion) – disbursement also set to commence in 2025. In addition to MFA loans 

32  The legal basis for MFA to non-EU countries other than developing countries is Article 212 of the Treaty on the 
Functioning of the European Union (TFEU). Article 213 TFEU may be  used as a legal basis when a  third country 
requires urgent financial assistance. 

33  The Euratom loan facility helps both Member States and  non-EU countries finance investments in nuclear power 
stations and in industrial installations in the nuclear fuel cycle. See Council Decision 77/270/Euratom of 29 March 
1977 empowering the Commission to issue Euratom loans for the purpose of contributing to the financing of nuclear 
power stations (OJ L 88, 6.4.1977, p. 9) as amended and supplemented. 

34  These include EUR 1 billion to Egypt, EUR 95 million to Moldova and EUR 50 million to North Macedonia. For more 
details,  including  the  outstanding  amount  per  individual  beneficiary,  see  the  report  from  the  Commission  to  the 
European Parliament and the Council on the implementation of macro-financial assistance to non-EU countries in 
2024 COM(2025) 330 final of 23.6.2025 and the accompanying SWD(2025) 166 final of 23.6.2025.  

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to  non-EU  country  sovereigns,  EUR 300 million  in  Euratom  loans,  which  were  provided  to  the 
Ukrainian nuclear energy programme are still outstanding as at 31 December 2024. 

Table 2: Outstanding amounts in respect of loans to non-EU countries* (as at 31 December 2024) 
(EUR million) 

Outstanding loans  Accrued interests 

Total 

MFA(*)  

Euratom 

Total  

15 738 

300 

16 038 

118 

1 

119 

15 856 

301 

16 157 

(*) Excluding Ukraine MFA+ loans and Ukraine Facility loans (backed by the headroom). 

Traditionally,  loans  to  non-EU  countries  have  been  funded  through  ‘back-to-back’  borrowing 
operations, i.e. each loan has been funded with a corresponding EU bond that fully matches the 
EU loan in terms of its maturity, interest rate and repayment schedule. As of January 2023,  a 
difference  approach  -  the  unified  funding  approach  -  has  been  established  as  the  general 
borrowing method for EU bonds35. Under the unified funding approach, the Commission collects 
all  issuance  proceeds  in  a  centralised  funding  pool  and  then  internally  allocates  them  to  the 
different policy programmes. Investors in EU bonds are exposed to the EU’s low credit risk and not 
to the credit risk of the ultimate beneficiary country. The liability for the EU is contingent because 
the beneficiary country is contractually obliged to provide the revenue flow to repay the EU bonds. 
As long as the loan beneficiary is not in default, no outflow of EU resources is necessary to settle 
the EU debt. 

As  contingency  against  the  eventuality  that  the  beneficiary  country  does  not  repay  interest  or 
principal on the loan received, the EU budget sets aside provisions for these loans. Traditionally 
and in line with existing legislation, 9% of the value of the loans is held as provisions for MFA or 
Euratom  loans  to  non-EU  countries  in  dedicated  compartments  in  the  CPF.  The  levels  of 
provisioning against these loans are discussed further in Section 3.2. 

The repayment amounts reported in Table 3 are therefore to be seen as the maximum foreseeable 
amounts that could be called against provisions in the years 2025-2030. 

Table  3:  Yearly  repayment  schedule  of  outstanding  provisioned  loans  to  non-EU  countries 
(principal + interest) under the existing programmes for the years 2025-2030 (as at 31 December 
2024)  
(EUR million) 

Year 

2025 

2026 

2027 

2028 

2029 

2030 

Total 

Euratom 

MFA 

All programmes 

1 

1 

51 

51 

0 

100 

204 

162 

410 

442 

441 

1 185 

308 

2 948 

163 

411 

493 

492 

1 185 

408 

3 152 

35  Regulation (EU, Euratom) 2022/2434 of the European Parliament and of the Council of 6 December 2022 amending 
Regulation (EU, Euratom) 2018/1046 as regards the establishment of a diversified funding strategy as a general 
borrowing method. 

8 

 
 
 
2.3  Headroom-backed loans  

The contingent liabilities under this heading arise from loans to Member States (i.e. loans under 
Balance of Payments (BoP) Facility36, European Financial Stabilisation Mechanism (EFSM) loans37, 
Euratom Facility loans, loans under SURE38 and loans under the RRF which are provided to support 
investments  and  reforms).  In  addition,  loans  to  Ukraine  granted  in  2023  and  2024  (EUR  18 
billion in MFA+ loans to Ukraine and EUR 13.1 billion in loans granted under the Ukraine Facility) 
are also backed by the budgetary headroom under the own resources ceiling. 

Contingent liabilities stemming from loans to Member States and from recent loans to Ukraine are 
not provisioned ex ante. Instead, they are back-stopped by the possibility of calling on additional 
‘own resources’ from Member States under the EU’s budgetary framework (up to the limits of the 
own resources ceiling, i.e. using the ‘headroom’ of the budget). 

This means that, if a beneficiary did not honour its obligations towards the EU, the EU would be 
entitled – as a last resort and only after having exhausted all other possibilities to find solutions 
within the existing multiannual financial framework – to call on the Member States to cover the 
amount in question. Such calls for funds would be made over and above the MFF ceilings, but in 
full compliance with the own resources ceilings. 

More  recent  loans  (RRF  loans  and  loans  under  the  Ukraine  MFA+  Instrument  and  the  Ukraine 
Facility)  are  financed  through  the  unified  funding  approach,  where  loans  to  beneficiaries  are 
granted with long durations, typically an extended period where principal is not repaid followed by 
a lengthy period with small annual principal reamortisation39.  

In 2024 the Commission, acting on behalf of the EU, operated four programmes under which it 
granted loans to Member States. No new loans were disbursed under the first three programmes 
in 2024. Details of these four programmes are set out in the bullet points below. 

•  The  BoP  Facility  was  created  in  2002  to  help  EU  countries  outside  the  euro  area  that 

experience - or run the risk of experiencing - balance of payments difficulties. 

•  The EFSM was put in place in 2010 to provide financial support to Member States experiencing 
-  or  threatened  by  -  severe  financial  difficulties  caused  by  exceptional  events  beyond  their 
control. 

•  The SURE programme was agreed in June 2020 to help finance sudden and severe increases 
in  national  public  expenditure  related  to  national  short-time  work  schemes  and  similar 
measures in response to the COVID-19 crisis. As this emergency instrument was put in place 
before the 2020 increase in the own resources ceiling40 and headroom entered into effect, all 
Member States have agreed to provide irrevocable, unconditional and on-demand guarantees 

36  Council Regulation (EC) No 332/2002 of 18 February 2002 establishing a facility providing medium-term financial 

assistance for Member States' balances of payments (OJ L 53, 23.2.2002, p. 1). 

37  Council Regulation (EU) No 407/2010 of 11 May 2010 establishing a European financial stabilisation mechanism 
(OJ L 118, 12.5.2010, p. 1). Council Regulation (EU) 2015/1360 of  4 August 2015 amending Regulation (EU) No 
407/2010 establishing a European financial stabilisation mechanism (OJ L 210, 7.8.2015, p. 1). 

38  Council Regulation (EU) No 2020/672 of 19 May 2020 on the establishment of a European instrument for temporary 
support  to  mitigate  unemployment  risks  in  an  emergency  (SURE)  following  the  COVID-19  outbreak  (OJ  L  159, 
20.5.2020, p. 1). 

39  At the end of 2022, the diversified funding strategy was established as the baseline method for the implementation 
of all borrowing operations including MFAs. It makes it possible to fully delink a specific  disbursement of loans to a 
Member State or a non-EU country from the issuance of specific EU bonds. Under NGEU the Commission also borrows 
on  the  markets  to  finance  non-repayable  support  (including  RRF  grants).  The  repayment  of  these  borrowing 
operations is covered through the appropriations of the future annual budgets, within the ceilings of the MFFs, and 
therefore does not constitute a contingent liability for the EU. Nevertheless, the NGEU borrowing-to-lend activities 
(i.e. to fund RRF loans) do give rise to new contingent liabilities and are addressed in this report. 

40  Council Decision (EU, Euratom) 2020/2053 of 14 December 2020 on the system of own resources of the European 

Union and repealing Decision 2014/335/EU. 

9 

 
 
 
for 25% of the maximum amount of financial assistance41 . Each Member State contributes to 
the overall amount of the guarantee proportionate to its relative share in the total GNI of the 
EU (based on the 2020 EU budget). 

•  The  RRF  is  the  central  pillar  of  the  NextGenerationEU (NGEU)  programme (2020)42  and  is  a 
temporary instrument to support reforms and investments in Member States with the ultimate 
goal of facilitating recovery from the COVID-19 pandemic while supporting the green and digital 
transitions. Under the EU recovery instrument, the Commission borrows funds which the RRF 
then uses to finance Member States’ reforms and investments. The financing can be either a 
loan (repayable support) or a grant (non-repayable support). Only RRF loans (as opposed to RRF 
grants) give rise to contingent liabilities, and therefore only RRF loans are considered for the 
purposes of this report.  

At the end of 2024, the EU budget had incurred contingent liabilities from  two programmes in 
support of Ukraine which were booked against the headroom. The first of these programmes is 
MFA+, for which outstanding amounts reached EUR 18 billion at end-2023 with no new additional 
loans disbursed in 2024. The second of these programmes is, the Ukraine Facility (EUR 13.1 
billion outstanding at the end of 2024). Interest costs under both programmes are subsidised in 
the  period  to  end-2027  to  increase  the  concessionality  of  those  loans,  with  different 
arrangements. Member States cover the interest costs of MFA+ loans through external assigned 
revenue through the EU budget, while the EU  budget covers  the  interest  rate costs on  Ukraine 
Facility loans.  

Table  4:  Disbursed  loans  backed  by  EU  budgetary  headroom  (as  at  31 December  2024) 
(EUR million) 

Disbursed loans 

Accrued interests 

Total 

BoP Facility 

EFSM 

SURE 

RRF (loans) 

MFA + 

Ukraine Facility 

Total 

200 

42 000 

98 355 

108 686 

18 000 

13 112 

280 353 

1 

380 

104 

201 

42 380 

98 459 

1 434 

110 120 

273 

205 

18 273 

13 317 

2 397 

282 750 

Between end-2023 and end-2024, the most significant increase was in the RRF loans, which rose 
from  EUR  79.6  billion  to  EUR  110.1  billion  —  an  increase  of  EUR  30.5  billion  since  end-2023 
(+38.3%). Overall, the total outstanding amounts increased from EUR 239.7 billion at end-2023 
to EUR 282.8 billion at end-2024, representing an increase of EUR 43.0 billion (+17.9%). 

Table 5 below presents the amounts of total yearly repayments (principal plus interest) due by all 
the beneficiaries of the EU loans granted in the context of: i) the financial assistance to Member 
States, and ii) financial assistance to Ukraine under the MFA+ and Ukraine Facility instruments.  

41  In addition to the guarantee provided by all Member States, there are a number of safeguards laid down in the SURE 
Regulation to mitigate the risk  from SURE contingent liabilities. These include a concentration limit on the three 
largest  loans  of  60%  of  the  maximum  amount  granted  under  SURE,  a  maximum  annual  exposure  of  10%  (i.e. 
payments due each year  may not exceed EUR 10 billion), and the possibility for the Commission to roll over its 
borrowings if necessary. 

42  Council Regulation (EU) 2020/2094 establishing a European Union Recovery Instrument to support the recovery in 

the aftermath of the COVID-19 crisis (OJ L 433 I, 22.12.2020, p. 23). 

10 

 
 
 
For each of the years under consideration, these amounts provide an indicator of the theoretical 
maximum outflow to be covered by the EU budget in relation to the contingent liabilities arising 
from financial assistance to Member States and Ukraine at the end of 2024. 

Over  the  time  horizon  of the  next  MFF  (until  2034),  principal  and  interest  repayments by  loan 
beneficiaries (i.e. excluding RRF loans) relevant for the permanent ceiling amount to EUR 9.2 billion 
on average each year. Principal and interest repayments by loan beneficiaries backed by the NGEU 
ceiling (i.e. RRF loans) are on average EUR 2.8 billion a year over the period 2025-2034.  

Table 5: Yearly repayment schedule of outstanding headroom-backed loans (capital + interest) 
under the existing programmes for the years 2025-2030 (as at 31 December 2024) (EUR million) 

Year 

BoP 

EFSM 

SURE 

RRF loans 
(*) 

MFA+ 
(**) 

Ukraine 
Facility(***) 

All 
programmes 

2025 

206 

306 

8 217 

2 215 

2026 

2027 

2028 

2029 

2030 

0 

0 

0 

0 

0 

6 913 

8 327 

2 216 

3 587 

327 

2 216 

4 612 

10 327 

2 219 

1 790 

8 464 

2 218 

371 

10 327 

2 216 

570 

570 

570 

571 

571 

570 

320 

391 

391 

392 

391 

391 

Total 

206  17 579  45 989 

13 300  3 423 

2 277 

11 834 

18 417 

7 091 

18 121 

13 434 

13 875 

82 772  

(*) Interest for RRF loans under the NGEU programme is calculated on a rolling basis according to a specific 
methodology  (see  Commission  implementing  decision  C(2022)9701  final  of  19.12.2022).  The  annual 
interest charge for these loans presented above is therefore an estimate based on current funding conditions. 
(**) In accordance with Article 17 of Regulation (EU) 2022/2463, each year, upon Ukraine’s request, the EU 
may grant an interest rate subsidy to cover interest costs related to MFA+ loans. 
(***) In accordance with Article 23 of Regulation (EU) 2024/792 Ukraine may request each year an interest 
rate subsidy to cover interest costs related to the loans granted under the Ukraine Facility. 

11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.4  Overview of contingent liabilities at the end of 2024 

At the end of 2024, the EU budget was exposed to contingent liabilities for a total amount of EUR 
410 billion, which can be broken down into: i) over EUR 300 billion relating to loans granted to 
Member  States  and  non-EU  countries;  and  ii)  EUR 110 billion  relating  to  guarantees  provided 
through the EFSI, InvestEU, ELM, EFSD, EFSD+, and the UIF. The largest set of exposures for the 
EU budget originates from loan programmes to Member States.  

Figure 1: Breakdown of contingent liabilities by source (as at 31 December 2024) 

Financial assistance 
to MS
(headroom)
61%

Financial assistance to non-
EU countries
4%

Financial assistance to 
Ukraine
(headrooom)
8%

Budgetary guarantees 
27% (*)

(*) Based on the total amount of ‘Max. available guarantee signed with impl. partners’ (see Table 1). 

The increasing importance of budgetary guarantees and financial assistance programmes for the 
implementation of EU policies can be seen in the constant upward trend in the period 2021-2024. 
The increase recorded in 2024 (+13% compared with the previous year) is in line with the increase 
registered between year-end 2022 and year-end 2023, +16%). This compares with the marked 
40% increase seen between year-end 2021 and year-end 2022, starting from a lower base. 

12 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 2: Breakdown of outstanding contingent liabilities by source in the period 2021-2024 (EUR 
billion) 

260

240

220

200

180

160

140

120

100

80

60

40

20

0

252

221

191

155

106

108

110

60

15

16

16

8

32

18

Budgetary guarantees

Financial assistance to
MS
(headroom)

Financial assistance to
non-EU countries (MFA +
Euratom loans)

Financial assistance to
Ukraine
(headroom)

2021

2022

2023

2024

The bulk of the 2024 increase is accounted for by the additional loan disbursements under the 
RRF and the financial assistance to Ukraine. Contingent liabilities stemming from the budgetary 
guarantee programmes remained largely stable in 2024. The increase in liabilities arising from 
the  budgetary  guarantee  programmes  due  to  the  start  of  the  implementation  phase  for  the 
InvestEU, EFSD+ and UIF was almost entirely compensated by the decline in the ELM, EFSI and 
EFSD exposures due to maturing or cancelled exposures.  

EU contingent liabilities have increased further in 2025 in relation to:  

(i)  additional  support  to  non-EU  countries  (in  particular  support  to  Ukraine  under  the  Ukraine 
Facility and ‘Extraordinary Revenue Acceleration’ (ERA) MFA loan43);  

(ii) additional disbursements of RRF loans to Member States;  

(iii) further progress in the implementation of the budgetary guarantee programmes (InvestEU, 
EFSD+ and the UIF); and  

(iv) implementation  of the  newly approved  MFA programmes to Egypt44 and Jordan45, together 
with  the  implementation  of  the  Western  Balkans  Investment  Framework  (WBIF)46  and Moldova 
Facility47. 

Disbursement  of  the  loans  to  Member  States  under  the  Security  Action  for  Europe  (SAFE) 
programme will commence in early 202648. 

43  Regulation (EU) 2024/2773 of the European Parliament and of  the Council of 24 October 2024 establishing the 

Ukraine Loan Cooperation Mechanism and providing exceptional macro-financial assistance to Ukraine. 

44  Decision (EU) 2025/1267 of the European Parliament and of the Council of 24 June 2025 providing macro-financial 

assistance to the Arab Republic of Egypt. 

45  Decision (EU) 2025/793 of the European Parliament and of the Council of 14 April 2025 providing macro-financial 

assistance to the Hashemite Kingdom of Jordan. 

46  Regulation (EU) 2024/1449 of the  European Parliament and of the Council of 14 May 2024 on establishing the 

Reform and Growth Facility for the Western Balkans. 

47  Regulation (EU) 2025/535 of the European Parliament and of the Council of 18 March 2025 establishing the Reform 

and Growth Facility for the Republic of Moldova. 

48  Council Regulation (EU) 2025/1106 of 27 May 2025 establishing the Security Action for Europe (SAFE) through the 

Reinforcement of the European Defence Industry Instrument.  

13 

 
 
 
3. Assessing  the  sustainability  of  EU  contingent 

liabilities  

3.1  Assessment framework 

Without prejudice to the assessment of provisioning of certain financial liabilities over their entire 
lifetime  that  is  required  when  liabilities  are  incurred,  Article  213(3)  of  the  Financial  Regulation 
stipulates  that  ‘contingent  liabilities  arising  from  budgetary  guarantees  or  financial  assistance 
borne  by  the  budget  shall  be  deemed  sustainable  if  their  forecast  multiannual  evolution  is 
compatible with the limits set by the regulation laying down the MFF provided for in Article 312(2) 
TFEU  and  the  ceiling  on  annual  payment  appropriations  set  out  in  Article  3(1)  of  Decision (EU, 
Euratom) 2020/2053.’ (i.e. the MFF ceilings and the own resources ceiling). 

This means that the resources that the EU is able to draw on in a single year under the current 
MFF and own resources ceiling should be enough to finance the expenditures arising under the 
MFF as well as any arising contingent liabilities.  

In particular, payments relating to provisioned contingent liabilities for budgetary guarantees 
and financial assistance to non-EU countries must be financed from the laid down provisions and 
any further provisioning payments planned under the MFF. Section 3.2 of this report presents an 
assessment of the adequacy of the available provisions to meet the expected and unexpected 
payments arising from budgetary guarantees and financial assistance to non-EU countries for the 
liabilities as they stood at the end of 2024. 

Payments  related  to  materialising  contingent  liabilities  resulting  from  headroom-backed 
financial assistance to Member States and to Ukraine can be financed by calling on additional 
own resources up to the ceiling laid down by the ORD as a last resort after other means to cover 
those payments or re-schedule the related liabilities. The headroom (i.e. difference between the 
own resources ceiling and the own resources necessary to finance the EU budget expenditures) 
represents the EU’s financial capacity to cover additional outflows relating to the materialisation 
of contingent liabilities arising from headroom-backed financial assistance49. The results of the 
assessment of the sustainability of headroom-backed contingent liabilities existing at the end of 
2024 are presented in Section 3.3 below. The 2020 ORD temporarily increases the own resources 
ceiling (by up to an additional 0.6% of GNI until 2058) to cater for the liabilities incurred during 
the implementation of  the  NGEU, including headroom-backed contingent liabilities arising from 
RRF loans to Member States. 

3.2  Assessment of the sustainability of the provisioned contingent 

liabilities 

a) Provisioning available at end of 2024 

Contingent liabilities arising from budgetary guarantees and from financial assistance to non-EU 
countries are provisioned for in the EU budget based on a conservative assessment of the lifetime 
expected  losses  for  each  instrument  plus  an  additional  safety  buffer  (to  cater  for  unexpected 
losses). The provisions protecting the EU budget against losses  that may arise from budgetary 
guarantees and financial assistance to non-EU countries are held in the CPF.  

As at 31 December 2024, the market value of net assets in the CPF amounted to EUR 23.2 billion, 
up from EUR 18.8 billion at the end of 202350. For the remaining years of this MFF, the Commission 
will build up additional provisions to the CPF (in particular provisions related to InvestEU, the EFSD+ 
and the Ukraine Guarantee), which will lead to further increases in the size of the CPF. 

49  The assessment framework for this set of  contingent liabilities was described in detail in the 2021 issue of this 

report i.e. COM(2021) 676 final of 5.11.2021. 

50  In 2024, the CPF received EUR 3.6 billion of net contributions from the EU budget or contributed by participating 

Member States and countries in the European Free Trade Area (EFTA). 

14 

 
 
As per the Asset Management Guidelines, the CPF maintains a liquid diversified portfolio, primarily 
investing in highly-rated debt instruments, such as bonds issued by governments, supra-nationals, 
state agencies and corporates with the aim of delivering capital preservation over its investment 
horizon. The CPF portfolio at year-end was well diversified across the different asset classes in 
the  eligible  fixed  income  universe,  including  some  limited  exposure  to  non-euro  denominated 
securities, equity exchange-traded funds (ETFs) and cash or cash equivalents.  

In  2024  the  CPF  achieved  an  annual  return  of  +3.57%,  exceeding  its  portfolio  benchmark 
(+3.31%)51.  

While the funds held in the CPF are managed in accordance with a single investment policy and 
using a common infrastructure, the provisions are earmarked as belonging to the programme (or 
Member State) that is the source of the budgetary provisioning. 

On  31  December  2024,  the  CPF  was  composed  of  18  compartments  (15  of  which  were  fully 
operational  and  contained  funds),  including  the  compartments  for  all  the  on-going  guarantee 
programmes and the Guarantee Fund for External Action (GFEA) compartment (that covers legacy 
ELM, Euratom and MFA loans) and those for the post 2020 MFA and Euratom loans. Of the 18 
compartments,  11  related  to  EU  exposures  and  7  were  Member  State  compartments  under 
InvestEU where the contributing Member States own the provisions and are solely responsible for 
the associated contingent liabilities. 

The  provisions  for  the  MFA  and  Euratom  loans  are  spread  over  a  number  of  different  CPF 
compartments: 

• 

• 

• 

the legacy exposures (EUR 7.3 billion of MFA loans and EUR 300 million of Euratom loans) 
are part of the GFEA compartment; 

the new MFA loans (EUR 2.7 billion) committed after 2020, including the 2022 1.2 billion 
emergency MFA loan to Ukraine, are in the post-2020 MFA compartment; 

the exceptional MFA loans to Ukraine of EUR 6 billion (exceptional MFA I and MFA II) are in 
a separate compartment given that these loans benefit from supplementary coverage of 
risks (i.e.  for this exceptional  MFA loans package to Ukraine, a coverage rate of 70% is 
required: 9% paid-in provisioning from the EU budget and 61% of callable guarantees from 
Member States). 

51  For additional information see the Report from the Commission to the European Parliament and the Council on the 

Common Provisioning Fund in 2024. 

15 

 
 
 
 
 
 
 
 
 
 
 
 
Table 6: CPF compartments (as at 31 December 2024) 

Compartment 

Market value in EUR 

Compartments opened in 2021 

EFSI 

GFEA52 

EFSD  
InvestEU53 

Compartments opened in 2022 

EFSD+ 

Post-2020 MFA 

Exceptional MFA Ukraine54 

Post-2020 Euratom loans 

Repurposed ELM loans Ukraine 

InvestEU Guarantee Romania 

InvestEU Guarantee Czechia 

InvestEU Guarantee Finland 

InvestEU Guarantee Greece 

InvestEU Blending Operations 

Compartments opened in 2023 

InvestEU Guarantee Bulgaria 

InvestEU Guarantee Malta 

Compartments opened in 2024 

Ukraine Guarantee 

InvestEU Guarantee Spain 

TOTAL 

8 880 303 796 

3 225 691 236 

761 545 053 

5 530 142 834 

2 942 175 755 

128 662 218 

240 575 443 

- 

- 

187 974 119 

44 099 187 

30 657 774 

252 204 112 

667 045 123 

79 674 706 

7 939 418 

201 878 310 

- 

23 180 569 085 

b) Assessment of sustainability of budgetary guarantees 

As explained in Section 2.1, EU budgetary guarantees differ substantially in terms of the policy 
objectives, risk sharing structures and risk profile of the underlying operations. This can in turn 
lead to a different provisioning rate for different programmes, based on a lifetime value-at-risk 
(VaR)55 which ensures appropriate coverage of potential losses at a certain (predefined) confidence 
level.  The  analysis  carried  out  as  part  of  the  latest  report  on  Article  41(5)  of  the  Financial 

52  Guarantee Fund for external actions (GFEA), holding the provisions for the External Lending Mandate (ELM), legacy 

MFA and Euratom programmes. 

53  EU Compartment. 
54  Under Decision (EU) 2022/12018 and Decision (EU) 2022/1628 providing exceptional macro-financial assistance to 

Ukraine. 

55  The VaR can be defined as the portfolio loss level which, statistically, over a certain time horizon, will not be exceeded 
with  a  certain  confidence  level.  The  respective  confidence  levels  for  internal  programmes  (EFSI,  InvestEU)  and 
external  programmes  (EFSD,  EFSD+)  are  95%  and  90%  respectively  and  take  into  account  factors  such  as  the 
different policy objectives and the respective frameworks. 

16 

 
 
 
 
 
 
 
Regulation confirms that the available provisioning amounts for the relevant CPF compartments 
are in line with the requirements of the respective regulations. For the EFSI and EFSD programmes, 
surplus provisioning was identified. 

The  following  conclusions  can  be  drawn  from  the  available  data  on  lifetime  net  losses  on 
31 December 2024 concerning the budgetary guarantees in place on that date: 

•  The  EFSI  is  a  budgetary  guarantee  fully  constituted  for  which  the  eligible  period  for 
signatures  elapsed  at  the  end  of  2022.  Therefore,  the  Commission  must  carry  out  the 
surplus/replenishment  assessment  required  under  Article  216(4)  of  the  Financial 
Regulation. The Commission concluded this year that the EFSI target provisioning rate of 
35% is still appropriate (i.e. the risk assessment based on the Value at Risk (VaR) analysis 
with a confidence level of 95% suggested a required provisioning rate of 34% (up from 
31%  in  the  previous  year)).  Current  provisioning  held  against  EFSI  exposures  (38.7%) 
exceeds the target provisioning rate of 35%. It is legally laid down that this excess EFSI 
provisioning  of EUR 853 million  can  be  used to finance the provisioning cost of the EU 
guarantee  under  InvestEU  and  the  remaining  part  will  finance  the  Public  Sector  Loan 
Facility. 

•  The EFSD is also fully constituted as of the end of 2024. Risk analysis shows that at this 
juncture the target provisioning rate of 50% is still appropriate. Compared with the relevant 
benchmark56, there is excess provisioning of EUR 321.4 million, and based on the target 
provisioning rate the surplus is EUR 405 million.  

•  The GFEA, which holds the provisioning for pre-2021 MFA loans, Euratom loan, and the 
ELM,  currently  has  a  de  facto  provisioning  rate  of  9.96%  (without  considering  the  ELM 
repurposed loans to Ukraine), which compares with a target provisioning rate laid down in 
the  GFEA  Regulation  of  9%.  For  ELM  repurposed  loans  to  Ukraine,  the  Commission 
considers that a provisioning rate of 70% is still appropriate.  

• 

InvestEU, the EFSD+ and the UIF are still in the ramp-up phase which means that the 
underlying portfolios and provisioning are not yet fully constituted. Therefore, it is too early 
to draw conclusions about the adequacy of the provisioning rates for these guarantees.  

c) Assessment of sustainability of provisioned loans to non-EU countries 

The composition of the outstanding MFA loan portfolio to non-EU countries comprises loans to a 
diversified set of: (i) EU candidate and potential candidate countries; (ii) countries and territories 
covered  by  the  European  Neighbourhood  Policy;  and  (iii)  other  non-EU  countries  that  play  a 
determining role in regional stability and which are of strategic importance for the  EU, and are 
politically, economically, and geographically close to the EU.  

The considerations set out in the three bullet points below support the continued suitability of the 
overall 9% target provisioning rate for MFA loans: 

• 

• 

the economic standing of the MFA beneficiaries, taking into account factors such as GDP 
per capita, the relative maturity of the economy, proximity to the EU economy, etc;  

the  MFA  programmes’  direct  link  to  and  contingency  on  an  existing  disbursing  IMF 
programme, and a satisfactory track record on its implementation, which should ensure 
the financial viability of the non-EU country and, thus, the eventual repayment of the Union 
funds; 

•  an  assessment  of  the  economic  situation  of  the  MFA  beneficiaries  and  the  recent 

macroeconomic developments in partner countries.  

On liquidity risk, it should also be borne in mind that the current structure of MFA loans, maturities 
and  repayments  from  beneficiaries  are  well  spread out  over  current  and  subsequent  MFFs  (as 

56  Value at Risk with a 90% confidence level. 

17 

 
 
 
reported in consolidated EU annual accounts57) thereby reducing the magnitude of the EU budget’s 
exposure even in the event of a repayment delay or a default. Additionally, the liquidity in the CPF 
acts  as  a  buffer,  ensuring  that  sufficient  liquidity  is  available  to  handle  potential  financial 
disruptions. 

Box  2:  EU  contingent  liabilities  arising  from  financial  support  to  Ukraine  –  Main 
developments in 2024-2025 

Since Russia’s invasion of Ukraine in 2022, the EU has consistently provided strong political, 
economic, military, financial and humanitarian support to Ukraine. The full set of direct and 
indirect  financial  exposures  to  Ukraine  under  existing  programmes  at  30  June  2025  are 
presented in Table 7 below.  

The main vehicle for delivering financial support to Ukraine for the period 2024-2027 is the 
Ukraine Facility, with an overall capacity of up to EUR 50 billion for 2024-202758.  

In 2024, the EU committed to provide a further MFA loan of EUR 18.1 billion in the context of 
the G7’s ‘Extraordinary Revenue Acceleration (ERA) Loans for Ukraine Initiative’59. 
The loan, to be  fully disbursed over the course of 2025, will  be repaid with proceeds from 
immobilised  Russian  State  assets  in  the  EU  through  the  Ukraine  Loan  Cooperation 
Mechanism (‘ULCM’)60 administered by the European Commission. The revenues from the 
immobilised assets will also cover the interest rate costs of these loans. 

Ukraine  Facility  loans  (EUR  33  billion  for  2024-2027)  and  the  Extraordinary  Revenue 
Acceleration  (ERA)  MFA  loan  (EUR  18.1  billion  for  2024-2027)  are  provided  with  high 
concessionality, given the interest subsidisation and the long repayment period of 35 years 
and 45 years respectively, including a 10-year grace period. This reduces the annual burden 
on Ukraine’s public finances while also minimising the risks for the EU budget. Loans for a 
total amount of EUR 16.2 billion were outstanding under the Ukraine Facility at the end of 
June 2025 while EUR 7 billion was disbursed in the first half of 2O25 under the ERA MFA loan. 

Budgetary cover for contingent liabilities arising from loans to Ukraine since 2023 has been 
provided  by  the  budgetary  headroom  (discussed  in  the  next  section).  The  loans  granted  to 
Ukraine in late 2022 (EUR 6 billion MFA and EUR 1.59 billion in repurposed loans under the 
ELM) are subject to a budgetary coverage of 70%61.  

In compliance with Article 13 of the MFA Decision (EU) 2022/1628, the Commission reviewed 
the adequacy of the 70% provisioning rate at the end of June 2025 in the context of the report 
on Article 41(5) of the Financial Regulation. Following this review, the Commission concluded 
that for the period under examination there were no sufficient new lasting and meaningful 
elements  which  would  justify  changing  the  provisioning  rate  of  70%.  The  most  recent 

57  https://commission.europa.eu/publications/consolidated-annual-accounts-european-union-financial-year-2024_en 
58  See Box 1 in the 2024 Report for details.  
59  In June and October 2024, the G7 announced an agreement to launch the 'Extraordinary Revenue Acceleration (ERA) 
Loans  for  Ukraine'  initiative’  (‘ERA  Loans  for  Ukraine  Initiative’),  by  which  the  G7  members  agreed  to  provide  to 
Ukraine loans of up to EUR 45 billion (approximately USD 50 billion) against non-repayable financial support out of 
the Ukraine Loan Cooperation Mechanism (‘ULCM’). The funding leg of the initiative consists of individual bilateral 
loans from each of the US, the UK, Canada and Japan and an exceptional macro-financial assistance loan facility 
provided by the European Union. The ERA Loans for Ukraine Initiative has been designed so that these loans can be 
repaid without recourse to Ukraine, with funds for servicing and repaying the loans to be derived from the ULCM. 
The ULCM, administered by the European Commission, will itself be funded from extraordinary net profits generated 
by central securities depositaries in the European Union and (possibly) other G7 countries on Russian Central Bank 
assets and reserves which were immobilised in the international clearing systems shortly after Russia launched its 
illegal war of aggression. 

60  Regulation(EU)  2024/2773  of the  European  Parliament  and  of the  Council  of 24  October  2024  establishing the 

Ukraine Loan Cooperation Mechanism and providing exceptional macro-financial assistance to Ukraine. 

61  For the repurposed ELM loans the coverage will take the form of paid-in provisioning funded by the EU budget. The 
same effect is achieved for the exceptional MFA by supplementing the paid-in provisioning rate at the level of 9% 
with guarantees from Member States to cover a second loss piece of up to 61% of the loan exposures. 

18 

 
 
 
developments, including the outcomes of the eighth IMF review of the Extended Arrangement 
under  the  Extended  Fund  Facility  (EFF)  programme  for  Ukraine,  confirm  that  the  70% 
provisioning rate for post-war exposures to the country is still appropriate62. 

Table  7:  Outstanding  direct  and  indirect  exposures  to  Ukraine  (capital)  under  the  existing 
programmes (as at 30 June 2025) (EUR million) 

Direct exposures 

Outstanding amount 

Budgetary coverage 

Legacy MFA 

Legacy Euratom loans 

Emergency MFA 

Exceptional MFA I + II 

MFA+ 
Ukraine Facility – Pillar I 

ERA MFA loan 

Total 

Indirect exposures 

ELM loans disbursed before 
February 2022 
EIB first package under ELM 

EIB second package under ELM 

EFSD+ IW1 

Ukraine Guarantee 

Total 

              3 810  

                 300  

              1 200  

9% 

9% 

9% 

              6 000  

9% (+61% MS guarantees) 

            18 000  
13 200 

7 000 

49 510 

              1 708  

                 668  

              1 338  

103 

1 489 

5 306 

Headroom 
Headroom 

Headroom 

9% 

9% 

70% 

70% 

70% 

3.3  Assessment  of  the  sustainability  of  the  headroom-backed 

contingent liabilities  

The  EU  budget’s  capacity to  cater  for  a  situation  where  the  exposure in  respect  of  headroom-
backed  contingent  liabilities  materialises  is  assessed  by  applying  the  framework  referred  to  in 
paragraph 3.1 above.  

For liabilities that are covered by the permanent own resources ceiling, the annual assessment 
takes into account the outstanding exposures as of 31 December 2024. As explained in Box 1, this 
includes contingent liabilities related to current state of borrowing and lending under: the EFSM; 
the Balance of Payments Facility; the SURE programme; MFA+ to Ukraine; and the Ukraine Facility. 
More recent contingent liabilities such as those resulting from  the ERA MFA loan and the SAFE 
Facility will be assessed in future annual assessments63. 

For NGEU liabilities, in 2021-2027 MFF, the own resources ceiling has been increased by 0.6% of 
EU GNI exclusively to guarantee these issuances. This ensures that the EU has the means to repay 
interest and principal on debt issued to fund NGEU non-reimbursable support (RRF grants) and 
repayable support (RRF loans) to Member States. As interest costs and the repayment of grants 

62  See 

https://www.imf.org/en/Publications/CR/Issues/2025/06/30/Ukraine-Eighth-Review-Under-the-Extended-

Arrangement-Under-the-Extended-Fund-Facility-568152 

63  Proposal for a Council Regulation laying down the multiannual financial framework for the years 2028 to 2034 
(COM(2025)571 final); Proposal for a Council Decision on the system of own resources of the European Union and 
repealing Decision (EU, Euratom) 2020/2053 (COM(2025)574 final). 

19 

 
 
 
 
 
 
 
are  included  in  future  annual  budget  programming,  only  the  RRF  loans  represent  contingent 
liabilities to the budget. In addition, to apply a conservative approach, maturing bonds that are 
planned to be rolled over are also considered in the stress tests. 

The first step is to draw up a central scenario (baseline) that corresponds to the expected evolution 
of EU spending and financial capacity in the coming years. To this end, this report takes as a basis 
the published draft budget for 202664 and the long-term forecast of future inflows and outflows 
of the EU budget65, which forecasts the revenue and expenditure stemming from the 2021-2027 
MFF, NextGenerationEU and the next MFF and ORD as per the Commission's proposal.  

In this central scenario, the permanent own resources ceiling is thus set at 1.4% of EU GNI in 2026 
and 2027, and 1.75% of EU GNI as of 202866. For NextGenerationEU, the central scenario assumes 
repayment  starting  in  2028  with  a  fixed  annual  amount  of  EUR 24 billion,  in  line  with  the 
Commission’s MFF proposal.  

This  scenario  provides  a  baseline  headroom  projection  against  which  the  sustainability  of 
contingent liabilities incurred at 31 December 2024 is assessed as per Article 256 of the Financial 
Regulation.  More  recent  borrowing  and  lending  operations  will  be  covered  in  future  annual 
reporting.  

Under this baseline scenario, and excluding the current budget year 2025, the headroom available 
for  covering  existing  and  new  contingent  liabilities  in  2026-2034  is  on  average  around 
EUR 128.5 billion per year in respect of the margin under the permanent own resources ceiling 
and around EUR 111.4 billion per year for the temporary ceiling of 0.6% of EU GNI. This baseline 
scenario thus assumes that no contingent liability materialises. 

Additional  stress  tests  assess  the  sustainability  of  existing  contingent  liabilities  under  extreme 
scenarios  in  2026-2034.  With  the  unified  funding  approach,  the  contigent  liabilities  related  to 
borrowing  under  different  programmes  are  reported  in  an  integrated  manner,  irrespective  of 
whether they relate to an expenditure risk (planned bond roll-overs for NGEU grants) or revenue 
risk  (planned  bond  roll-overs  for  loans  to  Member States  under  NGEU  or  to Ukraine  under  the 
MFA+ and the Ukraine Facility). For that reason the stress-testing on revenue and on expenditure 
is combined into a common test, compared with previous editions of the report. The stress-testing 
comprises three types of stress test, each of which are set out in the paragraphs below. 

1)  Stress test on the economy. In the central scenario, EU GNI follows the projections for real 
growth and inflation set out in the Commission Spring 2025 European Economic Forecast67. 
For the stress test, the projected nominal growth rates are lower than the baseline by one 
percentage point for each year of the reporting period68.  

This  reduces  the  nominal  value  of  the  own  resources  ceiling  and  therefore  the  available 
headroom  by  EUR 18.6 billion  on  average  per  year  for  the  ‘unbudgeted’  amounts 
(headroom)  under  the permanent  own  resources  ceiling  and  by  EUR 6.5 billion  under  the 
temporary ceiling for the NGEU over the period 2026-2034. 

2)  Stress test on the expenditure and revenue side of the budget. Under this scenario 
MFF expenditure is projected at its theoretical maximum (i.e. the maximum possible ceilings 
for the MFF payments and all individual special instruments, including the Ukraine Reserve). 
It is important to underline that: (i) this does not reflect a bottom-up forecast and is unrelated 

64  Including Amending Letter 1/2026 (COM(2025)851). 
65  COM (2025) 573 final. 
66  The Commission proposal for the future own resources decision also includes the possibility for a temporary increase 
in the own resources ceiling of an additional 0.25% of EU GNI if the ‘crisis mechanism’ is activated. However, unless 
and until the mechanism is activated during the next MFF, this provision does not impact the assessment presented 
here. 

67  European Commission, European Economic Forecast, Spring 2025. Institutional Paper 318, May 2025. Spring 2025 

Economic Forecast: Moderate growth amid global economic uncertainty - European Commission.  

68  This is similar to the stress test on the ‘adverse r-g scenario’ performed in the Commission’s Debt Sustainability 

Monitor: 2024. European Economy Institutional Paper 306, March 2025. 

20 

 
 
 
to any current expectations as to the evolution of EU payments; and (ii) on the expenditure 
side  of  the  budget,  any  decision  to  increase  spending  (within  the  MFF  ceilings)  requires  a 
proposal by the Commission and the approval of the European Parliament and the Council as 
budgetary authority.  

For NGEU financing costs, this scenario assumes  that the cost overrun compared  with the 
technical  update  of  the  financial  programming  in  2027  is  for  50%  of  the  overrun  to  be 
covered by other budgetary availabilities and other 50% to be covered by the EURI instrument.  

This extreme scenario also assesses whether the available headroom would be sufficient if 
all headroom-backed contingent liabilities were to materialise at the same time. In practical 
terms, this would mean that all countries benefiting from financial assistance programmes 
(mostly Member States) would simultaneously fail to honour their repayments when they are 
due. For programmes financed by the unified funding approach (both NGEU and the relevant 
MFF programmes), the assumption in this stress test is that all interest costs are borne by 
the budget and all issuances maturing in a given year are repaid. Planned debt roll-overs are 
thus not considered in this hypothetical situation.  

Note  that  this  is  an  extremely  unlikely  scenario,  which  does  not  take  into  account  all  the 
measures that the Commission can take to avoid such a situation (e.g. debt rescheduling and 
active cash management). 

This  stress  test  shows  that  the  headroom  is  sufficient  in  the  scenario  where  expenditure 
reaches the theoretical maximum, and all beneficiaries default on their loan. The resulting 
headroom  under  the  permanent  own  resources  ceiling  would  be  EUR 101.7 billion  on 
average over the period 2026-2034, i.e. EUR 26.7 billion less than in the baseline.  

The headroom under the temporary own resources ceiling of 0.6% of EU GNI that guarantees 
NGEU issuances would be reduced by  EUR 43.0 billion per year on average, to a level  of 
EUR 68.4 billion on average over the period 2026-2034. 

3)  A combined stress test on economic conditions, revenue and expenditure. This is an 
extreme scenario that combines the unfavourable scenarios described in the two tests above. 
It would reduce the headroom under the permanent ceiling to EUR 83.1 billion on average 
over the period 2026-2034 and for the temporary ceiling to EUR 62.0 billion. These amounts 
appear to constitute a large safety buffer for the EU’s financial capacity to cover its liabilities 
(stemming from both non-NGEU and NGEU operations). 

The  detailed  results  for  the  baseline  and  stress  test  scenarios  are  provided  in  the  annex  and 
summarised in Figures 3 and 4 below. 

21 

 
 
 
 
 
 
 
 
 
 
 
 
 
Figure  3:  Own  resources  ceiling  and  own  resources  needs  under  a  baseline  and  combined 
sensitivity tests for the permanent ceiling.  

Figure  4:  Own  resources  ceiling  and  own  resources  needs  under  a  baseline  and  combined 
sensitivity tests for the temporary NGEU ceiling.  

22 

 
 
 
 
 
 
 
 
 
4. Conclusions 

At the end of 2024, the EU budget supported EUR 410 billion in contingent liabilities, spread over 
EUR 300 billion in contingent liabilities arising from loans granted to Member States and non-EU 
countries. Of this, EUR 252 billion relates to loans to Member States and EUR 48 billion to loans 
to non-Member States. In addition, a further EUR 110 billion in contingent liabilities arose from 
investment guarantees provided under the ELM, EFSI, EFSD, InvestEU, EFSD+ and UIF programmes.   

Taking into account the multiple safeguards provided in the EU framework for the monitoring and 
management of the risks linked to both provisioned and headroom-backed contingent liabilities 
and the sustainability assessment presented in this report, three main conclusions can be drawn. 
These conclusions are set out in the three bullet points below. 

•  Risks  arising  from  provisioned  instruments  (i.e.  budgetary  guarantees  and  financial 
assistance to non-EU countries) are carefully managed and adequately provisioned. This 
assessment  takes  into  account:  (i)  data  on  past  defaults  and  expected  losses;  (ii)  the 
measures that are in place to ensure that losses do not exceed predefined tolerance levels; 
and (iii) the budgetary provisions that are available to cover potential payments. 

•  The  EU’s  financial  capacity  under  the  existing  and  proposed  legal  framework  (i.e.  the 
existing  ORD  and  the  MFF  Regulation  and  the  proposed  MFF  Regulation  and ORD  as  of 
2028)  is  largely  sufficient  to  cater  for  the  materialisation  of  losses  that  may  arise  in 
respect of headroom-backed loans between now and the end of 2034. 

•  The headroom is well-resourced to ensure the robustness of the EU’s financial system and 
its  credit  worthiness  even  under  an  extreme  negative  scenario  that  combines  adverse 
impacts in respect of the economic conditions, revenue and expenditure. In such an adverse 
scenario,  the  remaining  headroom  under  the  permanent  own  resources  ceiling  would 
amount  to  EUR 83.1 billion  on  average  per  year  over  the  2026-2034  period  and  to 
EUR 62.0 billion on average per year under the temporary NGEU ceiling of 0.6% of EU 
GNI  over  the  same  period.  These  amounts  represent  a  safety  buffer  against  further 
negative economic shocks, potential new needs and future contingent liabilities for both 
non-NGEU and NGEU operations. This result is based on - and underlines the importance 
of - an increase of the own resources ceiling to 1.75%, as proposed by the Commission in 
the context of its MFF 2028-2034 package. 

23 

 
5. Annexes:  

Sustainability  and  headroom  in  respect  of  the  permanent  own  resources  ceiling  
(EUR billion, current prices) 

2026  2027  2028  2029  2030  2031  2032  2033  2034 

Baseline 

Own resources ceiling (% of 
GNI) 
Own resources ceiling (EUR 
bn) 
Own resources to finance 
the budget (excl. NGEU) 
Headroom under permanent 
ceiling 

a 

b 

a-b 

1.40 

1.40 

1.75 

1.75 

1.75 

1.75 

1.75 

1.75 

1.75 

269.6  278.7  359.7  371.5  383.1  394.8  406.8  419.0  431.5 

178.8  188.2  243.0  273.8  270.2  265.9  250.5  247.8  240.4 

90.8 

90.5  116.7 

97.7  112.9  128.9  156.3  171.2  191.2 

267.0  273.3  349.4  357.3  364.9  372.5  380.0  387.6  395.3 

178.8  188.2  243.0  273.8  270.2  265.9  250.5  247.8  240.4 
94.7  106.5  129.5  139.8  154.9 

85.1  106.4 

88.2 

83.6 

269.6  278.7  359.7  371.5  383.1  394.8  406.8  419.0  431.5 

178.8  188.2  243.0  273.8  270.2  265.9  250.5  247.8  240.4 

b 

a 

a-b 

Stress tests 
1) Stress test on the economy 
Own resources ceiling  
Own resources to finance 
the budget (excl. NGEU) 
Headroom 
2) Stress test on expenditure and revenue 
Own resources ceiling  
Own resources to finance 
the budget (excl. NGEU) 
Additional own resources (up 
to MFF ceiling maximum and 
special instruments' 
maximum) (*) 
Extraordinary own resources 
to cover non-NGEU 
contingent liabilities (**) 

a 

d 

b 

c 

20.8 

17.2 

7.1 

16.6 

17.1 

17.0 

16.9 

16.6 

16.6 

16.7 

7.1 

16.4 

11.8 

12.2 

11.1 

6.4 

5.2 

7.8 

Headroom 
3) Combined adverse shock 
Own resources ceiling 
Own resources to finance 
the budget (excl. NGEU) 
Additional own resources 
(up to MFF ceiling 
maximum, and special 
instruments' maximum) 
Extraordinary own resources 
to cover non-NGEU 
contingent liabilities 

a-b-
c-d 

a 

b 

c 

d 

52.8 

76.2 

83.8 

68.8 

83.7  100.9  133.3  149.4  166.6 

267.0  273.3  349.4  357.3  364.9  372.5  380.0  387.6  395.3 

178.8  188.2  243.0  273.8  270.2  265.9  250.5  247.8  240.4 

20.8 

7.1 

16.6 

17.1 

17.0 

16.9 

16.6 

16.6 

16.7 

17.2 

7.1 

16.4 

11.8 

12.2 

11.1 

6.4 

5.2 

7.8 

a-b-
c-d 

50.2 

Headroom 

70.9 
(*) Expenditure is projected at the theoretical maximum for: 1) the MFF payment ceiling in 2026-2027 as set out in the 
most recent technical adjustment and future adjustments up to their potential maximum in any single year; and 2) the 
annual  ceilings  of  the  thematic  special  instruments  (the  Flexibility  Instrument,  the  European  Globalisation  Adjustment 
Fund, Solidarity and Emergency Aid Reserve, and the Ukraine Reserve). As of 2028, this includes full mobilisation of the 
Flexibility Instrument and Ukraine Reserve in the form of grants. 

65.5 

54.7 

73.5 

78.5  106.5  118.0  130.4 

24 

 
 
 
 
 
Baseline 

Own resources 
ceiling (0.6% GNI) 
Own resources to 
finance NGEU(*) 
Headroom 

Stress tests 

Own resources 
ceiling (0.6% GNI) 
Own resources to 
finance NGEU 
Headroom 

a 

b 

a 

b 

1) Stress test on the economy 

(**) This includes borrowing for loan support through the EFSM, SURE, MFA+, and the Ukraine Facility. The risk assessment 
of the SURE Instrument takes into account the specific counter-guarantee provided by all Member States for 25% of the 
maximum amount of financial assistance.  

Sustainability  and  headroom  in  respect  of  the  temporary  NGEU  own  resources  ceiling  
(EUR billion, current prices) 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

115.6 

119.4 

123.3 

127.4 

131.3 

135.4 

139.5 

143.7 

147.9 

8.0 

5.0 

a-b 

107.5 

114.4 

24.0 

99.3 

24.0 

24.0 

24.0 

24.0 

24.0 

24.0 

103.4 

107.3 

111.4 

115.5 

119.7 

123.9 

114.4 

117.1 

119.8 

122.5 

125.1 

127.7 

130.3 

132.9 

135.5 

8.0 

5.0 

a-b 

106.4 

112.2 

24.0 

95.8 

24.0 

98.5 

24.0 

24.0 

24.0 

24.0 

24.0 

101.1 

103.7 

106.3 

108.9 

111.5 

2) Stress test on expenditure and revenue 

Own resources 
ceiling (0.6% GNI) 
Own resources to 
finance NGEU 
Additional 
extraordinary own 
resources for NGEU 
(cost overrun, 
contingent liabilities)  
Headroom 

115.6 

119.4 

123.3 

127.4 

131.3 

135.4 

139.5 

143.7 

147.9 

8.0 

5.0 

24.0 

24.0 

24.0 

24.0 

24.0 

24.0 

24.0 

a 

b 

c 

a-b-c 

35.0 

72.5 

41.0 

73.5 

41.5 

57.8 

52.0 

51.3 

25.7 

81.6 

59.5 

51.9 

38.4 

77.0 

39.1 

80.5 

54.4 

69.5 

3) Combined adverse shock 

Own resources 
ceiling (0.6% GNI) 
Own resources to 
finance NGEU 
Additional 
extraordinary own 
resources for NGEU 
(cost overrun, 
contingent liabilities)  
Headroom 

114.4 

117.1 

119.8 

122.5 

125.1 

127.7 

130.3 

132.9 

135.5 

8.0 

5.0 

24.0 

24.0 

24.0 

24.0 

24.0 

24.0 

24.0 

a 

b 

c 

a-b-c 

35.0 

71.4 

41.0 

71.2 

41.5 

54.3 

52.0 

46.5 

25.7 

75.4 

59.5 

44.2 

38.4 

67.9 

39.1 

69.8 

54.4 

57.1 

(*)  For  2026  the  amount  reflects  the  commitments  appropriations  in  the  draft  budget  2026.  For  2027  the  amount 
corresponds to the financial programming of the EURI budget line.  The amounts for 2028 and 2029 are based on the 
Commission  proposal  for  the  next  MFF  as  included  in  the  long-term  report  on  inflows  and  outflows  of  the  budget 
(COM(2024) 573 final). 

25