28 February 2023

Positive preliminary assessment of the satisfactory fulfilment of milestones and targets related to
the first payment request submitted by Denmark on 16 December 2022, transmitted to the
Economic and Financial Committee by the European Commission

Executive summary
In accordance with Article 24(2) of Regulation (EU) 2021/241, on 16 December 2022, Denmark
submitted a request for payment for the first instalment of the non-repayable support. The payment
request was accompanied by the required management declaration and summary of audits.
To support its payment request, Denmark provided due justification of the satisfactory fulfilment of the
25 milestones and targets of the first instalment of the non-repayable support, as set out in Section
2.3(3.1) of the Council Implementing Decision of 13 July 2021 on the approval of the assessment of the
recovery and resilience plan for Denmark1.
Upon receipt of the payment request, the Commission has assessed on a preliminary basis the
satisfactory fulfilment of the relevant milestones and targets. Based on the information provided by
Denmark, the Commission has made a positive preliminary assessment of the satisfactory fulfilment of
all 25 milestones and targets.
The milestones and targets positively assessed as part of this payment request demonstrate significant
steps in the implementation of Denmark’s Recovery and Resilience Plan. This includes, among others,
removing carbon rich soils from production for a more decarbonised agriculture, the adoption of a
political agreement increasing emission taxes on industry, as well as a legal act incentivising consumers
to choose zero and low-emission cars by decreasing the registration tax for this type of vehicles. The
milestones and targets also confirm progress towards the completion of investment projects related to,
among others, improving the healthcare system through new digital solutions, the approval of the legal
framework for the transition towards energy efficiency in buildings, the adoption of the law on the green
tax reform to lower greenhouse gas emissions, the approval of several political agreements on
sustainable mobility, and in the field of research for green solutions, the selection of four mission
research and development and innovation roadmaps and the approval of a bill to incentivise research
and development investments in companies.
By the transmission of this positive preliminary assessment and in accordance with Article 24(4) of
Regulation (EU) 2021/241, the Commission asks for the opinion of the Economic and Financial
Committee on the satisfactory fulfilment of the relevant milestones and targets.

1

10154/21, 10154/21 ADD 1.

1

Non-repayable support ................................................................................................................ 3
Related Measure: C1.I2. Measures to ensure stocks of critical drugs .............................................. 3
Related Measure: C1.I3. Digital solutions in the healthcare sector ................................................. 4
Related Measure: C1.I3. Digital solutions in the healthcare sector ................................................. 6
Related Measure: C1.I4. Emergency management & monitoring of critical medical products ......... 8
Related Measure: C2.I5. Green transition of Agriculture and the environment – climate technologies
in agriculture ............................................................................................................................. 12
Related Measure: C2.R1. Green transition of Agriculture and the Environment- Carbon rich soils 14
Related Measure: C3.I01 Replacing oil burners and gas furnaces ................................................ 17
Related Measure: C3.I03. Energy efficiency, green heating and CCS - Energy efficiency in industry 22
Related Measure: C3.I03 Energy efficiency, green heating and CCS - Energy renovations in public
buildings .................................................................................................................................... 24
Related Measure: C3.I5 Carbon Capture Storage (CCS) Potential ................................................. 26
Related Measure: C4.I1. Investment window .............................................................................. 28
Related Measure: C4.I1. Investment window .............................................................................. 31
Related Measure: C.4 I2. Green tax reform – accelerated depreciation ........................................ 32
Related Measure: C4.I2. Accelerated depreciation ...................................................................... 34
Related Measure: C4.R2 Emission taxes on industries ................................................................. 35
Related Measure: C5.R1 Re-prioritisation of the registration tax of vehicles and low electricity tax on
charging electric vehicles............................................................................................................ 37
Related Measure: C5.I2 Development test of road-pricing .......................................................... 40
Related Measure: C5.I5. Analysis of the regulation on weight and dimensions to optimise heavy
haulage. .................................................................................................................................... 44
Related Measure: C5.I4. Analysis of test scheme with double trailers .......................................... 47
Related Measure: C5.I8. Subsidy scheme to green ferries ............................................................ 51
Related Measure: C7.I1: Research in green solutions: Carbon capture and storage or use of CO2 53
Related Measure: C7.I2: Research in green solutions: Green fuels for transport and industry ...... 56
Related Measure: C7.I3: Research in green solutions: Climate- and environment friendly agriculture
and food production .................................................................................................................. 58
Related Measure: C7.I4: Research in green solutions: Circular economy focusing on reuse and
reduction of plastic and textile waste ......................................................................................... 60
Related Measure: C7.I5: Incentives to boost R&D in companies.................................................. 62

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Non-repayable support
Number: 1

Related Measure: C1.I2. Measures to ensure stocks of critical drugs
Name of the Milestone: Report of the assessment of stocks of critical drugs by the Danish Medicines
Agency to be made available aiming to avoid situations with a shortage of important drugs in
Denmark
Qualitative Indicator: Report on the assessment of the stocks of critical
Time: Q4 2021
medicines and follow-up by the Danish Medicines Agency as necessary
Context:
The measure aims to maintain and ensure the stock of critical drugs in the secondary health sector of
Denmark. The goal is to avoid critical situations with shortages of important drugs.
Milestone 1 concerns the submission of a report of the assessment of stocks of critical drugs by the
Danish Medicines Agency.
Milestone 1 is the only milestone of this investment. However, the Danish Recovery and Resilience
Plan foresees other measures to strengthen the resilience of the health care system, namely, to
improve digital solutions and to study and report on clinical effects of COVID-19 vaccines with
milestones/targets 2 to 6 under the same component.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive elements)
was satisfactorily fulfilled.
ii.
The contract signed between the Danish Medicines Agency and Amgros on 22 December
2020 and respective annexes.
iii.
The Q4 2021 quarterly report of the Danish Medicines Agency regarding the stocks of critical
medicines on 15 December 2021.
The authorities also provided:
i.
Report of 28 April 2022 on the stocks of critical medicines issued by the Danish Medicines
Agency and sent to the Ministry of Health.
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
The Danish Medicines Agency has assessed and reported to the Danish Ministry of Health on the
stocks of critical medicines.
In line with the Council Implementing Decision requirements, an assessment has been passed on to
the Danish Ministry of Health by the Danish Medicines Agency in a report of 28 April 2022. This report
is based on a quarterly report of Q4 2021, which was assessed on 15 December 2021 and reported to
the Danish Medicines Agency on 16 December 2021 by Amgros. Amgros is a public-sector entity whose
main area of activity is to secure the right medicines for patients at public hospitals by organising and
conducting tendering procedures and procurement for the Danish regions, as per their website:
https://amgros.dk/en/about-amgros/. As stated in the summary document, the stocks of critical drugs
are being assessed on a quarterly basis by Amgros and reported to the Danish Medicines Agency. The
data provided in the quarterly report of Q4 2021 shows the stock levels of regular medicines
considered critical and of medicines for treating COVID-19 patients.
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The assessment shall be of high importance in forecasting and ensuring the right level of storage
capacity for critical drugs.
To maintain and ensure strategic stocks of critical drugs in the secondary health sector, the Danish
Medicines Agency signed a contract with Amgros. Sections 3 and 4 of the contract state that the role
of Amgros is to procure and maintain, as far as possible, a security stockpile of selected medicines to
safeguard against shortages and to purchase COVID-19 treatment drugs.
Furthermore, in line with the description of the measure, to avoid critical situations with shortages of
important drugs, the Danish authorities have established and will now extend infrastructure and
logistics support to maintain and ensure strategic stocks of critical drugs in the secondary health
sector. This follows from section 2.1 of the contract stating that its purpose is to increase and maintain
a security stock of relevant medicines so that possible backorders and supply issues do not result in
serious shortages.
Furthermore, in line with the description of the measure, the list of critical medicines has been
prepared on the basis of input from the clinical pharmacologists in the regions. Annex 2 to the contract
provides this list. As stated above, Amgros produces quarterly reports to the Danish Medicines Agency
on the stock of critical drugs. The Danish Medicines Agency has subsequently reported the assessment
to the Danish Ministry of Health. The specific medical products and their storage levels have been
continuously adjusted in mutual agreement between the Danish Medicines Agency and Amgros as
stated in the summary document. This shows that the assessment has been of high importance in
forecasting and ensuring the right level of storage capacity for critical drugs.
An assessment of infection pressure and number of patients hospitalized with COVID-19 as well as
the general development in the pharmaceutical markets shall be included in the assessment.
As stated in the report of 28 April 2022 issued by the Danish Medicines Agency and sent to the Ministry
of Health, the conclusions were based on an assessment made by clinical pharmacists in intensive care
units in the Capital Region of Denmark in December 2021 and provided by Amgros. As stated in the
summary document, the assessment took into account the infection pressure and number of patients
hospitalized with COVID-19 and whether the medicines held in stock corresponded to pandemic
developments and other healthcare needs. This derives from sheet ‘purchasing and stock’ (‘Indkøb og
lager’) of the Q4 2021 quarterly report of the Danish Medicines Agency, reflecting Amgros’ data on
the stock and procurement of medicines, including for the treatment of COVID-19. For each COVID-19
medicine listed, this sheet shows the stock of packages per treatments available; in other words, it
showcases how many treatments are possible to provide with the packages on stock. It further details
the stock of medicines that were ‘on order’, their expected arrival date, and the number of packages
that will be available for treatments, reflecting general developments in pharmaceutical markets. The
assessment of the need for medicines is a function of the epidemiological situation including the
infection pressure and the number of hospitalised patients in need of treatment, as stated in the
summary document, and the stocks of medicines is being adjusted on a need basis. Based on it, the
Danish Medicines Agency determined and stated in the report of 28 April 2022 that “the qualification
of the COVID-19 critical medicines concludes that Denmark is well covered with relevant medicines so
that the stockpile helps avoid supply difficulties for critical medicines”. The report further concludes
that the establishment of stocks helped avoid supply difficulties for critical medicines, affecting fewer
patient treatments, and that the stock overall contributed to ensuring an adequate supply of critical
medicines in the secondary sector.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 2

Related Measure: C1.I3. Digital solutions in the healthcare sector

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Name of the Milestone: Evaluation of patient involvement and widespread use of telemedicine to be
made available by the Danish Ministry of Health in close collaboration with Danish Regions
Qualitative Indicator: An evaluation about telemedicine solutions of health
anxiety

Time: Q4 2021

Context:
The objective of the measure is that the Ministry of Health develops new digital solutions to make the
healthcare system more connected following the COVID-19 pandemic. The solutions related to this
investment shall help foster the widespread use of digital technologies, patient involvement and the
widespread use of telemedicine.
Milestone 2 concerns an evaluation report written by the Central Region, in close collaboration with
the Danish Regions, and shared with the Danish Ministry of Health, on telemedicine solutions of health
anxiety related to the COVID-19 pandemic to further develop and increase the use of telemedicine
and patient involvement.
Milestone 2 is the first step of the implementation of the investment, and it will be followed by target
3 related to the development of the telemedicine consultation application ContactDoctor
(KontaktLæge), which is also part of the first payment request, and by milestone 4 related to the
implementation of a digital questionnaire in the application MyDoctor (MinLæge). The investment has
a final expected date for implementation in Q3 2023.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive elements)
was satisfactorily fulfilled.
ii.
Final evaluation report of 31 March 2022 about telemedicine solutions of health anxiety,
issued by the Central Region.
The authorities also provided:
i.
Email, of 31 March 2022, sent by the Centre for Telemedicine and Tele healthcare of the
Central Region to the Danish Ministry of Health.

Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
In close collaboration with Danish Regions, the Central Region shall report an evaluation to the
Danish Ministry of Health on telemedicine solutions of health anxiety.
In line with the Council Implementing Decision requirements, the Danish Regions collaborated for
producing an evaluation report following a project on telemedicine solutions for COVID-19-triggered
health anxiety (see final evaluation report of 31 March 2022 about telemedicine solutions of health
anxiety, issued by the Central Region). The allocation of funds for the project was given on the basis
of a dialogue between the Ministry of Health and the Danish Regions (see page 6 of the final evaluation
report, section “grant of the project”), and the final evaluation report was prepared and sent by the
Central Region to the Danish Ministry of Health as proven in the email of 31 March 2022, sent by the
Centre for Telemedicine and Tele healthcare of the Central Region to the Danish Ministry of Health.
The evaluation report provided by the authorities details the results of the project, whose aim is to
increase accessibility for internet-based treatment (video consultations) for patients with COVID-19triggered health anxiety. Page 6 of the final evaluation report, section “project purpose”, refers to the
5

three goals of the project: i) to adapt the existing internet-based treatment programme to include
health anxiety triggered by COVID-19; ii) to scale-up the existing treatment offer for COVID-19
pandemic health anxiety regionally and nationally; iii) to evaluate and provide quality assurance of the
new telemedicine treatment offer for COVID-19-triggered health anxiety.
To further develop and increase the use of telemedicine.
The further development and increased use of telemedicine is justified by the scaling potential of the
project. Page 4 of the final evaluation report, section “Existing treatment services for patients with
health distress”, explains that the existing offer of care for health anxiety is scarce and often
characterised by long waiting times. Section “Scaling potential”, page 18, of the final evaluation report
refers that the scaling potential of this project is significant as the offer provided is extendable to all
health anxiety diseases and not only to COVID-19 related health anxiety. It concludes that the
treatment should be extendable to everyone with health-anxiety and not exclusively to COVID-19triggered health anxiety.
Furthermore, in line with the description of the measure, the Ministry of Health is required to develop
and increase the use of these new digital solutions such as widespread use of digital solutions and
video consultations. The project was developed to increase the digital solutions in the healthcare
sector. This is shown by the purpose of the project, its digital nature and scaling potential. The fact
that patients have access to an online treatment for COVID-19-triggered health anxiety which is
adapted to each patient and that patients can self-enrol in the treatment without medical referral
proves that this solution contributes to a more digitalised healthcare sector. The use of video
consultations is used in the implementation of the project, where patients receive treatment in the
form of video consultations (page 5 of final evaluation report of 31 March 2022), which shows that the
project promotes the increased use of video consultations and telemedicine.
To further develop and increase the use of patient involvement.
The project aims at increasing patient involvement in the healthcare sector. Patients participating in
the project did not need a referral from the doctor to participate in the project. As stated on page 15
of the final evaluation report of 31 March 2022, section “Self-reference requires adjusted visa
procedure”, patients could answer an online questionnaire on a webpage designed for the programme
about their level of health anxiety before they received the treatment. Based on the answers, the
treatment was specifically designed for each patient individually. Page 5 of the final evaluation report
of 31 March 2022 states that patients received the treatment through video consultations and
interactive exercises on the webpage designed for the programme. The associated health professional
communicated with the patient in the embedded message module and the health professional gave
the patient access to new modules along with the patient's progress on the website designed for the
programme. The treatment was therefore tailored to the individual patient, and these procedures
were designed to increase patient empowerment and involvement. The nature and the goals of the
project prove its alignment with the goals of developing and increasing the use of new digital solutions
and patient involvement, as well as the widespread use of telemedicine and digital solutions in the
healthcare sector.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 3

Related Measure: C1.I3. Digital solutions in the healthcare sector
Name of the Target: Develop and make available facilities for telemedicine consultation
(KontaktLæge) for multiple platforms
Quantitative Indicator: Number Baseline: 1
Target: 2
Time: Q4 2021
Context:

6

The objective of the measure is that the Ministry of Health develops and promotes new digital
solutions to make the healthcare system more connected following the COVID-19 pandemic. The
solutions shall include the use of digital technologies and video consultations.
Target 3 concerns the development and operationalisation of the software application ContactDoctor
(KontaktLæge) on a second mobile device platform. The goal is to increase the use of video
telemedicine consultations to other mobile device platforms and to make the application available for
iOS and Android devices.
This target is first step of the implementation of the investment, and it will be followed by milestone
2 related to an evaluation of patient involvement and widespread use of telemedicine, which is also
part of the first payment request, and by milestone 4 related to the implementation of a digital
questionnaire in the application MyDoctor (MinLæge). The investment has a final expected date for
implementation in Q3 2023.
Evidence Provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the target (including all the constitutive elements)
was satisfactorily fulfilled.
ii.
Certificate of works completion of 3 November 2022, signed by the Ministry of Health and
MedCom.
iii.
Link to both platforms where the app is now available:
a.
Android:
https://play.google.com/store/apps/details?id=com.trifork.kontaktlaege&hl=da&gl=US
b.
iOS: https://apps.apple.com/dk/app/kontakt-l%C3%A6ge/id1512135032?l=da
The authorities also provided:
i.
Letter of Commitment signed by MedCom on 21 December 2020 showing the agreement
between MedCom and the Danish Ministry of Health for the development of the application.
ii.
Work Order Agreement signed between MedCom and Trifork Public A/S on 21 January 2021.
Trifork Public A/S was commissioned by MedCom to develop the application.
iii.
Mid-term evaluation report of the ContactDoctor (KontaktLæge) application issued by
MedCom in November 2021.
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the target.
Increase the use of video telemedicine consultations ContactDoctor (KontaktLæge) to other mobile
device platforms.
The authorities provided the mid-term evaluation report of November 2021 of the project for the
development of the application ContactDoctor (KontaktLæge). In section 1 “Introduction”, it is stated
that the ContactDoctor (KontaktLæge) app was created to allow citizens at particular risk of COVID-19
infection or citizens who do not or cannot use NemID (a common log-in solution in Denmark that
citizens may use for video consultations) and are connected to the municipality, to have video
consultations with the help of the social and health professionals in the municipality.
To increase the use of video telemedicine consultations, the Danish Ministry of Health, in collaboration
with MedCom, contracted the further development of the application ContactDoctor (KontaktLæge)
on iOS, which is the second mobile device platform where the application is available, as it was
previously available on Android devices only. The certificate of works completion of 3 November 2022,
signed by the Ministry of Health and MedCom, the contractor who developed the application, confirms
7

that the app is available and operational on both platforms. Therefore, the target of having the
application available on two mobile platforms was achieved.
Furthermore, in line with the description of the measure, the Ministry of Health is required to develop
and increase the use of these new digital solutions such as widespread use of digital solutions and
video consultations. As per section 1 “Introduction” of the mid-term evaluation report, the application
ContactDoctor (KontaktLæge) was firstly developed as a digital solution for the Danish healthcare
system given that it provides the means for access to video consultations for citizens through the help
of municipalities. As per the Work Order, section “description of the service”, the expansion of the
application to a new platform was performed so that the application can also be accessed by
municipalities via iPhone/iOS. The expansion of the application to a new platform improves this digital
solution by making it available to more users, therefore increasing the access to new digital solutions
and video consultations.
The Danish Ministry of Health in collaboration with MedCom shall develop and make available the
application ContactDoctor (KontaktLæge) on a second mobile device platform.
Page 1 of the Letter of Commitment of 21 December 2020 proves that the allocation of funds
designated to the further development of the app ContactDoctor (KontaktLæge) were agreed between
MedCom and the Danish Ministry of Health. MedCom is a non-profit organisation financed and owned
by the Ministry of Health, Danish Regions and Local Government Denmark to facilitate cooperation
between authorities, organisations and private firms linked to the Danish healthcare sector, as stated
in the Council Implementing Decision and on the website of MedCom:
https://www.medcom.dk/medcom-in-english/about-medcom
The Work Order agreement between MedCom and Trifork Public A/S shows that MedCom contracted
Trifork Public A/S for the development of the application. In the section “description of the service”, it
is stated that the Work Order Agreement of 21 January 2021 was signed to further develop
ContactDoctor (KontaktLæge) so that the solution can also be accessed by municipalities via iPhone.
Page 5, section “Background” of the mid-term evaluation report refers that the application
ContactDoctor (KontaktLæge) was released for use by all municipalities in May 2020 and can be used
on tablets/iPads and mobile phones that are Android and iOS controlled. Page 17 of the mid-term
evaluation report from MedCom, further references in section “Kontakt Læge app” that the
application is available for both Android and iOS devices.
Furthermore, the authorities have also provided the links to the application on both platforms. Both
links remain active, as verified by Commission staff on 11 January 2023.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 6

Related Measure: C1.I4. Emergency management & monitoring of critical
medical products
Name of the Target: Implement an optional IT-system to report on the side effects of the COVID19 vaccines into 1250 general practitioners’ local digital platforms.
Quantitative
Indicator: Number

Baseline: 1 000

Target: 2 250

Time: Q3 2021

Context:
The objective of this measure is to improve the infrastructure for monitoring and acting upon
potential side effects of the COVID-19 vaccines.
Target 6 concerns the implementation of an IT-system to report side effects of the COVID-19
vaccines into 1 250 additional general practitioner’s (hereinafter referred to as “GPs”) digital
platforms. Target 6 is the only target in this investment.
8

In line with the description of the measure in the Council Implementing Decision, Denmark has taken
steps to improve the infrastructure for monitoring shortages and supply problems, which is assessed
in milestone 1 of this payment request.
Evidence Provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
ii.

iii.

Summary document duly justifying how the target (including all the constitutive elements)
was satisfactorily fulfilled.
Letter from the Danish Medicines Agency, dated 4 November 2022, confirming that the IT
system (webservice) to report on the side effects of the COVID-19 vaccines has been
implemented in all medical practice systems for general practitioners in DK, and that it can
be used by all general practitioners (Annex A).
The list of all general practice clinics with access to the IT system to report on the side
effects of the COVID-19 vaccines after the implementation of the IT system in the additional
practitioner’s digital platforms, containing 1680 general practice clinics in total (Annex B).

The authorities also provided:
i.

ii.

iii.

iv.

v.

vi.

vii.

viii.

List of general practice clinics which gained access to the IT system for reporting side
effects as a result of implementation of the measure, representing 956 general practice
clinics. The list also includes the associated general practitioner medical management
system and the number of GP capacities in each general practice clinic (Annex C).
Documentation from the Danish Medicine’s Agency dated 5 December 2022 showing the
date of receipt of the first reports of side effects to COVID-19 vaccines via the IT system
(webservice) for clinics not in the baseline (Annex D).
Notice by the Danish Medicines Agency in the October 2020 edition of the magazine
Monthly Journal of Rational Pharmacotherapy (Månedsbladet for Rationel Farmakoterapi),
advertising the IT-system for reporting side effects to clinics which already had access at the
baseline (Annex E).
Documentation from the Danish Health Data Authority defining the ‘GP capacities’, a
measure used to report number of GPs per clinic in Annex C, and the data sources used to
produce Annex C (Annex F).
First report of suspected side effect of the COVID-19 vaccine, sent on 18 January 2021 to
the Danish Medicines Agency using the IT-system (DKMA webservice) provided by the
general practitioner medical management system XMO (Annex G).
First report of suspected side effect of the COVID-19 vaccine, sent on 9 February 2021 to
the Danish Medicines Agency using the IT-system (DKMA webservice) provided by the
general practitioner medical management system Multimed (Annex H).
First report of suspected side effect of the COVID-19 vaccine, sent on 11 January 2021 to
the Danish Medicines Agency using the IT-system (DKMA webservice) provided by the
general practitioner medical management system NOVAX (Annex I).
First report of suspected side effect of the COVID-19 vaccine, sent on 29 January 2021 to
the Danish Medicines Agency using the IT-system (DKMA webservice) provided by the
general practitioner medical management system MyClinic (Annex J).

Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all
constitutive elements of the target.
9

Implementation of an IT-system concerning reporting of side effects of the COVID-19 vaccines.
As stated in the letter from the Danish Medicines Agency (Annex A), the optional IT-system for
reporting side effects of COVID-19 vaccines and other medicines has been implemented in all
medical practice systems in general practice clinics in Denmark and is accessible to all doctors
associated with a general practice clinic. The IT-system was deployed by all seven IT-providers of
medical management systems. In the documentation from the Danish Medicine’s Agency dated 5
December 2022 (Annex D), the Danish Medicines Agency documents the first reports of side-effects
of COVID-19 vaccines received through the IT-services of each of the four medical management
providers which additionally implemented the IT-service as part of the implementation of the target.
This shows that the system is operational and is accessible to be used by all general practitioners.
Furthermore, it is reported in the summary document that over 10 000 reports of side-effects were
received by the Danish Medicines Agency through the IT-system between February and August
2021.
Furthermore, in line with the description of the measure, the Danish authorities are required to
improve the infrastructure for monitoring and acting upon potential side effects of the COVID-19
vaccines. As described on page 3 of the Notice by the Danish Medicines Agency (Annex E), compared
to the previous e-form system, the new IT-system for reporting side-effects of COVID-19 vaccines
and other medicines automatically prefills information that is available in the GP’s local digital
platforms. This makes reporting of side-effects both quicker and easier, while reducing the need for
manual follow-up of errors by the Danish Medicines Agency. This improves the infrastructure for
monitoring and acting upon potential side effects of the COVID-19 vaccines. The measure
description also presents another objective that is not directly reflected in the milestones and
targets in the Council Implementing Decision, namely to strengthen the overall emergency planning.
However, monitoring side effects of the COVID-19 vaccines in the context of a pandemic health
emergency should also be regarded as a means to strengthen overall emergency planning by
allowing to detect treatment problems early on and adapt the emergency response accordingly.
Coverage of 1 250 additional general practitioners’ local digital platform.
As there is no central registry of the individual doctors associated with each general practice clinic,
the Danish Medicines Agency provided in Annex A an estimate of the number of general
practitioners which gained access to the system with the implementation of the measure, as well as
an estimate of the number of GPs which already had access in the baseline. The baseline estimate
is detailed below in the section “Baseline of 1 000 GPs in 2021”. This estimate is based on the total
number of GPs working across all general practice clinics in Denmark so as to produce an estimate
of the average number of GPs working in each general practice clinic. A census of the number of GPs
in general practice clinics is done every year on 1 January. On 1 January 2021 there were 3 543 GPs
affiliated to the 1 680 clinics, as listed in Annex B. This corresponds to an average number of 2.11
GPs per clinic The letter from the Danish Medicines Agency (Annex A) states that approximately 60%
of general practice clinics received access to the IT-system as a result of the implementation. The
basis for this 60% estimate is explained below in the “Baseline of 1000 GPs in 2021” section. The
Danish Medicines Agency therefore estimates that the approximately 60% of clinics which received
access after the baseline correspond to 2 126 GPs (i.e.: 60% of 3 543 GPs), which far exceeds the
target of 1 250 additional GPs with access required by the Council Implementing Decision. These
approximately 60% of clinics are listed in Annex C, which shows the 956 clinics that gained access to
the IT-system after the implementation of the measure, associated with the four medical
management IT-systems providers which implemented the IT-system after the baseline cut-off
(XMO, Novax, Multimed, MyClinic). Annex C also provides further evidence of the number of GPs
10

associated with each GP clinic to supplement the estimates from Annex A, based on data from
MedCom (a non-profit organisation financed and owned by the Ministry of Health, Danish regions
and Local Government Denmark, to facilitate cooperation between stakeholders in the Danish
healthcare sector), the Registry of Health Care Providers and the Danish Health Data Authority.
Annex C shows the number of GP capacities associated with each of the clinics in the post-baseline
group of clinics. In 2022, at the time of data collection, there were 2036 GP capacities in the 956
clinics listed in Annex C. The methodological note from the Danish Health Data Authority (Annex F)
explains that a GP capacity is an administrative measure which can be interpreted as a full-time
general practitioner. The number of GPs working in general practice clinics is expected to be higher
than the capacity measure; there can be several doctors covering one GP capacity, for example if
they work part-time. The capacity measure also does not include substitute doctors and GPs in
training. The number of GP capacities associated to clinics in Annex C can therefore be safely seen
as a ‘lower bound’ estimate of the number of physical persons working as GPs in the clinics. In order
to ascertain the plausibility of the capacity-based estimates provided by the authorities, Commission
staff undertook a spot-check of the GP figures listed in Annex C by consulting the websites of 60
corresponding general practice clinics on 3 February 2023. For this, every tenth clinic on the list was
picked from the list (entries 1, 11, 21 etc. until entry 591). Out of the 60 clinics sampled, two had
closed since the collection of the data in August 2022. From the 58 open clinics, the total number of
GPs suggested from the websites of the general practice clinics was 141, compared to an estimated
127 GP capacities in Annex C. The average number of GPs per clinic in the sample was 2.43, which
is higher than the average 2.19 suggested by the GP capacities estimate and also higher than the
overall average 2.11 used for estimation in Annex A. On this basis, the Commission considers that
the evidence provided by Denmark of the GP capacities can reliably be used as a ‘lower bound’
measure of the number of GPs in the clinics listed in Annex C, and that the number of GPs connected
as a result of implementation of the measure is at least 2036, which exceeds the target of 1250
additional GPs with access.
Baseline of 1 000 GPs in 2021.
Using the estimation method described above, the Danish Medicines Agency estimated the number
of GPs who had access at the time of measurement of the baseline (Annex A). The assumption made
to calculate both the baseline and post-baseline figures in Annex A is of an average 2.11 GPs per
clinic. In Annex C, we find that the average number of GP capacities per clinic is 2.13, which is in line
with the assumption. The Danish Medicines Agency and the Ministry of Health argue that there is
no theoretical or empirical evidence of systematic differences in the average number of GPs in clinics
between those clinics that received access before the baseline cut-off date and those after (Annex
A). According to the Danish Medicines Agency, approximately 40% of clinics had access to the ITsystem in the baseline (Annex A). On this basis, the Danish Medicines Agency estimates that 1417
GPs had access to the IT-system at the time of measurement of the baseline. Using the different
average number of GPs per clinic outlined above (2.13 GP capacities per clinics in Annex C), the
number of GPs in the baseline with previous access could be up to 1526 GPs. This is higher than the
baseline figure of 1 000 GPs cited in the Council Implementing Decision description of the target but
does not affect the additional number of GPs that gained access to the system, which — as shown
above — still exceeds the target.
The Commission considers that there is a clerical error in the text of the Council Implementing
Decision in the sense that the baseline year was incorrectly (and, at any rate, imprecisely in terms
of specific dating) stated as simply being “2021” and has undertaken the assessment on a revised
basis. The summary document explains that the baseline was in fact measured on 29 September

11

2020, when approximately 40% of general practice clinics had access to the system. This is supported
on page 3 of the Notice by the Danish Medicines Agency in the October 2020 edition of the magazine
Monthly Journal of Rational Pharmacotherapy (Månedsbladet for Rationel Farmakoterapi), (Annex
E). The Notice by the Danish Medicines Agency is an article which promotes the use of the IT-system
for reporting side effects. The Notice states that the Danish Medicines Agency had already certified
two IT providers (WinLPC and Clinea) at the time of publication, and that these two providers
covered around 40% of all general practice clinics in the country. The notice informed these clinics
that they could already use the IT-system to report side effects of medicines and announced to the
rest of the general practice clinics that the IT-system would be implemented in all general practice
medical management systems. A third provider (Ganglion) covering 0.8% of general practice clinics
also provided these clinics with access to the IT-system before the implementation of the target and
is counted in the baseline. This provider was not included in the notice in Annex E as the IT-system
of this provider was temporarily suspended due to technical issues at the time of publication (see
summary document section “Annex E”). The four remaining IT providers were certified by the Danish
Medicines Agency to implement the IT-system between 23 December 2020 and 15 January 2021
(see summary document, section “Annex C”) and the first side effects were reported between 11
January 2021 and 9 February 2021, as shown in the documentation from the Danish Medicines
Agency dated 5 December 2022 (Annex D). These four providers form the group of additionally
installed systems (i.e., those counting towards the achievement of the target relative to the
baseline).
The Danish Medicines Agency shall ensure implementation of the IT-system concerning reporting
of side effects of the COVID-19 vaccines for general practitioners to use.
The Danish Medicines Agency confirms that the IT-system is implemented in all general practice
clinics and can be used by all GPs associated with a general practice clinic (Annex A). The Danish
Medicines Agency has certified the IT providers for implementation of the IT-system (summary
document, section “Annex C”), has communicated to general practitioners about the IT-system
(Annex E and summary document section “Annex D”), and confirms receipt of reports on side effects
of COVID-19 vaccines through the IT-system (Annex D). Copies of the first reports of side-effects of
COVID-19 vaccines, as sent by GPs to the Danish Medicines Agency using the IT-system (DKMA
webservice), are provided for each of the four IT providers in the (post-baseline) additional group
(Annexes G to J). All reports are in accordance with the information provided by the Danish
Medicines Agency in Annex D. Overall, this shows that the Agency has ensured the implementation
of the IT-system for reporting side effects of COVID-19 vaccines (and other medicines) for general
practitioners to use.
Commission Preliminary Assessment: Satisfactorily fulfilled

Related Measure: C2.I5. Green transition of Agriculture and the environment –
climate technologies in agriculture
Name of the Milestone: Call for applications for the subsidy schemes for climate technologies in
agriculture (brown biorefineries) is completed
Qualitative Indicator: Call for tender has been completed
Time: Q4 2021
Context:
The measure aims to set up a subsidy scheme to promote and upscale the most promising technologies
in relation to reducing emissions in the agricultural sector. The objective of the scheme shall be to
Number: 11

12

demonstrate the use of the brown bio-refineries that have a large potential to reduce greenhouse gas
emissions in agriculture.
Milestone 11 concerns the completion of the call for applications for the subsidy schemes for climate
technologies in agriculture (brown biorefineries).
Milestone 11 is the first step of the implementation of the investment, and it will be followed by target
12 related to the realisation of one brown biorefinery allowing to test the technology in full scale. The
investment has a final expected date for implementation in Q4 2025.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all constitutive elements)
was satisfactorily fulfilled.
ii.
The publication of the call for applications, of 31 January 2022: Grants for projects that
promote technologies for reducing greenhouse gas emissions within the agricultural sector
(Pyrolysis Pool 2022)” (Indkaldelse af ansøgninger: Tilskud til projekter, som fremmer
teknologier til reduk-tion af drivhusgasudledningen inden for landbrugssekto-ren
(Pyrolysepuljen 2022)) showing that the competition is open to applications and press release
of 10 February 2022 on the call for applications. The evidence is publicly available on the
website of the energy authority and includes the mention of EU funds as well as the NGEU
logo.
iii.
Announcement from the Danish Energy Agency, of 22 June 2022, published on the website
of the Danish Energy Agency, of the approved projects, including a list of project names of
approved projects; the evidence takes the form of a press release in Danish detailing the
beneficiaries and the relevant projects including project names, expected outcomes and
grants.
iv.
Description of the three supported projects provided by the Danish Energy Agency, including
project descriptions and extract of the relevant parts of the technical specifications of the
projects in line with the objectives of the scheme; the evidence takes the form of an overview
in English of the three projects including names, grant amounts and expected outcomes.
The authorities also provided:
i.
Detailed overview of the criteria to be fulfilled to obtain support provided by the Danish
Energy Agency. This information was already included in the published call for applications.
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
The milestone shall be completed when the application round is closed, and the Danish Agricultural
Agency announces on its homepage that the application round is closed.
The evidence provided in the Publication of the call for applications of 31 January 2022 and in the Press
release of the call of 10 February 2022 meets the requirements from the Council Implementing
Decision, as the detailed information included therein clearly sets out the opening and closing dates
and the timeline for the process that relates to the application round, including the public nature of
the call and the range of eligible applicants. It spells out the deadline of 1 April 2022 and details the
EU wide competition among eligible private or public businesses or knowledge institutes including
universities and technological institutes. The milestone in the Council Implementing Decision is further
specified in the Operational Arrangements, which requires that the Danish Energy Agency, rather than
the Danish Agricultural Agency shall be considered as the authority in charge of the implementation
of the milestone. Therefore, the Danish Energy Agency took over as handling body for the subsidy
13

scheme, and the call for applications, as well as the announcement that the application round had
closed, and a list of the approved projects were published on the official website of the Danish Energy
Agency.
Furthermore, in line with the description of the measure, Denmark shall further invest in the upscaling
of the most promising technologies on the market. The measure description also asserts that the
research in new technologies not only benefits the climate and the environment but also job creation.
To this end, the call for applications of 31 January 2021 described additional investments for the
upscaling of the most promising technologies in terms of being cost effective and with a large potential
for reduction of emission in the agriculture sector (page 3 of the published call). In this regard, a
separate call for applications is to be published between 2023 and 2024 for the amount of 196 million
DKK (page 4 of the published call). This is additional to the present call for applications of 31 January
2022 that is the subject of this milestone.
The present call for applications envisages three projects that have the potential to provide new jobs
both directly and indirectly, as they allow for production sites producing biowaste that can be refined
in a sustainable manner. Equally, the three projects represent new or innovative technologies that can
be scaled up and developed commercially. It is precisely this potential for growth that benefits job
creation, over and above the creation of jobs directly linked to the three projects’ operations. The
potential for each of the projects is set out as follows: (1) on page 3 of the Announcement from the
Danish Energy Agency, for the project SkyClean it is said that the focus of the project is upscaling the
pyrolysis technology ), (2) on the same page 3 of the Announcement, the potential of the project Dall
energy is indicated as starting the process of establishing a technology centre through creating the 10
MW demonstration plant that is the outcome of the project (3) and for the third project on page 4 of
the Announcement the aim is described as further developing the chosen pyrolysis technology and
establishing a full-scale flash pyrolysis plant. On page 5 of the call for applications of 31 January 2022
it is set out that the call aims to establish larger and pronounced development and demonstration
projects, so-called lighthouse projects. A list of projects and project descriptions have been provided
by the authorities and demonstrates that the three selected projects meet the objectives of the
scheme. The authorities furthermore provided a detailed overview of the criteria to be fulfilled to
obtain support, which is also included in the call for applications.
The objective of the scheme shall be to demonstrate the use of the brown bio-refineries that have
a large potential to reduce greenhouse gas emissions in agriculture.
The call for applications issued on 31 January 2021 indicates that the objective of the scheme is to
explore innovative technologies for their further promotion (page 1: support scheme for
developments and demonstration projects in the pyrolysis technology a.o (tilskudsordning for
udviklings- og demonstrationsprojekter indenfor pyrolyseteknologi mv.); page 4: basis to support a
succeeding realisation of the potential for greenhouse gas reductions in the agricultural sector
(grundlag for at understøtte en efterfølgende realisering af potentialet for drivhusgasreduktioner I
landbruget). According to page 2 of the Announcement from the Danish Energy Agency, the call is
aimed to develop technologies that support the green transition of the Danish agriculture, primarily
through pyrolysis – a process where biomass is heated without the presence of oxygen (Puljen er
målrettet udvikling af teknologier, der skal fremme grøn omstilling af dansk landbrug, primært gennem
pyrolyse – en proces, hvor biomasse opvarmes uden tilstedeværelse af ilt). The pyrolytic method
provides the agricultural sector with opportunities to eliminate biowaste stemming from animal
production that would otherwise increase greenhouse gas emissions significantly. The scheme will
thus provide technologies for the agricultural sector that allows the sector to continue its meat
production while reducing related greenhouse gas emissions.
Commission Preliminary Assessment: Satisfactorily fulfilled

14

Related Measure: C2.R1. Green transition of Agriculture and the EnvironmentCarbon rich soils
Name of the Milestone: Call for applications for the subsidy scheme for rewetting and taking out
carbon rich soils out of production is completed
Qualitative Indicator: The call for applications for the subsidy scheme for taking
Time: Q4 2021
out carbon rich soils out of productions is completed.
Context:
The measure aims to finance the alternative use of carbon rich soils to reduce the CO2 emission of
Danish agricultural land. The scheme provides financial support to projects that reduce the CO2
emission of the agricultural sector while addressing objectives related to environment and climate
issues.
Milestone 13 concerns the call for proposals that initiates the measure. The milestone identifies the
objective of the scheme to be “to create financial incentives for farmers to take their carbon rich soils
out of production and rewet them in order to prevent the carbon from being emitted into the
atmosphere”.
Milestone 13 is the first step of the implementation of the reform, and it will be followed by targets
14 and 15 related to effectively taking out of production a total of 4 700 hectares of carbon rich land
in the context of awarded projects. The reform has a final expected date for implementation in Q2
2026.
Evidence provided:
Number: 13

In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive elements)
was satisfactorily fulfilled.
ii.
Announcement of the call for applications on the generic portal (https://www.statenstilskudspuljer.dk) used by all Danish authorities linking the announcement to the publication
on the website of the Danish Environmental Protection Agency, in an extract announcing the
opening and closure dates of the call, showing the call is open to applications.
iii.
Announcement of the Danish Environmental Protection Agency closing the application
round of the call for proposals on the generic portal used by all Danish authorities
(https://www.statens-tilskudspuljer.dk).
iv.
List of approved projects including dates, identifying numbers, project names, amounts and
internal administrative specifications.
v.
Overview of the projects selected in the first phase for further exploration, including projects
descriptions and extract of the relevant parts of the technical specifications (area in hectares
and the proportion of the project area in hectares with a carbon content of more than 6 per
cent) of the projects in line with the objectives of the scheme.
The authorities also provided:
i.
Individual detailed project descriptions including relevant parts of the technical specifications
of each project in line with the objectives of the scheme, as an extract from the project
database used by the Environment Protection Agency for the implementation of the call.
ii.
Statutory order of 8 February 2022 establishing the legal basis for the call for applications
proposals (BEK nr. 211 af 08/02/2022, “(Applicable) Order on the extraction of carbon-rich
low-lying soils for the purpose of restoring natural hydrology (climatic low-lying projects))”
(Gældende) Bekendtgørelse om udtagning af kulstofrige lavbundsjorder med henblik på
genopretning af naturlig hydrologi (klimalavbundsprojekter)).

15

iii.

Presentation provided by the Environmental Protection Agency (Miljøstyrelsen) to the
European Commission on 18 November 2022 on the details of the subsidy scheme including
overview of process details of geographical data and how they are collected.
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
The purpose of the scheme shall be to create financial incentives for farmers to take their carbon
rich soils out of production and rewet them in order to prevent the carbon from being emitted into
the atmosphere.
The statutory order of 8 February 2022 constitutes the legal act for publishing the call for applications.
Chapter 15 §29 of the statutory order of 8 February 2022 states that this statutory order repeals the
statutory order of 15 January 2021 that was the initial legal act for the publication of the call for
applications. The statutory order of 8 February 2022 defines the general objective of the call for
applications and sets the focus on taking carbon rich soils out of agricultural production with the
purpose of rewetting them, as per Chapter 1 §1 of the aforementioned statutory order of 8 February
2022.
The financial incentive for farmers is set out in Chapter 1 §3 of the aforementioned statutory order of
8 February 2022 and is represented by the compensation for the loss of productive land that the owner
of the plot is entitled to receive. The overall purpose is thus to re-establish the natural hydrology of
low-level lands and to ensure that carbon contained in the land below water level is not released into
the atmosphere due to artificially reduced water levels.
In accordance with Chapter 2 §6 of the statutory order of 8 February 2022, the criterion of ‘carbon
rich soils’ is met by lands for which at least 60% have a minimum composition of 6% organic carbon
material.
Furthermore, in line with the description of the measure, rewetting and taking carbon rich soils out of
production shall contribute to a reduction of nitrogen emission as well. Chapter 4 §9 of the
aforementioned statutory order of 8 February 2022 sets out that all lands subject to an application
under the call will be further analysed to evaluate in detail the project proposed for rewetting the
lands and must be subject to detailed calculations regarding their contribution to reductions of
emissions of CO2, nitrogen and phosphorus. According to Chapter 6 §14 of the statutory order of 8
February 2022, compensation will only be granted for those lands which in this first phase are found
to be falling within the criteria for the call. It is thus included in the process of the call that all lands will
be rewetted in accordance with the initial objective of the measure.
It is set out in Chapter 7 §17 of the statutory order of 8 February 2022 that compensation is given in
relation to the original use of the land, comprising three kinds of agricultural use forms that vary in
intensity. The three kinds of eligible use are: growing crops (highest intensity use and highest
compensation) livestock grassing (medium intensity use and compensation) and nature areas
belonging to a farm that is not used for crops or livestock (lowest intensity use and compensation).
The lands included in the applications for compensation under the call must be defined as agricultural
land.
It is further set out in Chapter 8 §19 of the statutory order of 8 February 2022 that lands for which
financial compensation is being granted must never be used for agricultural production, and that this
must be codified through a legally binding act. The codification must include details about the limits
for future use and set out that the land in question should respect the natural water levels and cannot
include crops or forestry, nor any kind of livestock production that is based on additional feeding.
It is set out in Chapter 3 §8 of the statutory order of 8 February 2022 that applicants must include a
clear geographical identification using a specific publicly available tool (MiljøGIS). Geodata are thus to
be included in the application and allow for verifying the identification of agricultural land.

16

The evidence included as ‘Individual detailed project descriptions’ makes reference to this
geographical identification for the calculation of the surface of each of the projects and sets out that
each applicant in addition has declared that the eligibility criterion related to agricultural land is met.
The milestone shall be completed when the application round is closed, and the Danish
Environmental Agency announces on its homepage that the application round is closed.
The announcement of the opening of the call for proposals and the announcement of the closing of
the call for applications clearly indicate that the call was open between 1 February 2021 and 15 April
2021. The opening and closing dates have been obtained from the generic public portal
(https://www.statens-tilskudspuljer.dk) where Danish authorities have the obligation, in line with
national legislation, to announce all public calls. The announcement of the Danish Environmental
Protection Agency closing the application round of the call for proposals that was published on the
aforementioned public portal confirms that the call was closed on 15 April 2021.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 19

Related Measure: C3.I01 Replacing oil burners and gas furnaces

Name of the Milestone: Political agreement has been adopted on the allocation of the funds for
the schemes for replacing oil burners and gas furnaces with electric heat pumps and district
heating.
Qualitative Indicator: A political agreement between the government and a
majority of the parliament is concluded and published on the relevant
Time: Q2 2021
Ministry’s webpage
Context:
The measure aims to phase out oil and natural gas heating systems and replace them with electric
heat pumps and district heating powered by renewable energy. The provision of subsidies reduces
the costs borne by consumers following the conversion to green and more energy efficient heating,
thus helping to speed up the phasing out of oil burners and gas furnaces.
Milestone 19 requires reaching a political agreement between the Danish government and
parliament on the allocation of funds for the support schemes for replacing oil burners and gas
furnaces with electric heat pumps and district heating. The political agreement is to outline the
allocation of 645 million DKK to support schemes.
Milestone 19 is the first step of the implementation of the investment, and it will be followed by
milestone 20 and target 21 related to the selection of recipients for the funding and the replacement
of 10 100 individual oil burners or gas furnaces by heat pumps or district heating substitutes. The
investment has a final expected date for implementation in Q2 2026.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive
elements) was satisfactorily fulfilled.
ii.
Political agreement of 17 March 2021 named ‘Agreement on the distribution of the subsidy
pool to phase out oil and gas boilers from the Finance Act 2021 to the four subsidy pools
from the Energy Agreement 2018 and the Climate Agreement for Energy and Industry, etc.
2020’ (Aftale om fordeling af Tilskudspulje til udfasning af olie- og gasfyr fra Finansloven
2021 på de fire tilskudspuljer fra Energiaftale 2018 og Klimaaftale for energi og industri mv.
2020) published on the Ministry for Climate, Energy and Utilities’s website and outlining the
financial allocation for schemes funding the replacement of oil burners and gas furnaces
17

iii.

with electric heat pumps and district heating. The link to the political agreement, published
26 March 2021: https://kefm.dk/aktuelt/nyheder/2021/mar/650-mio-kr-er-nu-fordelt-saaflere-danskere-kan-faa-groen-varme
Political agreement of 30 November 2021 named the ‘Agreement on the reprioritisation of
30 million DKK from the decoupling scheme and 9 million DKK from the Skrotning Scheme
to the district heating pool in 2021’ (Aftale om omprioritering af 30 mio. kr. fra
Afkoblingsordningen og 9 mio. kr. fra Skrotningsordningen til Fjernvarmepuljen i 2021)
which amends the financial allocation for the schemes funding the replacement of oil
burners and gas furnaces with electric heat pumps and district heating.

The authorities also provided:
i.
An explanation by the Ministry for Climate, Energy and Utilities, dated February 2022,
named the ‘Reduction of primary energy consumption due to pools financed by recovery
funds from the EU was reached’.
ii.
Energy Agreement 2018 of 29 June 2018 (Energiaftale 2018) which is the political
agreement from which this scheme is derived.
iii.
Climate Agreement for Energy and Industry etc. 2020 of 22 June 2020 (Klimaaftale for
energi og industri mv. 2020") which is part of the Government's climate action plan proving
the scaling up of an existing scheme.
iv.
Document provided by the Ministry for Climate, Energy and Utilities named ‘Tagging of
subsidies for renovation of buildings and conversion of heating technologies’ dated 22
May 2021, explaining the methodology for estimation of primary energy consumption.
v.
Government Order No. 1415 of 29 September 2020 (BEK nr. 1415 af 29/09/2020) named
‘Order on subsidies for individual heat pumps for the scrapping of oil or gas boilers’
(Bekendtgørelse om tilskud til individuelle varmepumper ved skrotning afolie- eller gasfyr)
showing the legal basis for a subsidy to expand district heating grids into new areas.
vi.
Government Order No. 2306 of 18 December 2020 (BEK nr. 2306 af 18/12/2020) named
‘Order on grants for projects for the roll-out of district heating distribution networks’
(Bekendtgørelse om tilskud til projekter vedrørende udrulning affjernvarmedistributionsnet)
describing the subsidy scheme on the deployment of district heating distribution networks.
It shows that households may be exempted from the fee that the Danish state-owned gas
distribution company charges for decoupling.
vii.
Danish Finance Act of 2021 which describes the measures i) Scrapping scheme
(Skrotningsordningen); ii) Decoupling (Afkoblingsordningen); iii) District Heating pools
(Fjernvarmepuljen); and how they will operate.
viii.
Document provided by the Ministry for Climate, Energy and Utilities, dated 24 November
2022, named Annex J: The 645 million DKK specified, explains how the 645 million DKK are
divided amongst the subsidy schemes and the breakdown of the allocation of 645 million.
ix.
Supplementary appropriations act for the financial year 2021 dated 27 January 2022
(Forslag til lov om tillægsbevilling for finansåret 2021) showing the new allocation of the
schemes
amounts
adopted
by
Parliament.
Link:
https://fm.dk/udgivelser/2022/januar/forslag-til-lov-om-tillaegsbevilling-for-finansaaret2021/

Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all
constitutive elements of the target.

18

The milestone shall be reached when a majority of the Danish parliament has entered an
agreement on the allocation of the funds for the support schemes for replacing oil burners and
gas furnaces with electric heat pumps and district heating.
Two political agreements (the agreement of 30 November 2021) were put forward by the governing
party Social Democratic Party (48 seats; at the time according to the parliamentary website:
https://www.ft.dk/-/media/sites/ft/pdf/folkestyret/valg-og-afstemninger/folketingsvalg-fra1953.ashx), Social Liberal Party (Radikale Venstre) (16 seats), Socialist People's Party (Socialistisk)(14
seats), Unity List (Enhedslisten) (13 seats) and The Alternative (Alternativet) (5 seats). Both
agreements were agreed by parties adding up to 96 out of 179 members of the Danish parliament,
confirming more than the 90 votes required for the majority.
The political agreement of 17 March 2021 establishes the distribution of the subsidy pool between
the sub-schemes of the scheme for replacing oil burners and gas furnaces.
The scheme is made up of four sub-schemes which originate from the ‘Energy Agreement 2018’ and
the ‘Climate Agreement for Energy and Industry etc. 2020’, as explained in further detail below in
this assessment. There are three sub-schemes that are funded by the measure that this milestone
represents: (i) Sub-scheme for district heating (“Fjernvarmepuljen”): shall provide a subsidy to
expand district heating grids into new areas; (ii) Sub-scheme for decoupling
(“Afkoblingsordningen”): the Danish state-owned gas distribution company charges a fee to cover
the cost of decoupling. With this subsidy scheme, households may be exempted from this fee. (iii)
Sub-scheme for scrapping (“Skrotningsordningen”). In addition, there are derived tax losses
resulting from these three schemes, as well as from a fourth scheme (Building Pool (Bygningspuljen)
that is not directly related to this particular measure or its assessment.
In paragraphs 1 and 2 of the political agreement dated 17 March 2021 it is stated that the subsidies
will be granted to households in order to speed up the phasing out of oil burners and gas furnaces
and help reduce the costs incurred by consumers from switching to green heating. The allocation of
funds is indicated in Table 1 of the political agreement and will be explained in further detail later in
this assessment. Page 2 states that the date for the parties to reach an agreement was 19 March
2021. Subsequently, a new political agreement was put forward and agreed on 30 November 2021,
which agreed a moderate readjustment to the allocation of funds. This new agreement amended
the one of 17 March 2021 by reprioritising 30 million DKK from the decoupling scheme and 9 million
DKK from the scrapping scheme to the district heating pool, in order to improve the take-up of the
schemes.
Furthermore, in line with the description of the measure, the scheme aims at phasing oil and natural
gas out of the heating system and replacing them with electric heat pumps and district heating from
renewable sources. This aim is stated in the ‘Climate Agreement for Energy and Industry etc. 2020’,
where subsection “Phasing out of individual oil and gas boilers” (Udfasning af individuelle olie- og
gasfyr), states that ‘oil and natural gas must be removed from the heating system and green
electricity and green district heating must be inserted instead. To speed up the phasing out of oil
and gas boilers and reduce the cost to consumers of the green heat transition, the adjustments of
heat taxes are combined with subsidies for conversions to green solutions.’
Furthermore, in line with the description of the measure, the investment that this milestone
represents shall consist in the provision of subsidies to speed up the phasing out of oil burners and
gas furnaces and to reduce the cost to consumers of the conversion to green heating. Chapter 1 §1
paragraph 1 of Government Order No. 1415 of 29 September 2020 and Chapter 1 §1 paragraph 1 of
Government Order No. 2306 of 18 December 2020, lay out the legal framework for two of the three
relevant sub-schemes, the Scrapping scheme and District heating pool scheme respectively,
outlining that the subsidies will be in the form of a grant. For the decoupling scheme
(Afkoblingsordningen), rather than awarding a grant, the sub-scheme is exempted from the
decoupling fee, which in principle, also has a favourable financial impact on households by reducing
their costs incurred when decoupling from the gas system. The support available for this third sub19

scheme is detailed on page 3228 §29 no. 130 subsection 1 through 7 of the ‘Danish Finance Act
2021’.
Furthermore, in line with the description of the measure, the support provided by the Danish
Recovery and Resilience Plan shall scale up an existing measure. The milestone in the Council
Implementing Decision requires the schemes to originate from the ‘Energy Agreement 2018’
(Energiaftale 2018) and the ‘Climate Agreement for Energy and Industry etc. 2020’ (Klimaaftale for
energi og industri mv. 2020). The Scrapping Scheme (Skrotningsordningen) can be found in the
‘Energy Agreement 2018’ under subsection “Support for individual heat pumps when scrapping oil
boilers” (Støttepulje til individuelle varmepumper ved skrotning af oliefyr), while the Decoupling and
District Heating pools (Afkoblingsordningen & Fjernvarmepuljen) can be found in the ‘Climate
Agreement for Energy and Industry etc. 2020’ under subsection “Phasing out of individual oil and
gas boilers” (Udfasning af individuelle olie- og gasfyr). Both of the aforementioned documents were
agreed prior to the negotiations of the Recovery and Resilience Plan, and therefore represent a preexisting measure that is extended through the measure under consideration in this milestone. Table
2 of the political agreement of 17 March 2021 shows the allocation of funds from the ‘Energy
Agreement 2018’ and the ‘Climate Agreement for Energy and Industry etc. 2020’ as well as the
additional funds from the Danish Finance Act 2021 from which the RRF funds have been distributed.
Considering that the total amounts for Table 2 are higher than the sums listed in ‘Annex J: the
645million specified’ for the same sub-measures, this also proves the upscaling of already existing
measures.
A political agreement between the government and a majority of the parliament is concluded and
published on the relevant Ministry's webpage.
The political agreement of 17 March 2021, as reached by the parties involved, was published in the
form of a press release on the Danish Ministry for Climate, Energy and Utilities website. The second
political agreement of 30 November 2021, amending the allocation of funds was not published in
the Danish Ministry for Climate, Energy and Utilities website.
The Council Implementing Decision states that the political agreement should be concluded and
published. Whilst the political agreement of 30 November 2021 was not published, its conclusion is
evidenced by the supplementary appropriations act for the financial year 2021, which demonstrates
that this political agreement was followed. This also proves that the political agreement of 17 March
2021 was superseded by the political agreement of 30 November 2021 in terms of budgetary
execution and that the scheme was conducted using the amended allocation. On this basis, it is
considered that this constitutive element of the milestone is satisfactorily fulfilled.
The political agreement shall be on how 645 million DKK is to be distributed among the support
schemes to phase out oil burners and gas furnaces.
Table 1 named ‘Economic profile, subsidy pools for phasing out oil and gas boilers – funds allocated
with the Finance Act 2021’ within the Political agreement of 17 March 2021 shows the distribution
of 650 million DKK in expenditure funds that were allocated by the Finance Act 2021 to phase out
oil and gas boilers for the years 2021 to 2024 and that were split amongst four schemes (in addition
to 300 million DKK already located separately to the ‘Building Pool’ in 2021 in connection with the
Finance Act 2021): (i) District heating pool; (ii) Scrapping scheme (iii) Building pool; and (iv)
Decoupling scheme, and including in the final row, the derived tax losses of the four schemes in
2021-2025 for this allocation. As already outlined above, only three of the schemes in this table were
funded by this particular sub-measure (Component 3, investment 1), and these are the District
heating scheme (Fjernvarmepuljen) with 340 million DKK, the Scrapping scheme
(Skrotningsordningen) with a total of 20 million DKK, and 125 million DKK were distributed to
subsidies for decoupling private house owners from the gas system within the Decoupling scheme
(Afkoblingsordningen). These add up to 485 million DKK in total and this sum corresponds to the
measures costed by the RRF, while the Building pool scheme is funded by another measure within
20

the Danish Recovery and Resilience Plan (Component 3, investment 4). Additionally, the table shows
the derived tax losses for all four schemes adding up to 260million DKK. As 100million DKK of the
total derived tax losses are attributed to the derived tax losses of the Building Pool, as explained in
the summary document, the remaining 160 million DKK in tax losses are derived from the three
schemes that fall under the sub-measure at hand. This sums the total costs for the three schemes
including the derived tax losses to the total of 645 million DKK required by the Council Implementing
Decision. ‘Annex J: the 645 million DKK specified’ extracts the relevant tax losses for the three
schemes to 160 million DKK and reduces it with the 100 million DKK from the original 260 million
DKK quoted in the Table 1 of both political agreements. The derived tax losses are solely funded by
national funds and are therefore not considered further for the sake of this assessment.
Following this political agreement of 17 March 2021, another agreement was reached, as per the
political agreement of 30 November 2021. A small proportion of funds were reallocated amongst
the four aforementioned schemes, so as to ensure full disbursement of the funds. 30 million DKK
were reallocated from the decoupling scheme (Afkoblingsordningen) and 9 million DKK reallocated
from the scrapping scheme (Skrotningsordningen) to the district heating pool (Fjernvarmepuljen) as
the latter scheme received more applications. Thus, a total amount of 39 million DKK, as depicted
in Table 1 of the political agreement dated 30 November, was reallocated in order to ensure
maximization of the efforts for phasing out oil and gas boilers through greater uptake of subsidies,
as explained in paragraph 1 of the political agreement of 30 November 2021. The new allocation
from Table 1 of the political agreement dated 30 November 2021 is as follows: (i) District heating
pool with 379 million DKK, (ii) scrapping scheme with 11 million DKK; (iii) Building pool with 465
million DKK (iv) Decoupling mechanism with 95 million. Summing only the three schemes covered
by this Recovery and Resilience Plan measure ((i), (iii) and (iv)), these add up to 485 million DKK,
which still corresponds to the original costing for the measure at hand. Table 1 of the document
‘Annex J: specifying the 645 million DKK’ provided by the Ministry for Climate, Energy and Utilities
dated 24 November 2022, includes the 160 million derived tax losses that are not funded by the
Recovery and Resilience Facility, but are included in the 645 million DKK of the Council Implementing
Decision.
Furthermore, in line with the description of the measure, the scheme for district heating
(Fjernvarmepuljen) shall provide a subsidy to expand district heating grids into new areas. With an
allocation of 340 million DKK, as per political agreement of 17 March 2021, the sub-scheme targets
the expansion of the district heating network by subsidising the expansion of the grid into areas
currently not reached by the district heating network. This is described in §3 paragraph 2 of
Government Order No. 2306 of 18 December 2020, the funds are granted per conversion to the
newly rolled out district heating from gas or oil furnaces. On page 3228 of the ‘Danish Finance Act
2021’ (no. 129), which Government Order No. 2306 of 18 December 2020 refers to, clarifies that the
minister may grant subsidies for district heating companies who roll out new district heating grids
and thereby creates new district heating areas. On §18 of Government Order No. 2306 of 18
December 2020 it is clarified that the legal framework for the district heating pool enters into force
10 January 2021. Moreover, it is shown in table 1 and 2 in the political agreement of 17 March 2021,
that the funds from the Danish Recovery and Resilience Plan are additional allocations to the already
nationally financed scheme, thereby upscaling the measure, as explained previously in our
assessment.
Furthermore, in line with the description of the measure, for the scheme for decoupling
(Afkoblingsordningen) the Danish state-owned gas distribution company charges a fee to cover the
cost of decoupling. With this subsidy scheme, households may be exempted from this fee. Page
3228 §29, no. 130 subsection 1 through 7 of the evidence Danish Finance Act 2021, shows that 125
million DKK were allocated to the subsidy for decoupling private house owners from the gas system,
which is described as a fee exemption scheme, with an amount equivalent to that of the Danish
utility regulator.

21

Furthermore, in line with the description of the measure, the scheme for scrapping
(Skrotningsordningen) shall provide a subsidy for companies that offer heat pumps on subscription
for private year-round housing of 20 million DKK, as per Political agreement of 17 March 2021, or
the new allocation of 11 million DKK as per Political agreement of 30 November 2021 and ‘Annex J:
The 645 million DKK specified’, is allocated heat pumps on subscription for year-round private
housing, as described in §1 paragraph 1 and 2 of Government Order No. 1415 of 29 September 2020.
The measure shall achieve at least a 30% reduction in primary energy demand at the level of the
building.
Paragraph 2 and Table 1 of the document ‘Reduction of primary energy consumption due to pools
financed by recovery funds from the EU’ provide the calculations for the estimated reduction on
how much the consumption of primary energy will decrease as a result of the shift from oil burners
and gas furnaces to electric heat pumps and district heating. In total, the pools will reduce the
primary energy consumption by 276 GWh/year out of a total of 680 GWh/year affected heat. The
total estimated reduction in primary energy is calculated at around 41%, which meets the
requirement that the measure shall achieve at least a 30% reduction in primary energy demand at
the level of the building.
Commission Preliminary Assessment: Satisfactorily fulfilled

Related Measure: C3.I03. Energy efficiency, green heating and CCS - Energy
efficiency in industry
Name of the Milestone: Entry into force of the legal framework for a subsidy scheme for energy
efficiency in industry.
Qualitative Indicator: The parliament has adopted the legal act
setting up the subsidy scheme, published and it has entered into Time: Q3 2021
force.
Context:
The measure aims to speed up energy efficiency interventions and the transition to green energy in
industry through the scale up of an existing national subsidy scheme. The scheme targets energy
savings in all private businesses and the distribution of funds through a competitive selection
procedure based on a criterion of highest energy savings per subsidy received.
Milestone 22 concerns the adoption, publication, and entry into force of the legal framework for the
subsidy scheme for energy efficiency in industry.
Milestone 22 is the first step of the implementation of the investment, and it will be followed by
milestone 23 and target 24, related to the completion of the application rounds for the subsidy
scheme, and the achievement of a reduction of the final energy consumption of Danish industry by at
least 16 petajoule. The investment has a final expected date for implementation in Q4 2024.
Number: 22

Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive elements)
was satisfactorily fulfilled.
ii.
Consolidated Act No. 1897 of 1 October 2021 (LBK nr. 1897 af 01/10/2021) titled Order of the
Act on the promotion of savings in energy consumption (Bekendtgørelse af lov om fremme
af besparelser i energiforbruget), published in the Danish official online Journal

22

iii.

Retsinformation.dk concerning the Act on the promotion of savings in energy consumption.
The link can be found here: https://www.retsinformation.dk/eli/lta/2021/1897
Administrative Order No. 2237 of 1 December 2021 (BEK nr. 2237 af 01/12/2021) titled Order
on grants for energy savings and energy efficiency improvements in commercial enterprises
published in the Danish official online Journal Retsinformation.dk on grants for energy savings
and energy efficiency improvements in commercial enterprises. The link can be found here:
https://www.retsinformation.dk/eli/lta/2021/2237

The authorities also provided:
i.
Political agreement on energy, Energy Agreement 2018 (Energiaftale) of 29 June 2018,
published on the Ministry for Taxation website (Skatteministeriet) that sets out the action plan
towards
the
green
transition.
The
link
can
be
found
here:
https://www.skm.dk/aktuelt/publikationer/politiske-udspil-og-aftaler/energiaftale-2018/
ii.
Administrative Order No. 1414 of 29 September 2020 (BEK nr 1414. Link:
https://www.retsinformation.dk/eli/lta/2020/1414 af. 29/09/2020) titled Order on grants for
energy savings and energy efficiency improvements in commercial enterprises
(Bekendtgørelse om tilskud til energibesparelser og energieffektiviseringer i
erhvervsvirksomheder) published in the Danish official online Journal Retsinformation.dk
showing the measure derives from an existing scheme. The link can be found here:
https://www.retsinformation.dk/eli/lta/2020/1414
Analysis:
The justification and substantiating evidence provided by Denmark authorities covers all constitutive
elements of the milestone.
Legal framework for a subsidy scheme for energy efficiency in industry has been adopted by the
parliament, published and entered into force.
The publication of the political agreement on energy, the Energy Agreement 2018 of 29 June 2018,
was followed by the adoption of Consolidated Act No. 1897 of 1 October 2021 setting the legal basis
for energy efficiency subsidy schemes in general, and of Administrative Order No.2237 of 1 December
2021 on grants for energy savings and energy efficiency improvements in commercial enterprises.
Consolidated Act No. 1897 of 1 October 2021 and Administrative Order No. 2237 of 1 December 2021
were published on the official website “retsinformation.dk”, the joint state legal information system
which provides access to all applicable laws, executive orders and circulars. Chapter 1 of Consolidated
Act No. 1897 of 1 October 2021 establishes the basis of the legal framework for the subsidy scheme
for “energy savings and energy efficiency improvements in commercial enterprises”. Administrative
Order No. 2237 of 1 December 2021 sets out the detailed provisions for the subsidy scheme for
“energy savings and energy efficiency improvements in commercial enterprises” and has its legal basis
in Chapter 1 paragraph 1 of Consolidated Act No. 1897 of 1 October 2021.
In line with national legislation, the Consolidated Act No. 1897 of 1 October 2021 was approved by the
Ministry for Climate, Energy and Utilities. In accordance with Danish Law, the approval of a
consolidated act is an administrative step made by the competent ministry and does not require going
through the parliamentary procedure.
Chapter 14 §4 of the Consolidated Act No. 1897 of 1 October 2021 indicates that the Consolidated Act
entered into force on 1 July 2021 and was signed by the Danish Energy Agency on 1 October 2021.
Chapter 8 §25 of the Administrative Order No. 2237 of 1 December 2021 indicates that the
Administrative Order entered into force 1 January 2022 and was signed by the Ministry for Climate,
Energy and Utilities on 1 December 2021.
Furthermore, in line with the description of the measure, the initiative aims to speed up energy
efficiency measures in industry and is expected to lead to a reduction in greenhouse gas emissions.
23

Chapter 1 §1 paragraph 1 of Administrative Order No. 2237 of 1 December 2021 states that the Order
aims at ‘achieving reductions in the use of fossil fuels in connection therewith’ and as a result, this will
help transition to lower energy consumption in industry which would ensue in the reduction of
greenhouse gas emissions.
Furthermore, in line with the description of the measure, the scheme scales up an existing national
scheme by building on the originally and exclusively nationally funded scheme which was adopted in
the framework of the political agreement on energy, Energy Agreement 2018 and which originates
from Administrative Order No.1414 of 29 September 2020 on ‘Order on grants for energy savings and
energy efficiency improvements in business enterprises’. This political agreement of 29 June 2018 was
agreed by a majority of the Parliament, consisting of the Government at the time (Venstre, Liberal
Alliance and Det Konservative Folkeparti) and other parties including: Social Democratic Party, Danish
People's Party, Unity Party, Alternative Party, Radical Left and Socialist People's Party
(Socialdemokratiet, Dansk Folkeparti, Enhedslisten, Alternativet, Radikale Venstre and Socialistisk
Folkepart), and includes on page 9 a subsidy scheme for “Energy savings and energy efficiency
improvements in commercial enterprises”, as mentioned under section ‘Targeted energy saving
efforts’ (Målrettet energispareindsats) paragraphs 1 and 2. By allocating additional funding to the
existing scheme mentioned in the Energy Agreement 2018, Consolidated Act No. 1897 of 1 October
2021 and Administrative Order No. 2237 of 1 December 2021 scale up the existing initiative.
Furthermore, in line with the description of the measure, the subsidy scheme “Energy savings and
energy efficiency improvements in commercial enterprises” targets energy savings in all private
businesses. Chapter 3 paragraph 2 of Administrative Order No. 2237 of 1 December 2021 states that
all non-public enterprises are eligible for this grant scheme, which is equivalent to all private
businesses, as required in the Council Implementing Decision. As included in Chapter 1 §3 point 4 of
Administrative Order No. 2237 of 1 December 2021, the scope of the overall energy savings envisaged
by the scheme can be determined on the basis of the “final energy consumption”, which is an official
statistical definition prescribed by article 2 paragraph 3 of the Directive 2012/27/EU of the European
Parliament and of the Council of 25 October 2012 on energy efficiency. “Final energy consumption” is
thus defined as representing all energy supplied to industry, transport, households, services and
agriculture. It excludes deliveries to the energy transformation sector and the energy industries
themselves. This definition, also outlined in Chapter 1 §3 point 4 of Administrative Order No. 2237 of
1 December 2021, sets out the basis for calculating the energy savings in industry achieved by the
subsidy scheme “Energy savings and energy efficiency improvements in commercial enterprises”. The
scheme does not cover deliveries to the energy transformation sector and the energy industry itself,
as these do not qualify as end users, in line with article 2 paragraph 3 of the energy efficiency directive
2012/27/EU. Chapter 1 §3 point 4 of Administrative order No. 2237 of 1 December 2021 refers to this
exclusion.
The funds shall be allocated on the basis of a competitive selection procedure.
In line with the provisions of Chapter 4 §11 paragraph 2 of Administrative Order No. 2237 of 1
December 2021, funds are to be allocated through application rounds. Calls by the Danish Energy
Agency are published on their respective website as per Chapter 4 §11 paragraph 1 of Administrative
Order No. 2237 of 1 December 2021. Furthermore, the calls are also published on the website statenstilskudspuljer.dk of the Agency for Public Finance and Management that falls under the responsibility
of the Ministry of Finance, which compiles information on all central government schemes from all
ministries on one platform. Chapter 4 §11 paragraph 2 of Administrative Order No. 2237 of 1
December 2021 describes that the length of the application period has to be specified in the
publication of the calls before the opening of the application rounds. Applications are ranked based
on the bidding price per saved kWh, according to the procedure laid out in Chapter 4 §12 paragraph 3
of Administrative Order No. 2237 of 1 December 2021. The selection is therefore based on the projects
that would result in the highest energy efficiency savings. Moreover, Chapter 2 §5 paragraph 2 of
Administrative Order No. 2237 of 1 December 2021 outlines that the Danish Energy Agency caps the
24

total grant amount to 15 million EUR per investment project. Therefore, it can be concluded that
Administrative Order No. 2237 of 1 December 2021 provides for a competitive selection procedure for
granting the subsidy scheme for energy efficiency in industry.
Commission Preliminary Assessment: Satisfactorily fulfilled

Related Measure: C3.I03 Energy efficiency, green heating and CCS - Energy
renovations in public buildings
Name of the Milestone: The government issues statutory order establishing a subsidy scheme for
energy renovations in public buildings.
Qualitative Indicator: The statutory order is published and shall
include the legal framework for model/set-up for the subsidy Time: Q4 2021
scheme for energy renovations in public buildings
Context:
The measure aims to support, through a subsidy scheme, energy renovations of regional and municipal
buildings. It targets buildings with the lowest energy performance certificate standards, as well as
buildings still being heated by oil burners and gas furnace.
Milestone 25 concerns the publication of the statutory order establishing the subsidy scheme for
energy renovations in public buildings, defining the conditions for receiving funding.
Milestone 25 is the first step of the implementation of the investment, and it will be followed by target
26, related to the improvement in the energy performance of 40% of the municipal and regional
buildings with D-G rating. The investment has a final expected date for implementation in Q4 2025.
Evidence provided:
Number: 25

In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all constitutive elements)
was satisfactorily fulfilled.
ii.
Government Order No. 1816 of 14 September 2021 (BEK nr 1816 af 14/09/21) titled Order
on subsidies for energy improvements and digital solutions in municipal and regional
buildings (Bekendtgørelse om tilskud til energiforbedringer og digitale løsninger i kommunale
og regionale bygninger) published in the online Danish Official Journal ‘Retsinformation.dk’:
https://www.retsinformation.dk/eli/lta/2021/1816
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
The milestone is reached when the government has published the statutory order.
As required by the Council Implementation Decision, the Danish government has published the
statutory Government Order No. 1816 of 14 September 2021 establishing the legal framework
defining the subsidy scheme for energy renovations in public buildings. This Government Order was
published in the online Danish Official Journal ‘Retsinformation.dk’, the joint state legal information
system which provides access to all applicable laws, executive orders and circulars. Its article §34
indicates that the Government Order entered into force on 20 September 2021.
This legal framework shall define the conditions for receiving funding under the subsidy scheme for
energy renovations in public buildings, such as maximum grant size or target group.
As required by the Council Implementation Decision, articles §1 to §7 of Government Order No. 1816
of 14 September 2021 define the conditions for receiving funding under the subsidy scheme for energy
renovations in public buildings. The conditions for receiving funding include:
25

Maximum grant size: Chapter 3 §12 paragraphs 3 and 4 of the Government Order No. 1816
define the upper and lower limits of the grants per project. As per Chapter 3 §12 paragraph 5
of the Government Order No. 1816, in case of full disbursement of the allocated funds to the
subsidy scheme, each municipality can obtain a maximum total grant of 4 million DKK. If there
is no full disbursement of the allocated funds of the subsidy scheme, this threshold may be
surpassed as defined in Chapter 3 §12 paragraph 5 of this Government Order.
ii.
The target group: Chapter 1 §1 paragraph 1 of the Government Order No. 1816 identifies that
the target group of the statutory order is composed of the regional and municipal buildings
with the lowest energy performance as well as the buildings still being heated by oil burners
and gas furnace.
Chapter 1 §6 paragraph 1 of the Government Order No. 1816 of 14 September 2021 sets out that the
subsidy targets energy savings renovations and the transition to green heating in buildings.
Furthermore, in line with the description of the measure, the subsidy targets energy renovations in
regional and municipal buildings with the lowest energy performance certificate standards. The
Government Order establishes in its article §1 paragraph 1 and article §3 that it targets the
aforementioned actions and buildings, stipulating that the Danish Energy Agency can only grant
subsidies to projects made in buildings with energy certificate standards rated D, E, F and G which are
the four lowest tiers of the Danish energy certificate standards.
Furthermore, in line with the description of the measure, municipal and regional buildings that are
heated by oil burners and gas furnaces are also eligible for the scheme, as they hold very low rated
energy certificates by default, as defined in §6 paragraph 3 (a) and (b) of Government Order No. 1816
of 14 September 2021.
i.

Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 27

Related Measure: C3.I5 Carbon Capture Storage (CCS) Potential
Name of the Milestone: Award of contracts for selected applicants for the CCS feasibility study
Qualitative Indicator: Call for applicants and selection of fund receivers
Time: Q4 2021
completed.
Context:
The measure aims to conduct a study of the technical and economic feasibility of CO2 storage in
depleted oil and gas fields in the Danish part of the North Sea, through development, testing and
demonstration of CO2 storage.
Milestone 27 concerns the award of contracts for selected applicants for the carbon capture and
storage (hereinafter referred to as “CCS”) feasibility study, selected after an open selection
procedure.
Milestone 27 is the first step of the implementation of the measure, and it will be followed by
milestone 28 which is the final milestone related to the completion of the feasibility study. The
investment has a final expected date for implementation in Q4 2023.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all constitutive elements)
was satisfactorily fulfilled.
ii.
A copy of the call for applications for funding from the Energy Technology and
Demonstration Programme (Energiteknologiske Udviklings- og Demonstrationsprogram)
EUDP 2021-II, in original Danish and the English translation, showing that the call is open to
26

iii.
iv.
v.

vi.

applications and including relevant parts of specification proving alignment with the
description of the target and investment in the CID annex.
A copy of selection criteria and conditions for development and demonstration projects, as
included in the call for applications.
Description of the awarded project Greensand Phase 2, including terms of reference, from
the EUDP website. Link: https://eudp.dk/projekter/project-greensand-fase-2
Letter from the EUDP secretariat addressed to INEOS Oil & Gas Denmark, dated 9 December
2021, notifying the award of the project Greensand Phase 2 and grant agreement for year
2021.
Letter from the EUDP secretariat addressed to INEOS Oil & Gas Denmark, dated 31 January
2022, notifying the award of the project Greensand Phase 2 and grant agreement for year
2021 and 2022. The English translation was also provided.

The authorities also provided:
i.
Announcement of the opening of the call for applications from the Danish Energy Agency
website, dated 24 June 2021. Link: https://eudp.dk/nyheder/mere-500-mio-kroner-til-nyeenergiprojekter
ii.
Announcement of the awarded project published on the EUDP website, including a
description of the project. Link: https://eudp.dk/nyheder/eudp-stoetter-groenenergiteknologi-med-554-mio-kroner

Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all
constitutive elements of the milestone.
The selection of applicants for the CCS feasibility studies is completed.
Page 5, section “Carbon storage in the North Sea”, of the Call for applications for funding from the
Energy Technology and Demonstration Programme (Energiteknologiske Udviklings- og
Demonstrationsprogram) EUDP 2021-II provided by the authorities, includes the CCS feasibility
study. The call was open from 24 June 2021 to 3 September 2021 as referenced in the
Announcement of the opening of the call for applications. The deadline for applications can also be
found on pages 1 and 4 of the Call for applications for funding from the Energy Technology and
Demonstration Programme (Energiteknologiske Udviklings- og Demonstrationsprogram) EUDP
2021-II. The awarded project for the CCS feasibility study was publicly announced by EUDP on its
website on 14 December 2021, as indicated in the Announcement of the awarded project from the
EUDP website. The EUDP notified the project applicant INEOS Oil & Gas Denmark that their project
had been selected as stated in the letter from the EUDP secretariat addressed to INEOS Oil & Gas
Denmark, dated 9 December 2021. The letter contains the grant information for the 2021 tranche
of the grant and project agreement. A subsequent letter from EUDP to the applicant, dated 31
January 2022, contains the grant information including both the 2021 and 2022 tranches of the grant
and the revised project agreement. The funding for the project was divided equally between the
2021 National Budget and the 2022 National Budget with DKK 98.5 million per tranche, totalling 197
million. The funds for 2022 only became available after the entry into force of the Danish Finance
Act for the Financial Year 2022 (Finanslov for finansåret 2022), as explained in paragraph 7 on page
5 of the Call for applications, hence the second letter dated 31 January 2022 contains the funding
information including the 2022 tranche. As described on page 5 of the Call for applications, this is
the only round of applications for the feasibility study. As the awarded project has been selected
and notified, the selection of applicants is completed. The Council Implementing Decision states that
the milestone shall be reached when the selection of applicants for the CCS feasibility is completed.
Only one project was awarded and thus one applicant selected. The project was selected following
27

an open selection procedure and is a feasibility study corresponding to the requirements of the
Council Implementing Decision as described below. On this basis, it is considered that this
constitutive element of the milestone is satisfactorily fulfilled.
Furthermore, in line with the description of the measure, the above-mentioned call targets the
development and demonstration of the technical and economic feasibility of CO2 storage in
depleted oil and gas fields in the Danish part of the North Sea. As stated on page 5 of the Call for
applications (English version), the call was open to “projects which deal with development and
demonstration of technologies related to carbon storage in the North Sea”, specifically in “end-oflife oil and gas fields in the Danish part of the North Sea”. Moreover, on page 1 of both the Letter
from the EUDP secretariat addressed to INEOS Oil & Gas Denmark dated 9 December 2021 and the
Letter from the EUDP secretariat addressed to INEOS Oil & Gas Denmark dated 31 January 2022, it
is specified that “the application meets the established criteria, which appear from the EUDP 2021II call”. This specification in the letters of award shows alignment with the description of the target
and measure description in the Council Implementing Decision. The Announcement of the awarded
project from the EUDP website includes a short description of the awarded project (Project
Greensand Phase 2) and shows that the awarded project focuses on CO2 storage in the Nini field in
the Danish part of the North Sea. A more detailed description including the terms of reference can
be found in the Description of the awarded project Greensand Phase 2. Project Greensand Phase 2
aims to generate the necessary knowledge to subsequently store 0.5 to 1.5 million tons of CO2 in
the Nini gas field, by raising the technology readiness level (hereinafter referred to as “ TRL”) of the
project from TRL 5 (technology validated in relevant environment – industrially relevant
environment in the case of key enabling technologies) to TRL 8 (system complete and qualified) and
by providing necessary technical documentation for a subsequent storage site permit application.
Furthermore, in line with the description of the measure, the support does not cover investments
needed to implement operational CO2 storage facilities but only a feasibility study, as described
above. Page 9 of the Call for applications for funding from the Energy Technology and
Demonstration Programme (Energiteknologiske Udviklings- og Demonstrationsprogram) EUDP
2021-II, section 2.8, specifies which type of projects would not be eligible for funding, which include
the deployment of existing technology, the commercial operation of plants, the expansion of
infrastructure among others. On page 1 of both the Letter from the EUDP secretariat addressed to
INEOS Oil & Gas Denmark dated 9 December 2021 and the Letter from the EUDP secretariat
addressed to INEOS Oil & Gas Denmark dated 31 January 2022, it is specified that “the application
meets the established criteria, which appear from the EUDP 2021-II call.” This ensures that the
selected project is a feasibility study and will not include investments to implement operational CO2
storage facilities.
Furthermore, in line with the description of the measure, further development, testing and
demonstration of CO2 storage will be carried out in order to determine the technical and financial
feasibility before any depleted gas and oil fields become operational. The criteria of the Call for
applications for funding from the Energy Technology and Demonstration Programme
(Energiteknologiske Udviklings- og Demonstrationsprogram) EUDP 2021-II, section 2.1, states that
demonstration projects (TRL 6-8), such as Project Greensand Phase 2 (TRL 5-8), involve experimental
testing of a technology with the aim of subsequent introduction to the market or further
development before market introduction. As stated on pages 1 and 2 of the description of the
awarded project Greensand Phase 2, the project will provide the necessary technical documentation
and the reports for a subsequent CO2 storage site permit application. The awarded project will also
assess the monitoring technologies that enable environmentally friendly CO2 capture and storage.
Open selection procedure.
In accordance with the requirement of the Council Implementing Decision on selecting applicants
on the basis of an open call, the call for applications was announced publicly on the EUDP website,
as seen in the Announcement for the opening of the call, available at the following link:
28

https://eudp.dk/nyheder/mere-500-mio-kroner-til-nye-energiprojekter. The Danish Energy Agency
also made a press release announcing the application round and describing the earmarked pool for
the CCS feasibility study, available at the following link: https://ens.dk/presse/ny-pulje-skalfremme-co2-lagring-i-nordsoeen. The selection criteria are detailed on page 7 of Call for applications
for funding from the Energy Technology and Demonstration Programme (Energiteknologiske
Udviklings- og Demonstrationsprogram) EUDP 2021-II. As per page 10, the description of eligibility
criteria under section 3.1 of the call does not contain unreasonable restrictions to access, given that
all public and private enterprises as well as knowledge institutions registered in the Danish Central
Business Register could apply for funding, including foreign participants registered in the Danish
Central Business Register. Given the public nature of the call, the fact that applications could be
submitted from 24 June 2021 to 3 September 2021, the explicit selection criteria and open access,
it is considered that the selection followed an open selection procedure.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 31

Related Measure: C4.I1. Investment window
Name of the Milestone: A political agreement on an investment window has been adopted by the
Danish Parliament and the relevant legislative procedures in the Parliament have been launched.
Qualitative Indicator: The political agreement on the green tax reform including
the investment window is signed and published on the Ministry of Taxation's
Time: Q4 2020
webpage.
Context:
The aim of this measure is to establish an investment window for business investment. Investments
within this investment window will benefit from a tax rebate, implying an economic incentive for such
investments. The measure is part of the green tax reform, of which the investment window is an
integral part, to foster economic activity in the short-term leading to reduced greenhouse gas
emissions in the longer term.
Milestone 31 requires the Danish parliament to adopt a political agreement on an investment window
and to launch the relevant legislative procedure. The political agreement constitutes a political
commitment for the concerned political parties to support a given political initiative. On this basis the
legislative procedures are launched.
Milestone 31 is the first step of the implementation of the investment, and it will be followed by
milestone 32 and target 33, related to the adoption of the legislation and its entering into force and
to 1000 companies having used the tax deduction provided by the investment window, respectively.
The investment has a final expected date for implementation in Q2 2024.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including the constitutive elements)
was satisfactorily fulfilled.
ii.
Political agreement on green tax reform (Aftale om Grøn skattereform) of 8 December 2020
as published on the website of the Ministry of taxation and the link:
https://www.skm.dk/aktuelt/presse-nyheder/pressemeddelelser/bred-aftale-skattereformkickstarter-groen-omstilling/
The Ministry of Taxation links to the agreement from the initial publication on the Ministry of
Finance website. The link can be found:
https://fm.dk/nyheder/nyhedsarkiv/2020/december/bred-aftale-om-groen-skattereformbaner-vej-for-groen-omstilling-i-erhvervslivet/

29

The authorities also provided:
i.
Legislative proposal on the green tax reform (Draft Law No. L 178 Proposal to Act amending
the Depreciation Act, the Tax Assessment Act; the Pension Return Tax Act and the Sulphur Tax
Act), Lovforslag nr. L 178 (Forslag til Lov om ændring af afskrivningsloven, ligningsloven,
pensionsafkastbeskatningsloven og lov om afgift af svovl), published on 24 February 2021 in
the online Danish Official Journal Retsinformation.dk. The link can be found here:
https://www.retsinformation.dk/eli/ft/202012L00178

Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
A majority of the Danish Parliament has entered an agreement on the green tax reform including
the investment window.
On 8 December 2020 a political agreement on the green tax reform was reached. At page 4 in the
chapter on compensatory measures (kompensation i forbindelse med første fase af grøn
skattereform), it is stipulated that the agreement includes an investment window. The political
agreement on the green tax reform, including the investment window, has been reached by a broad
majority in the Danish Parliament, thereby ensuring that the agreement should hold also in case of a
change in the political majority. As indicated in the title of the agreement, it was agreed by a broad
majority of the political parties in the Danish Parliament - Social Democratic Party (Socialdemokratiet)
(the ruling party at the time), as well as the parties Liberal Party (Venstre), Social Liberal Party (Radikale
Venstre), Socialist People's Party (Socialistisk Folkeparti) and The Conservative People's Party (Det
Konservative Folkeparti). At the time of the agreement, these parties represented 130 out of 179 seats
in the Danish Parliament.
The Council Implementing Decision states that the political agreement should be signed. In accordance
with Danish parliamentary procedures, political agreements are not signed. They are agreements
amongst legislative coalitions obliging the parties to vote in favour of the agreed law or legislative
package in Folketinget and give all parties in the conciliation community a veto right in relationship to
amendments to the consensual legislation. Nonetheless, the agreement of the political parties is
evidenced by the publication of the document and the presence of the respective parties on the first
page of the agreement. On this basis, it is considered that this constitutive element of the milestone
is satisfactorily fulfilled.
Furthermore, in line with the description of the measure, the investment window is expected to boost
the companies’ growth potential and job creation, while encouraging companies to invest in new
hardware and technology that can reduce emissions in the longer run. The investment window is a
two-year tax rebate on business investment and implies a tax subsidy (since 116% of an investment
can be depreciated), which creates an incentive for additional investment. The investment window is
indicated on page 4, fifth paragraph of the political agreement. Furthermore, the announced
subsequent increase in energy taxation creates an incentive for business investment in technologies
to reduce such emissions.
Furthermore, in line with the description of the measure, the tax reform shall consist of temporarily
increased tax deduction for companies investing in productive capacity such as technology and
software that may help increasing business operations and at the same time reduce greenhouse gas
emissions. This is achieved through an investment window implying a tax rebate (since 116% of an
investment can be depreciated), which creates an incentive for additional investment. Furthermore,
the announced subsequent increase in energy taxation and later of emission taxation creates an
incentive for business investment in technologies to reduce such emissions.
Furthermore, in line with the description of the measure, the investment window should not include
machinery running on fossil fuels to ensure a green transition of industry and ensure compliance with
the “Do No Significant Harm” principle. Page 4 of the draft law (fifth paragraph) excludes fossil fuel
30

driven machinery. In case of investments when there is no real green alternative, RRF funding will not
apply but national funds could, as explained in the summary document. To that end, page 114 of the
national Danish Recovery and Resilience Plan included a safety margin of 6.5% between the estimated
tax revenue shortfall and the costing estimate (last paragraph) to ensure full compliance with this
condition. This safety margin is calculated as the upper bound of the range of observed annual shares
of business investments in fossil fuel driven vehicles other than cars in total business investments over
the 2008-2017 period. Additionally, two elements are provided by authorities re-assuring on the
effective exclusion of any fossil fuel vehicles: (i) confirmation that the structure of demand for the tax
scheme has not changed significantly, thus the safety margin of national funding is currently higher
that the period average (4.8%); and (ii) confirmation that the subsequent target (T33) can be achieved
in full alignment with fossil-fuel exclusion as compliant selection will be carried out by Danish
authorities. The acquisition of new technology through investments benefitting from the economic
incentives of the investment window can be expected to provide positive climate and environmental
effects, due to generally cleaner technology of modern equipment, including lower energy
consumption and stronger environmental requirements for such technology. This is expected to lead
to lower emission of greenhouse gasses, due to the generally lower energy consumption of new
technology and the stricter environmental standards of new technology.
The relevant legislative procedures in the Parliament have been launched.
The legislative proposal amending the Tax Code (Lovforslag nr. L 178) was published on 24 February
2021 in Retsinformation.dk. The proposal contains the investment window, with the same elements
as in the political agreement, as per §1, third indent. This legislative proposal amending the Tax Code
is therefore the appropriate and relevant legislative procedure since it includes the investment
window in the Tax Code. Thereby the political agreement on the green tax reform including the
investment window has formed the basis for launching the relevant legislative procedures in the
Parliament.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 32

Related Measure: C4.I1. Investment window
Name of the Milestone: The bill on the green tax reform including the investment window is
adopted by the Danish parliament and the initiative enters into force.
Qualitative Indicator: The law on the green tax reform including the
Time: Q2 2021
investment window is adopted and enters into force.
Context:
The measure aims at establishing an investment window for business investment. Investments
within this investment window will benefit from a tax rebate, implying an economic incentive for
such investments. The measure is part of the green tax reform, of which the investment window is
an integral part, to foster economic activity in the short-term leading to reduced greenhouse gas
emissions in the longer term.
Milestone 32 consists in the adoption and entry into force of the investment window legislation.
Milestone 32 is the second milestone of the investment, and it follows the completion of milestone
31 related to the signature and publication of a political agreement on the green tax reform, which
is also part of the first payment request. It will be followed by target 33, related to 1000 businesses
having benefitted from the depreciation rules under the investment window. The investment has a
final expected date for implementation in Q2 2024.

31

Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive
elements) was satisfactorily fulfilled.
ii.
Government Law No 672of 19 April 2021 (L 178 of 19/4/2021 named Act amending the
Depreciation Act, the Tax Assessment Act, the Pension Return Tax Act and the Sulphur Tax
Act (Lov om ændring af afskrivningsloven, ligningsloven, pensionsafkastbeskatningsloven
lov om afgift af svovl) published in the Danish official online Journal Retsinformation.dk. The
link can be found here: https://www.retsinformation.dk/eli/ft/202013L00178
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all
constitutive elements of the milestone.
The bill has been adopted by the Danish Parliament and entered into force in April 2021.
The law on the green tax reform (2020-21 L 178) was adopted by the Danish Parliament on 19 April
2021. §5, third indent of the law indicates that the provisions of the law with respect to the
investment window took effect as of 23 November 2020. §5, first indent, indicates that the law
entered into force on 21 April, the day after its publication on 20 April 2021.
§1, third indent, includes a new provision to be inserted in §5 D of the Danish law on depreciation
(Afskrivningsloven, LBK nr. 1147, of 29 August 2016). §5 D, first indent, contains a reference
indicating that the taxpayer may choose to write off expenses for the acquisition of new operating
assets, which are used exclusively for business purposes, on a separate balance, where the
acquisition sum is stipulated at 116 per cent. The acquisition of new technology through investments
benefitting from the economic incentives of the investment window can be expected to provide
positive climate and environmental effects, due to generally cleaner technology of modern
equipment, including lower energy consumption and stronger environmental requirements for such
technology. This is expected to lead to lower emission of greenhouse gasses, due to the generally
lower energy consumption of new technology and the stricter environmental standards of new
technology.
The investment window is effective as from 23 November 2020.
§5, fourth indent of the law 2020/I LSV 178, indicates that the investment window is effective as
from 23 November 2020. The temporary increase from 100% to 116% of tax depreciation ends
ultimo 2022 as per §1 in the law.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 34

Related Measure: C.4 I2. Green tax reform – accelerated depreciation
Name of the Milestone: A political agreement on an accelerated depreciation has been adopted by
the Danish Parliament and the relevant legislative procedures in the Parliament have been launched
Qualitative Indicator: The political agreement on the green tax reform including
the accelerated depreciation is signed and published on the Ministry of
Time: Q4 2020
Taxation’s webpage.
Context:
The measure aims to establish an accelerated depreciation for business investment. Investments
within this accelerated depreciation will benefit from immediate (as opposed to four yearlong)
32

depreciation, implying an economic incentive for such investments. It is the objective of the green tax
reform, of which the accelerated depreciation is an integral part, to foster economic activity in the
short-term leading to reduced greenhouse gas emissions in the longer term.
Milestone 34 requires the Danish Parliament to adopt a political agreement on an accelerated
depreciation and to launch the relevant legislative procedure. The political agreement constitutes a
political commitment for the concerned political parties to support a given political initiative. On this
basis the legislative procedures are launched.
Milestone 34 is the first step of the implementation of the investment, and it will be followed by
milestone 35 and target 36, related to the adoption of the legislation and its entering into force and
to 1 000 companies having used the tax deduction provided by the accelerated depreciation,
respectively. The investment has a final expected date for implementation in Q2 2024.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including the constitutive elements)
was satisfactorily fulfilled.
ii.
Political agreement on green tax reform of 8 December 2020 (Aftale om Grøn skattereform)
and link, as published on 8 December 2020 on the website of the Ministry of Taxation. Link:
https://www.skm.dk/aktuelt/presse-nyheder/pressemeddelelser/bred-aftale-skattereformkickstarter-groen-omstilling/
iii.
The Ministry of Taxation links to the agreement from the initial publication on the Ministry of
Finance website: https://fm.dk/nyheder/nyhedsarkiv/2020/december/bred-aftale-omgroen-skattereform-baner-vej-for-groen-omstilling-i-erhvervslivet/
The authorities also provided:
i.
The legislative proposal on the green tax reform (Draft Law No. L 178, Proposal to Act
amending the Depreciation Act, the Tax Assessment Act; the Pension Return Tax Act and the
Sulphur Tax Act) amending the Tax Code, (Lovforslag nr L 178) (Forslag til Lov om ændring af
afskrivningsloven, ligningsloven, pensionsafkastbeskatningsloven og lov om afgift af svovl),
published on 24 February 2021 in the online Danish Official Journal Retsinformation.dk. The
link can be found: https://www.retsinformaton.dk/eli/ft/202012L00178
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
A majority of the Danish Parliament has entered an agreement on the green tax reform including
the accelerated depreciation.
On 8 December 2020 a political agreement on the green tax reform was reached. On page 4, paragraph
5, fifth point of the political agreement, it is stipulated that the agreement includes an accelerated
depreciation element. The political agreement was reached by a broad majority in the Danish
Parliament, thereby ensuring that the agreement should hold also in case of a change in the political
majority. As indicated in the title of the agreement, it was agreed by a broad majority of the political
parties in the Danish Parliament - Social Democratic Party (Socialdemokratiet) (the ruling party at the
time), as well as the parties Liberal Party (Venstre), Social Liberal Party (Radikale Venstre), Socialist
People's Party (Socialistisk Folkeparti) and The Conservative People's Party (Det Konservative
Folkeparti). At the time of the agreement these parties represented 130 out of 179 seats in the Danish
Parliament.
The Council Implementing Decision states that the political agreement should be signed. In accordance
with Danish parliamentary procedures, political agreements are not signed. They are agreements
33

amongst legislative coalitions obliging the parties to vote in favour of the agreed law or legislative
package in Folketinget and give all parties in the coalition community a veto right in relationship to
amendments to the consensual legislation. Nonetheless, the agreement of the political parties is
evidenced by the publication of the document and the presence of the respective parties on the first
page of the agreement. On this basis, it is considered that this constitutive element of the milestone
is satisfactorily fulfilled. The qualitative indicator of the milestone requires that the agreement is
signed and published on the Ministry of Taxation webpage.
Furthermore, in line with the description of the measure, the initiative shall deliver on the
recommendations to Denmark in the National Energy and Climate Plan to frontload investments in a
green and digital transition, and by ensuring a just transition for the most affected companies with the
implementation of a green tax reform. The initiative delivers on the recommendations in the National
Energy and Climate Plan to frontload investments supporting the green and digital transition through
creating an economic incentive for business investments with immediate full depreciation as opposed
to the general rule of depreciation over four years (page four, fifth paragraph, fifth bullet point of the
political agreement). Furthermore, the initiative contributes to ensuring a just transition for the most
affected companies by alleviating the financial burden of investments as the ceiling for benefitting
from immediate full depreciation is raised from DKK 14 100 to DKK 30 000 (the lower financial burden
in terms of tax expenditures is presented on page five, third paragraph of the political agreement).
Furthermore, in line with the description of the measure, an increase in the threshold is expected to
work as a short-term stimulus initiative, as it generates additional liquidity for firms in the initial years
(where all investments below DKK 30 000 are depreciated at 100 per cent) but the stimulating effect
declines over time as future depreciations are reduced to zero.
Furthermore, in line with the description of the measure, after 31 December 2025, the increased limit
may result in fiscal losses for Denmark. These losses shall be covered by reducing the overall budget
for fiscal expenditures. After the end of the investment in the Recovery and Resilience Plan, the
accelerated depreciation is likely to imply a permanent loss of tax revenue for Denmark, as the total
value of business investments benefitting from immediate deprecation as opposed to depreciation
over four years will be permanently higher. These losses are reflected in page six, table one, of the
legislative proposal amending the Tax Code (Lovforslag nr. L 178), which refers to a “permanent” tax
expenditures of 70 million DKK annually after 2025. The coverage of those losses after 2025 will be
ensured by the Danish authorities, outside of the scope of the Recovery and Resilience Plan.
Furthermore, in line with the description of the measure, an increase in the threshold is expected to
strengthen the incentive to invest in information and communications technology and is expected to
help strengthen liquidity among companies that earn profits. Investment in information and
communications technology is facilitated by the increase in the ceiling for immediate deprecation from
previously DKK 14 100 to DKK 30 000. The initiative constitutes an economic incentive since the benefit
from tax deduction can be achieved immediately rather than over four years.
The relevant legislative procedures in the Parliament have been launched.
The legislative proposal amending the Tax Code (Lovforslag nr. L 178) was published on 24 February
2021 in Retsinformation.dk. The proposal contains the accelerated depreciation, with the same
elements as the political agreement as per §1 fourth indent. This legislative proposal amending the
Tax Code is therefore the appropriate and relevant legislative procedure since it includes the
accelerated depreciation in the Tax Code. Thereby the political agreement on the green tax reform
including the accelerated depreciation has formed the basis for launching the relevant legislative
procedures in the Parliament.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 35

Related Measure: C4.I2. Accelerated depreciation
34

Name of the Milestone: The bill on the green tax reform including the accelerated depreciation is
adopted by the Danish parliament and the initiative enters into force
Qualitative Indicator: The law on the green tax reform including the accelerated
Time: Q2 2021
depreciation is adopted and enters into force.
Context:
The measure aims to establish an accelerated depreciation for business investment. Investments
within this accelerated depreciation will benefit from immediate (as opposed to four yearlong)
depreciation, implying an economic incentive for such investments. It is the objective of the green tax
reform, of which the accelerated depreciation is an integral part, to foster economic activity in the
short-term leading to reduced greenhouse gas emissions in the longer term.
Milestone 35 requires the Danish Parliament to adopt the bill on the green tax reform including the
accelerated depreciation and for the law to enter into force.
Milestone 35 is the second step of the implementation of the investment. It is preceded by milestone
34 requiring the Danish Parliament to reach a political agreement on the green tax reform, including
the accelerated depreciation and the start of the legislative process. Milestone 35 will be followed by
target 36, requiring 1 000 companies having used the tax deduction provided by the accelerated
depreciation. The investment has a final expected date for implementation in Q2 2024.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including the constitutive elements)
was satisfactorily fulfilled.
ii.
Government Law No 672 of 13 April 2021 (L 178 of 19/4/2021 named Act amending the
Depreciation Act, the Tax Assessment Act, the Pension Return Tax Act and the Sulphur Tax Act
(Lov om ændring af afskrivningsloven, ligningsloven, pensionsafkastbeskatningsloven og lov
om afgift af svovl)) published in the Danish official online Journal Retsinformation.dk. The link
can be found here: https://www.retsinformation.dk/eli/ft/202013L00178.
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
The Danish parliament shall adopt in April 2021 the bill on the green tax reform, including the
accelerated depreciation.
The law on the green tax reform, L178 2020-21 was adopted by the Danish Parliament on 19 April
2021. §5, third indent of the law indicates that the provisions of the law with respect to the accelerated
depreciation took effect as of 23 November 2020 (§5, third indent). As per §5, first indent, indicates
that the law itself entered into force on 21 April, the day after its publication on 20 April 2021.
The accelerated depreciation shall be applicable to assets purchased on or after 23 November 2020.
§5 third indent of the law on the green tax reform (L178 2020-21) indicates that the provisions of the
law with respect to the accelerated depreciation took (retroactively) effect as of 23 November 2020.
§1 section three fourth point stipulates that the law includes an accelerated depreciation element.
Immediate depreciation implies that businesses undertaking investments with a value of up to DKK 30
000 can write these investments off immediately rather than over four years, as per the normal rules
for tax depreciation of business investments. This constitutes that the maximum ceiling for the 100%
immediate tax depreciation is raised to DKK 30 000.
The change in the maximum ceiling for 100% immediate tax depreciation consists in a permanent
increase in the ceiling for immediate full tax depreciation to DKK 26 300 from previously DKK 12 700.
The difference in the amount for the ceiling between the political agreement of 8 December 2020 (DKK
30 000) and the law on the green tax reform (DKK 26 200) is due to the political agreement being
35

expressed in 2020 price levels (as the political agreement was reached in 2020) while the legislation,
in accordance with normal Danish legislative praxis, is expressed in 2010 price levels (see page 2 and
footnote 1 of the summary document).
The Depreciation Act, the Tax Assessment Act, the Pension Return Tax Act and the Sulphur Tax Act are
existing laws being amended by the new law. The existing laws are expressed in 2010 prices, hence
the law amending the existing legislation is currently normally expressed in 2010 prices.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 38

Related Measure: C4.R2 Emission taxes on industries
Name of the Milestone: A political agreement on an increase in the emissions tax on industry has
been adopted by the Danish parliament.
Qualitative Indicator: The political agreement on the green tax reform
including the increased emissions tax on industry is signed and published on the Time: Q4 2021
Ministry of Taxation's webpage.
Context:
The objective of this measure is to increase the emissions tax in Denmark for all industries equally, as
part of the wider green tax reform (component 4 of the Danish Recovery and Resilience Plan), in order
to provide cost efficient reductions in greenhouse gases emissions. To this end, this measure increases
the process energy tax on fossil fuels for industry by DKK 6/GJ, corresponding to approximately 100
DKK/ton CO2.
Milestone 38 consists of a political agreement on an increase in the emissions tax on industry adopted
by a majority of the Danish parliament.
Milestone 38 is the first step of the implementation of this reform. It will be followed by milestones
39 and 40, which consist of the adoption of the bill for green tax reform excluding agriculture and
mineral process and its entry into force for all industries, respectively. The reform has a final expected
date for implementation in Q1 2025.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including the constitutive elements)
was satisfactorily fulfilled.
ii.
Political agreement on green tax reform, as published on 8 December 2020 on the website of
the
Ministry
of
Taxation.
Link:
https://www.skm.dk/aktuelt/pressenyheder/pressemeddelelser/bred-aftale-skattereform-kickstarter-groen-omstilling/
The
Ministry of Taxation links to the agreement from the initial publication of in the Ministry of
Finance website: https://fm.dk/nyheder/nyhedsarkiv/2020/december/bred-aftale-omgroen-skattereform-baner-vej-for-groen-omstilling-i-erhvervslivet/
The authorities also provided:
i. The legislative proposal on the increase of the energy tax on fossil fuels for businesses, Draft
Law No. L 8 – 2022-2023 (1st session): Proposal for an Act amending the Act on the taxation of
natural gas and city gas, etc., the Act on the taxation of hard coal, lignite and coke, etc., the
Act on the energy tax on petroleum products, etc., the Act on the taxation of pesticides and
various other acts (L 8 – 2022-2023 (1. Samling): Forslag til lov om ændring af lov om afgift af
naturgas og bygas m.v., lov om afgift af stenkul, brunkul og koks m.v., lov om energiafgift af
mineralolieprodukter m.v., lov om afgift af bekæmpelsesmidler og forskellige andre love), as
presented to the Danish Parliament (Folketing) on 5 October 2022 and published on the
36

Danish Parliament (Folketing) website:
https://www.ft.dk/samling/20221/lovforslag/L8/som_fremsat.htm#
ii. The legislative proposal on the increase of the energy tax on fossil fuels for businesses, Draft
Law No L 15 – 2022-2023 (2nd session): Proposal for an Act amending the Act on the taxation
of natural gas and city gas, etc., the Act on the taxation of hard coal, lignite and coke, etc., the
Act on the energy tax on petroleum products, etc., the Act on the taxation of pesticides and
various other acts (Lovforslag No L 15 – 2022-2023 (2. Samling) Forslag til lov om ændring af
lov om afgift af naturgas og bygas m.v., lov om afgift af stenkul, brunkul og koks m.v., lov om
energiafgift af mineralolieprodukter m.v., lov om afgift af bekæmpelsesmidler og forskellige
andre love), as presented to the Danish Parliament (Folketing) on 25 January 2023 and
published on the Danish Parliament (Folketing) website:
https://www.ft.dk/samling/20222/lovforslag/L15/som_fremsat.htm
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
A majority of the Danish Parliament has entered an agreement on the green tax reform.
On 8 December 2020 a political agreement on the green tax reform was reached. The political
agreement on the green tax reform, including the increase in the emissions tax, has been reached by
a broad majority in the Danish Parliament, thereby ensuring that the agreement should hold also in
case of a change in the political majority. As indicated in the title of the agreement, it was agreed by a
broad majority of the political parties in the Danish Parliament - Social Democratic Party
(Socialdemokratiet) (the ruling party at the time), as well as the parties Liberal Party (Venstre), Social
Liberal Party (Radikale Venstre), Socialist People's Party (Socialistisk Folkeparti) and The Conservative
People's Party (Det Konservative Folkeparti). At the time of the agreement, these parties represented
130 out of 179 seats in the Danish Parliament.
The Council Implementing Decision states that the political agreement should be signed. In
accordance with Danish parliamentary procedures, political agreements are not signed. They are
agreements amongst legislative coalitions obliging the parties to vote in favour of the agreed law or
legislative package in Folketing and give all parties in the conciliation community a veto right in
relationship to amendments to the consensual legislation. Nonetheless, the agreement of the political
parties is evidenced by the publication of the document and the presence of the respective parties on
the first page of the agreement. On this basis, it is considered that this constitutive element of the
milestone is satisfactorily fulfilled. The qualitative indicator of the milestone also requires that the
agreement is published on the Ministry of Taxation webpage. The Ministry of Taxation on its website
links to the political agreement as published on the website of the Ministry of Finance.
The agreement on the green tax reform includes the increased emissions tax on industry.
Page 2 of the political agreement of 8 December 2020 on the green tax reform sets out the increase
in the process energy tax on fossil fuels for industry. The political agreement states that the
Government and the parties to the agreement agree to increase the energy tax on fossil fuels for
businesses by DKK 6 per GJ. Furthermore, in line with the description of the measure, the measure
shall raise the fossil energy taxation for all industries equally. As described in paragraphs 5 and 6 on
page 2 of the Political agreement, the tax reform aims to introduce a higher and more uniform tax on
CO2 emissions. By 2025, the same increase in the energy tax for businesses would be phased in for all
industries, including mineralogical processes and agriculture.
The relevant legislative procedures in the Parliament have been launched.
As described on page 6 of the political agreement, it has been reached by a majority of the Danish
parliament, with the obligation for the parties to vote for law proposals and the legal basis for the
financing necessary to implement the agreement. The legislative proposal No L 8 – 2022-2023 (1st
37

session), which concerns the increase of the energy tax on fossil fuels for businesses following the
political agreement on the green tax reform on 8 December 2020, was presented to the Danish
Parliament on 5 October 2022 by the Ministry of Taxation. Due to the early elections announced on
the same day, the discussions on the legislative proposal were postponed and the proposal lapsed.
Following the formation of a new government on 13 December 2022, the legislative proposal was
reintroduced. The legislative proposal No L 15 – 2022-2023 (2nd session), which concerns the increase
of the energy tax on fossil fuels for businesses following the political agreement on the green tax
reform of 8 December 2020, was presented to the Danish Parliament on 25 January 2023 by the
Ministry of Taxation. On this basis, the relevant procedures in the Parliament can be considered
launched.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 41

Related Measure: C5.R1 Re-prioritisation of the registration tax of vehicles and
low electricity tax on charging electric vehicles

Name of the Milestone: Entry into force of legal act to re-prioritise the registration tax of vehicles
and low electricity tax on charging electric vehicles
Qualitative Indicator: The legal act enters into force

Time: Q1 2021

Context:
The measure aims to incentivise more consumers to choose zero and low-emission cars. The tax on
electricity for zero and low-emission vehicles shall be lowered. The reform is part of a set of
measures related to lowering registration tax for low emission vehicles and scrappage schemes for
diesel cars.
Milestone 41 concerns the entry into force of the legal act to reduce the registration tax for lowand zero-emission cars, simplify the registration tax to make it dependent only on the car’s value
and CO2 emissions, and extend the special scheme with low electricity tax to charge electric cars
Milestone 41 is the first step of the implementation of the reform. It will be followed by target 43,
related to the number of zero- and low emission cars in the Danish car stock. The reform has a final
expected date for implementation in Q4 2025.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive
elements) was satisfactorily fulfilled.
ii.
Legislative Act No. 203 of 13 February 2021 (LOV nr. 203 af 13/02/2021) - Act amending the
Registration Tax Act (LOV nr. 228 af 11/03/2020), the Fuel Consumption Tax Act, the Tax
Assessment Act and various other Acts (Lov om ændring af registreringsafgiftsloven,
brændstofforbrugsafgiftsloven, ligningsloven og forskellige andre love). The legislative act
was published in the Danish official online Journal Retsinformation.dk. The link can be found
here: https://www.retsinformation.dk/eli/lta/2021/203
Analysis:
The Commission considers that there is a clerical error in the text of the Council Implementing
Decision Annex as regards the description of this measure in reference to the sentence “This first
subset of measures shall also include a premium for scrapping old diesel cars in order to ensure that
older cars are rapidly changed into new and less polluting cars”. Such description should have been
included further up on the same page of the Council Implementing Decision Annex, namely at the
end of paragraph 3 on page 32, in the text related to the description of the overall component. The
38

erroneous nature of the current positioning of this sentence is evident from its reference to “this
sub-set of measures”, as the single measure at hand (‘Reform 1’) does not constitute a ‘subset of
measures’; the true subset is defined in paragraph 2 and 3 on page 32 of the Council Implementing
Decision Annex and includes both reform 1 and investment 1 of component 5. As further evidence,
pages 139 and 141 of the national Recovery and Resilience Plan submitted by Denmark clearly makes
the difference between these two measures. As explained above, the complementary requirement
of investment 1 is relevant only for milestone 42, which specifically relates to the scrapping scheme
for diesel cars, due for the second payment request, and therefore will not be checked under
milestone 41.
The justification and substantiating evidence provided by the Danish authorities covers all
constitutive elements of the milestone.
The milestone shall be reached when the legal act to reduce the registration tax for low- and zeroemission cars:
First, section 5b of the amended legislative act No. 228 describes the changes made to the
registration tax for zero-emissions cars. It describes that cars emitting 0 grams CO2 pr. km will pay a
reduced registration tax. From 18 December 2020 until 31 December 2025, the registration tax will
be reduced to 40 per cent of the full tax. After 2025, this share of 40 per cent will increase with eight
percentage points each year until 2030, where the registration tax for zero-emissions cars will be
reduced to 80 per cent of the full tax. It follows from revised section 5b, paragraph 2, that zeroemissions car receive a deduction in the full tax of 170 000 DKK in 2021, which is gradually reduced
until 2030, where it amounts to 137 000 DKK.
Second, the registration tax for low-emissions cars follows from section 5c of the amended
legislative act No. 228 and describes that cars that emit more than 0 grams CO2 pr. km but under 50
g CO2 pr. km, pay a reduced registration tax. From 18 December 2020 until 31 December 2021, the
registration tax will be reduced to 45 per cent of the full tax. The share of 45 per cent will increase
each year and until 2030, where it will amount to 80 per cent. It follows from section 5c, paragraph
2, of the amended legislative act No. 228 that low-emissions car receive a deduction in the full tax
of 50 000 DKK in 2021, which is gradually reduced until 2030, where it amounts to 35 000 DKK.
Simplify the registration tax to make it dependent only on the car’s value and CO2 emissions:
Section 1 of the amended legislative act No. 228 describes the changes made to the registration tax,
which entered into force for cars registered after 18 December 2020. Before the amended legislative
act entered into force, the registration tax was dependent on the car’s value, safety equipment and
fuel economy, which in total entailed a more complex tax structure. Section 4 (1) (1) of the amended
legislative act No. 228 describes the changes made to the part of the tax that is dependent on the
cars value. A new paragraph 2 is introduced and describes that a supplementary charge should now
be calculated only based on how many grams of CO2 per km the car emits. While in the past the tax
was dependent on the car’s value, safety equipment and fuel economy, it is now dependent only on
the car’s value and CO2 emissions.
Extend the special scheme with low electricity tax to charge electric cars:
Section 8(4) of the amended legislative act No. 228 describes that the current special scheme with
low electricity tax on electricity used to charge electric cars is extended until 1 January 2031. Before
the entry into force of the Legislative Act No 203, the scheme would have expired on 1 January 2022.
Enters into force:
39

The legislative act No. 203, amending the Registration Tax Act (LOV nr. 228 af 11/03/2020), the Fuel
Consumption Tax Act, the Tax Assessment Act and various other Acts, was adopted by the Danish
government on 9 February 2021. It entered into force on 13 February 2021, which corresponds to
the date of publication in the Danish Official Gazette (paragraph 1 of section 9). The act was
published in Retsinformation. Section 9 paragraph 4 the act No. 203 of 13 February 2021 indicates
that certain sections of the act are subject to different dates of entry into force:






Paragraph 2 indicates the sections and sub-sections that entered into force on 1 June 2021;
Paragraph 3 indicates the sections and sub-sections that apply to the individual vehicle from
the first tax period starting on or after 1 January 2021;
Paragraph 4 indicates the sections and sub-sections that entered into force on 18 December
2020; subject to paragraphs 9 to 11;
Paragraph 5 indicates the sections and sub-sections that entered into force as from the 2021
financial year;
Paragraph 6 indicates the sections and sub-sections that entered into force on 1 July 2021.

Furthermore, in line with the description of the measure, this reform shall be part of the set of
measures related to lower registration tax for low emission vehicles and scrappage schemes for
diesel cars. The scrappage scheme for diesel cars is a complementary measure to the measure
related to lower registration tax. It relates to a different measure and will be fulfilled by a different
milestone (milestone 42), due for the second payment request, and therefore will not be assessed
under this milestone. Together the two measures (reform 1 and investment 1 of component 5 in the
Council Implementing Decision Annex) form the first sub-set of measures of component 5 that are
referred to on page 32 of the Council Implementing Decision Annex.
Furthermore, in line with the description of the measure, the tax on electricity for zero and lowemission vehicles shall be lowered. First, section 5b of the amended legislative act No. 228 describes
that cars emitting 0 grams CO2 pr. km will pay a reduced registration tax. From 18 December 2020
until 31 December 2025, the registration tax will be reduced to 40 per cent of the full tax. After 2025,
this share of 40 per cent will increase with eight percentage points each year until 2030, where the
registration tax for zero-emissions cars will be reduced to 80 per cent of the full tax. It follows from
revised section 5b, paragraph 2, that zero-emissions car receive a deduction in the full tax of 170
000 DKK in 2021, which is gradually reduced until 2030, where it amounts to 137 000 DKK.
Second, the registration tax for low-emissions cars follows from section 5c of the amended
legislative act No. 228 and describes that cars that emit more than 0 grams CO2 pr. km but under 50
g CO2 pr. km, pay a reduced registration tax. From 18 December 2020 until 31 December 2021, the
registration tax will be reduced to 45 per cent of the full tax. The share of 45 per cent will increase
each year and will in 2030, where it will amount to 80 per cent. It follows from section 5c, paragraph
2, of the amended legislative act No. 228 that low-emissions car receive a deduction in the full tax
of 50 000 DKK in 2021, which is gradually reduced until 2030, where it amounts to 35 000 DKK.
Against this background, the justification and substantiating evidence provided by the Danish
authorities cover all constitutive elements of the milestone.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 44

Related Measure: C5.I2 Development test of road-pricing
40

Name of the Milestone: Political agreement has been adopted by the government and a majority
of the parliament on the conduction of the test scheme
Qualitative Indicator: Agreement reached between the government and a majority of the
parliament on the conduction of the test scheme.
Context:
The measure on the development test of road pricing aims to provide an overall evaluation of roadpricing options, understood as the application of vehicle-based tolls, both in terms of technology,
system costs, practicability, user behaviour and user under-standing of the system, as well as socioeconomic and distributional effects. The project management and dissemination of results is
expected to be assigned to a university with scientific knowledge in the area of transport economics.
This investment is part of a series of studies and tests will be executed in order to accelerate the
decarbonisation of roads (promotion of car-pooling, test-scheme for heavy haulage transportation,
optimization of road pricing).
Milestone 44 concerns the political agreement to be reached on the description of the test-scheme
and the organisation of the test. The objective of the political agreement is to initiate development
tests of road pricing in order to explore efficient ways of taxing congestion and the damage and
health costs associated with driving.
Milestone 44 is the first step of the implementation of the investment. It will be followed by
milestone 45, related to the publication of the results of the test. The investment has a final
expected date for finalisation in Q1 2024.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive
elements) was satisfactorily fulfilled.
ii.
Political agreement on Green transition of road transport of 4 December 2020 between
the Government, Social Liberal Party; the Socialist People’s Party and the Unity Party, on the
conduction of the road pricing test scheme (Aftale mellem regeringen, Radikale Venstre,
Socialistisk Folkeparti og Enhedslisten om: Grøn omstilling af vejtransporten), with a
majority of 91 votes out of 179. Link to the website of the Danish Ministry of Finance where
the agreement is published: https://fm.dk/nyheder/nyhedsarkiv/2020/december/groenvejtransportaftale-massiv-co2-reduktion-og-ambition-om-1-mio-groenne-biler-i-2030/
The authorities also provided:
i.
Letter of approval of 1 July 2022 concerning the project “test development of road pricing
for passenger cars” for road pricing test scheme specifying how the test will be administered
(Bevillingsskrivelse vedr. projektet “Udvik-lingsforsøg med roadpricing for personbiler”). The
letter was issued on 1 July 2022 by the Ministry of Transport and addressed to “Danmarks
Tekniske Universitet” (DTU).
ii.
A document including the Description and organization for road pricing test scheme of 1
July 2022 drafted by Danish Technical University (DTU) “Danmarks Tekniske Universitet” in
cooperation with “Sund og baelt” (SB).
Analysis:
The Council Implementing Decision states that a “political agreement shall be reached on the
description of the test-scheme and the organisation of the test. In this regard, the objective of the
41

agreement shall be to initiate development tests of road pricing in order to explore efficient ways of
taxing congestion and the damage and health costs associated with driving. No further legal basis
shall be needed to initiate the test scheme.” The political agreement on Green transition of road
transport was adopted by the government and the parliament, with a majority of 91 votes out of
179 on 4 December 2020. On the basis of this agreement, the Danish Technical University (DTU)
drafted a technical document including the ‘Description and organization for road pricing test
scheme’, which sets forth the requirements from the Council Implementing Decision. The political
agreement of 4 December 2020 only established that the scheme shall take the form of a publicprivate cooperation, without including any specifications regarding the description of the testscheme nor the organisation of the test. To this end, the technical document drafted on the basis of
the political agreement establishes that the scheme shall take the form of a public-private
cooperation and describes the test-scheme and the organisation of the test, in line with the
requirements of the Council Implementing Decision. Thus, the content of the technical document
on the ‘Description and organization for road pricing test scheme’ is evidence that the political
agreement was followed in drafting the technical document. Additionally, the letter of approval of
1 July 2022 concerning the project “test development of road pricing for passenger cars”
demonstrates that the project has started and that the Government, the Social Liberal Party, the
Socialist People’s Party and the Unity Party have not objected to the implementation of the political
agreement through this project and on the basis of the technical document developed by the Danish
Technical University. On this basis, it is considered that this constitutive element of the milestone is
satisfactorily fulfilled.
The political agreement shall be reached on the description of the test-scheme.
The Council Implementing Decision required that the political agreement shall be reached on the
description of the test-scheme.
As indicated in the title of the agreement, the Agreement was agreed by a broad majority of the
political parties in the Danish Parliament - Social Democratic Party (Socialdemokratiet) (the ruling
party at the time), as well as the parties, Social Liberal Party (Radikale Venstre), Socialist People's
Party (Socialistisk Folkeparti) and the Unity Party (Enhedslisten). At the time of the agreement, these
parties represented 91 out of 179 seats in the Danish Parliament. The Agreement reached is
formalised
by
its
publication
that
took
place
on
4
December
2020
(https://fm.dk/nyheder/nyhedsarkiv/2020/december/groen-vejtransportaftale-massiv-co2reduktion-og-ambition-om-1-mio-groenne-biler-i-2030/)
The Agreement of 4 December 2020 describes that it is the government and the supporting parties
behind the political agreement’s intention to introduce a road pricing system based on tolls for
passenger cars (page 6). This Agreement describes that the test-scheme shall consist in assessing
the administrative challenges associated with taxing congestion and the damage and health costs
associated with driving, and that the scheme would take the form of a public-private development
cooperation to assess these challenges.
Agreement reached between the government and a majority of the parliament on the
organisation of the test
Pages 6-18 of the ‘Description and organization for road pricing test scheme’ provides information
on the organisation contemplated for the test. Page 9 refers that the organization will take the form
of a cooperation between the public and private sector. Secondly, the letter of approval of 1 July
2022 for road pricing test scheme shows that the tests will be administrated by “Danmarks Tekniske
Universitet” (DTU), a Danish university with experience in transport economics, in cooperation with
“Sund og baelt” (SB), a state-owned company with experience in transport links. Thirdly, page 1 of
the ‘Description and organization for road pricing test scheme’, under section ‘Purpose and
principles of the development study’ explains that a representative group of test subjects
(approximately 2 000 - 2 500) will be chosen to conduct testing periods, where the movement of
42

their car is tracked. During test periods the test person will be acting based on different driving
centred fee structures. Each test subject will test two different fee structures during the time of the
experiment. Fourthly, page 16 of the ‘Description and organization for road pricing test scheme’,
under section ‘Project team and organisation’, also mentions that the test scheme will be performed
by DTU and SB. DTU will be responsible for the analytical parts of the test scheme while SB will hold
responsibility for design and actualisation of the project. The project is monitored by an external
party in the form of Mogens Fosgerau from Copenhagen University, the leading professor in the
field of transport economics (page 17). Finally, as page 17 of the ‘Description and organization for
road pricing test scheme’ describes, the project will be followed by a follow up group made up of
public servants and a follow up group consisting of the government and the parties behind the
political agreement.
The objective of the agreement shall be to initiate development tests of road pricing in order to
explore efficient ways of taxing congestion.
Page 1 of the ‘Description and organization for road pricing test scheme’, describes that the purpose
of the road price test scheme is to evaluate the option of using road pricing in regard to the most
appropriate tolling technologies, their associated costs and their feasibility. The scheme is to also
analyse user behaviours based on how roads are priced. Page 1 further specifies that during test
periods the test persons will be acting based on different driving fee structures. Each test person
will test two different fee structures during the time of the experiment.
The objective of the agreement shall be to initiate development tests of road pricing in order to
explore the damage and health costs associated with driving.
Page 1 of the ‘Description and organization for road pricing test scheme’ document describes that
the purpose of the scheme is to evaluate road pricing options in regard to user behaviour, evaluate
their welfare economic impact and distributional effects. The document explains that test seeks to
address the health risks of congestion, which are predominant in urban areas. Therefore, the test is
to be geographically focused on one or more larger urban areas. The scheme will also allow analysing
the economic impact of road pricing on welfare, as well as its distributional effects on individual
wealth. For instance, the scheme intends to provide indications on how the introduction of a
congestion taxation will impact house prices, in particular in the most congested areas (page 15).
No further legal basis shall be needed to initiate the test scheme.
The political agreement of 4 December 2020 is an agreement involving the government and political
parties represented in the Danish parliament. The Political agreement does not indicate that further
legislation is necessary to initiate the test scheme. The accompanying evidence provided, ‘letter of
approval’ and ‘Description and organization for road pricing test scheme’, exclusively refer to the
political agreement as the only legal basis for implementing the scheme.
Furthermore, in line with the description of the measure, this investment is part of a series of studies
and tests that shall be executed in order to accelerate the decarbonisation of roads. The measure
intends to contribute to the acceleration of the decarbonisation of roads as indicated on page 2 of
the ‘Description and organization for road pricing test scheme’ document. The measure
‘Development test of road-pricing’ consists in analysing options aiming at optimising road pricing.
For instance, page 1 of the ‘Description and organization for road pricing test scheme’ mentions that
the purpose of the road price test scheme is to evaluate the most appropriate tolling technologies
and their associated costs and feasibility. The measure ‘Development test of road-pricing’ is also
part of a political agreement which includes a series of complementary measures also contributing
to the decarbonisation of roads. Some of those measures are addressed by other milestones of the
Danish plan. It is in particular the case of an ‘analysis of pilot double-trailers scheme’ (page 5 of the
political agreement) that consists in a test-scheme for heavy haulage transportation (measure
C5.I4), an ‘analysis of optimisation and adaptation of national weight and size regulation’ (measure
43

C5.I5) (page 5 of the political agreement), ‘car sharing and pooling’ (measure C5.I3) (page 5 of the
political agreement).
Furthermore, in line with the description of the measure, the project management and
dissemination of results is expected to be assigned to a university with scientific knowledge in the
area of transport economics. The ‘Letter of approval’ of 1 July 2022’ specifies that the tests will be
managed by “Danmarks Tekniske Universitet” (DTU), a Danish university with experience in
transport economics, in cooperation with “Sund og baelt” (SB), a state-owned company with
experience in transport links. The ‘Letter of approval’ describes that the dissemination of the results
by DTU will be warranted by a professional report communicated to stakeholders on a semi-annual
basis, and by the submission of a comprehensive technical report and a final project account to the
Ministry of Transport, within three months of the closure of the project. The ‘Description and
organization for road-pricing’ describes that the expertise of DTU is warranted by the DTU project
team (page 16), composed of professor Otto Anker Nielsen and Deputy Head of Senior Science
Ninette Pile-gaard, who both have long experience in analysing road charges and regulating
transport, as well as in evaluating transport projects. Professor Otto Anker Nielsen and Senior
researcher Ninette Pile-gaard were both members of the Commission for the Green Transition of
passenger cars, and Mr. Nielsen has also been a member of, inter alia, the Train Electricity
Commission, the Transport Expert Group of the Minister for Transport for the Future of Transport,
and was project manager for DTU’s part of the former Akta experiment in Copenhagen (Alternative
Driv-ing and Taxes).
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 46

Related Measure: C5.I5. Analysis of the regulation on weight and dimensions to
optimise heavy haulage.

Name of the Milestone: Publication of a report on the analysis of the national regulation on
weight and dimensions
Qualitative Indicator: Publication of report on analysis of the
national regulation and on weight and dimensions, which is
expected to help quantifying potential reductions in emissions.

Time: Q4 2021

Context:
The objective of the measure is to provide an analysis of the potential of lower emissions through
further adjustments of the current regulation on weight and dimension. Besides estimating the
potential reduction in emissions, the analysis will estimate financial consequences for the transport
sector and the society - such as increased wear and tear on roads.
Milestone 46 requires the publishing of a report with an analysis of the current national regulation
on weight and dimensions. This analysis shall result in a final report with recommendations,
including proposals for amendments to the national regulation with estimated climate effects,
description of traffic safety conditions and costs. The proposed actions must be compliant with the
‘Do No Significant Harm’ requirement. Milestone 46 is the only milestone of this investment.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.

Summary document duly justifying how the milestone (including all the constitutive
elements) was satisfactorily fulfilled.
44

ii.

The report of 31 December 2021 on optimization and adaptation of the regulation on
weight and dimensions regarding heavy haulage, including annexes (‘Analyse af optimering
og tilpasning af national vaegt – og dimensionregulering’) prepared by COWI Denmark, a
consultancy, published on the website of the Danish Road Traffic Authority.
Link to the publication: https://fstyr.dk/da/-/media/FSTYR-lister/Publikationer/COWIAnalyse-af-optimering-og-tilpasning-af-national-v%C3%A6gt--ogdimensioneringsregulering.pdf

The authorities also provided:
i.

‘Do No Significant Harm’ checklist provided by the Danish Ministry of Transport dated 9
November 2022.

Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all
constitutive elements of the milestone.
An analysis regarding the current national regulation on weight and dimensions is published:
Pages 53-59 of the report on optimization (meaning the design of a road network that would
minimise wear and tear costs and risk on safety, while maximising the CO2 emission decrease) and
adaptation of the regulation on weight and dimensions regarding heavy haulage provides for an
assessment of the ‘national weight and dimensions regulation’. In line with the description of the
measure, the report provides an analysis concerning the potential of lower emissions through
amendments to the current regulation on weight and dimensions. The analysis also includes
estimates the financial consequences for the transport sector and the society - such as increased
wear and tear on roads.
The analysis includes 24 initiatives, which entail amendments to the existing framework, including
national regulation, on the weight and dimensions of heavy-duty vehicles. These initiatives belong
to four main categories (an overview is provided on page 61 of the report):
Increased total permissible weight of up to one and two tons for alternatively fuelled and
zero-emission vehicles;
ii.
Increased total permissible weight of up to one ton for vehicles with electric equipment
installed;
iii.
Increased total permissible weight for rigid vehicles and trailers;
iv.
Increased total permissible vehicle length for vehicles with electric equipment, cranes or
alternatively fuelled and zero-emission technologies.
The analysis performed by COWI Denmark regarding the current national regulation on weight and
dimensions in Denmark was published on 31 December 2021 on the Danish Road Traffic Authority
website.
i.

The analysis shall be based on existing data:
The report of 31 December 2021 on optimization and adjustment of the regulation on weight and
dimensions regarding heavy haulage uses different datasets of existing data to support the analysis.
This is reflected in the second section, page 24, which references the data from the “land transport
model”, second section page 25 references the Tema2015 dataset, section 3 page 26 states the WIM
dataset and section 8 page 91, includes a reference to the dataset TERESA, used to study the socioeconomic consequences of the proposed actions.
The data used that forms the analysis of the report includes number of vehicles subdivided per gross
weight, the amount of ton-km, which is the transported amount of goods measured in tonnes
multiplied with amount of km per transport. Also, both the parameters which are used to measure
and compare the different initiatives (such as road wear and tear for equivalent 10 tonnes axle),
which is mostly based on data from Statistics Denmark, and data on road bridges and emission45

factors are set by the Danish Energy Agency, as explained on page 2 of the summary document. This
Agency is responsible for tasks linked to energy production, supply and consumption, as well as
Danish efforts to reduce carbon emissions. This shows that all the data used in the analysis existed
beforehand and no new data has been collected for the analysis.
And including a cost-benefit analysis of the potential emissions reductions and of the potential
financial consequences, such as wear and tear on roads:
The report includes a cost-benefit analysis, which provides evidence for reduced emissions for the
individual initiatives. The report concludes (pages 10 and 11 of the report) that all initiatives lead to
a decrease in emissions, and the largest decrease is found with the initiatives which increases the
total permissible vehicle length for vehicles with electric equipment, cranes or alternatively fuelled
and zero-emission technologies. The effects on emissions are defined as significant when using zeroemission technologies. The climate and environmental effects are high when transferring to battery
operation, such as by installing electric equipment on the vehicle (for example cranes) or switching
to zero-emission vehicles. The effects deriving from switching from diesel to zero-emission
technologies are due to less emission per kilometre driven. The effects deriving from allowing higher
weight (for example with installed electric equipment) are caused by vehicles being able to carry
more goods and hence drive fewer kilometres.
The cost benefit analysis in the report also quantifies the potential negative impacts, such as wear
and tear (see below), of technical solutions for increasing weight for four categories of vehicles,
namely: i) low/zero emission vehicles; ii) for vehicles with electric equipment installed; iii) for rigid
vehicle and trailers and, iv) for vehicles with electric equipment, cranes or alternatively fuelled/zero
emission vehicles (pages 12-19 and pages 53-90 of the report). The report (on pages 10 and 11)
includes findings and recommendations related to socioeconomic benefits of the initiatives, notably
when it comes to a) the increase in the weight of the vehicles and the impacts on municipal roads;
b) savings for operators due to the greater flexibility and reduction in kilometres travelled if the
overall weight limits are increased; c) road safety; d) impacts on bridges; and e) environmental and
climate effects.
The report also quantifies the potential financial consequences of the measures on wear and tear
on roads (conclusions on page 9 of the report). For instance, across all analysed initiatives, the
analysis shows a significant additional wear and tear on roads, expected to happen on smaller
municipal roads. The wear and tear are relatively higher when the vehicles are heavier, due to an
increasing impact from the weight on the axels.
The cost of the considered measures is offset by their benefits: the report explains that there are
relatively lower impacts for vehicles when the number of axels is increased. In addition, the costly
risk of breaching weight restrictions for bridges is found to be limited.
Lastly, the analysis explains that operators can save costs from the reduced number of vehicle
kilometres necessary to carry the same amount of goods. The reduction in vehicle kilometres will
also provide mitigation of some of the road wear and tear for transport companies.
The analysis on national regulation on weight and dimensions shall result in a final report with
recommendations, including proposals for amendments to the national regulation with estimated
climate effects, description of traffic safety conditions and costs:
Denmark explained (page 2 of the summary document) that the analysis provided is the final report
referred to in the Council Implementing Decision annex. The summary document also clarifies that
the report provided the Danish Ministry of Transport with an overview of the impact of possible
allowance of higher weight and larger heavy-duty vehicles in Denmark, showing both the positive
consequences and the negative consequences related to the 24 considered initiatives. Estimated
climate effects and road maintenance costs were analysed for each initiative (pages 67-90 of the
report), this also occurred with respect to road safety (pages 46 and 47 of the report).

46

Denmark confirmed that 5 out of the 24 initiatives considered in the report will be used for adapting
the existing framework and for amending the national regulation (page 2 of the summary
document), including four initiatives regarding longer vehicles. They all integrate the impacts on
emissions, wear and tear on road surfaces, bridge carrying capacity limits, road safety (pages 46-47
of the report) and user cost highlighted in the analysis.
Among other, the analysis provided the Ministry and authorities with suggestions to initiate multiple
initiatives regarding possible allowance of higher weight and dimensions for heavy-duty vehicles
from 2025 in relation to a political agreement on kilometre-based road toll for trucks (page 2 of the
summary document).
As a background information, Denmark is considering 11 initiatives, divided in two areas. Seven
initiatives regarding increased gross weight of rigid trucks and road trains, and four initiatives
regarding longer vehicles, without increasing the allowed total length of the load-space. All 11
initiatives will make it possible to carry more goods per transport, and their implementation is
expected to contribute to a reduction in CO2 emissions on approximately 0.1 million tons per year.
Out of these 11 initiatives, 5 initiatives originate from the recommendations of the report.
The report shall propose actions that are compliant with the DNSH requirement:
The ‘Do No Significant Harm’ checklist prepared by the Danish Ministry of Transport shows that the
analysed initiatives are compliant with the DNSH requirement included in the Council Implementing
Decision Annex, and that the recommendations on how to optimize heavy haulage have been
assessed against the DNSH-principle using Annex 1 of the Technical guidance on the application of
“Do No Significant Harm” under the Recovery and Resilience Facility Regulation (2021/C 58/01).
In part one of pages 1 and 2 of the DNSH checklist, neither of the six environmental goals of the
taxonomy is significantly harmed by the analysed recommendations on how to optimize heavy
haulage:
i.

ii.

iii.

iv.

v.

vi.

The recommended actions will contribute to climate change mitigation as they will not lead
to significant greenhouse gas emissions as more efficient trucks and transports would lead
to a decrease in the number of trucks, and thereby lower the emissions per transported tons
of goods. The initiatives could in theory in total reduce the CO2-emissions by approximately
1 million tons in a 15-year period.
The recommended actions will not significantly harm climate change adaptation as the
analysed initiatives regarding alternatively fuelled, zero-emission vehicles and
electrification of vehicles could disincentive the use of fossil fuel combustion. At the same
time, the initiatives do not entail construction of new roads, only higher maintenance cost
of the existing.
The recommended actions will not significantly harm the sustainable use and protection of
water and marine resources as the analysed initiatives encourages the usage of sustainable
road transport and limits the consumption and usage of polluting and emitting vehicles, thus
the initiatives are not expected to have an implication for the good status or the good
ecological potential of bodies of water.
The recommended actions will not significantly harm circular economy, including waste
prevention and recycling as they will not lead to significant inefficiencies in the use of
materials or in the direct or indirect use of natural resources, or increase the generation,
incineration or disposal of waste.
Further, the analysed initiatives will not significantly harm the pollution prevention and
control to air, water or land as they will not lead to a significant decrease in emissions of
pollutants into air, water or land.
Lastly, the recommended actions will not significantly harm the protection and restoration
of biodiversity and ecosystems since they will not lead to significant harm of the good
condition and resilience of ecosystems, or to the conservation status of habitats and species.
Pollutants are strictly regulated in Danish environmental laws and their emissions will not
47

be impacted by the analysed initiatives of optimising the national regulation on weight and
dimensions.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 48

Related Measure: C5.I4. Analysis of test scheme with
double trailers

Name of the Milestone: Publication of an analysis on double trailers analysing road safety, vehicle
engineering, road engineering and environmental conditions.
Qualitative Indicator: Publication of a
report on the findings of the analysis of Time: Q4 2021
test scheme with double trailers.
Context:
The objective of the measure is to carry out an analysis, by the Danish Road Directorate and the
Danish Road Traffic Authority, covering the efficiency of the road design, planning and test rides.
Based on the analysis it must be possible to decide which reconstructions can be carried out in order
to ensure both traffic safety and traffic flow on the certain road network.
Milestone 48 covers the analysis on double trailers, which includes the publication of a report with
final recommendations, including proposals for a pilot road network and estimate of climate effects,
road safety conditions and finances, including investments in rebuilding the road network. The
Council Implementing Decision includes compliance with ‘Do No Significant Harm’ as requirement
for the actions proposed by the report. Milestone 48 is the only milestone of this investment.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive
elements) was satisfactorily fulfilled.
ii.
The report of 22 December 2021 on the findings of the analysis of test scheme with double
trailers (‘Analyse af forsogsordning med dobbelttralere (DUO2)’) issued by the Danish Road
Directorate. It was published on the website of the Danish Ministry of Transport on 22
December 2021. Link to the publication: https://www.trm.dk/nyheder/2021/analyse-afforsoeg-med-ekstra-lange-lastbiler
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all
constitutive elements of the milestone.
The analysis on double trailers shall result in the publication of a report:
The analysis was published in the form of a report on 22 December 2021 on the website of the
Danish Ministry of Transport.
With final recommendations, including proposals for a pilot road network:
Following the political agreement of 4 December 2020 (only referred to on page 7 of the report
which explains the context of the analysis, not submitted by Denmark) on the green transition of
road transport, Denmark has decided to allocate 1 million DKK to allow the Danish Road Traffic
Authority and Danish Road Directorate to carry out an analysis on double trailer in 2021 (page 7 of
the report). The objective of the report is to study the possibility to use double-trailers (so-called
‘DUO2’) on roads in order to reduce CO2 emissions per ton of goods transported.
48

Against this background, the purpose of the report is more precisely to identify an experimental or
pilot road network and to provide recommendations to maintain road safety on this network during
the trial period.
Page 7 of the report indicate that the pilot road network should cover approximately 900 km, divided
into approximately 865 km of motorways, 15 km of other national roads and 25 km of municipal
roads. The area is composed of ten logistic hubs, of which six are located in municipal areas, three
public ports and one on private land. Page 13 of the report indicates in a map the network
recommended for the trial.
Pages 9, 10 and 11 of the report indicate that the trial shall be conducted for a period of 5 years.
The report recommends that the trial shall be performed with a certain type of double trailers, the
‘variant A-double, this is, with a total length of up to 32 meters with the possibility of additional
length of up to 2 meters. The report also recommends that the maximum weight of the double
trailers shall be from 70 to 72 tonnes, depending on the combustion of the engine.
The report proposes that the Danish Road Directorate and the Danish Transport Authority, in
dialogue with industry organizations, the police, etc. prepare an overall status report after the first
and third year of the trial period.
In addition, specific requirements are considered in view of equipping double-trailers with latest
traffic accident control technology and therefore ensuring a sufficient level of road safety (page 8 of
the report). For the trial, the report requires that all double-trailers shall be equipped with an
Emergency Braking System (page 46 of the report), Electronic Stability Control (page 43 of the
report).
On pages 52-53, the report estimates that the authorisation of double-trailers on a limited road
network during the trial period will allow a socio-economic benefit of approximately 300 million
DKK. This socio-economic cost covers the construction/adaptation costs of the roads, the operation
and maintenance costs, to be offset by savings on drivers’ wages and equipment, lower driving costs,
reduced emissions and noise, as well as lower fuel taxes and tolls.
And estimate of climate effects:
Pages 10 and 53 of the report provide an estimate of the climate benefits entailed by the measures
included in the report. The report estimates that such measure would reduce CO2 emissions by 1
500 tonnes by 2026, after full phasing-in. Overall, the reduction could reach 22 000 tonnes over a
period of 15 years. In addition, the socio-economic analysis provided (page 53 of the report)
estimates the reduction of CO2 emission to entail a socio-economic benefit of DKK 6 million and air
pollution an additional 6 million DKK.
The report explains (page 53) the assumptions taken for the calculation of the climate effects of the
initiative. For the calculation of CO2 emission, the report uses assumptions made for the trial of
double-trailers used in Sweden (between Gothenburg and Malmö), with an assumption 1.5 kg of
CO2 per kilometre driven.
In the report (page 55) the assumption is stated that the introduction of double-trailer will also lead
to a shift of freight transport from rail to road, with a negative partial impact on CO2. However, the
report does not provide a quantification of this.
Road safety conditions and finances, including investments in rebuilding the road network:
The report indicates that longer vehicles present challenges in relation to the other traffic and the
design of the road network. Therefore, a test is planned to be conducted in a way that minimises
both the need for road changes and the road safety challenges, in line with the investment
description set out in the Council Implementing Decision.
On page 8 the report indicates at the increased risk of introducing double-trailers for road safety
can be mitigated by restricting their use to roads with the lowest risk of accidents. The report
recommends that concrete and targeted road improvements should be made on the road network.
It explains (page 10) that the use of double trailers will trigger a cost of around 34.5 million DKK
49

needed for road conversion and 1.5 million DKK for the update of traffic counting equipment and IT
development of systems, for the experimental road network.
The report shall propose actions that are compliant with the DNSH requirement:
Denmark explained in pages 2 and 3 of the summary document, that the measures set out in the
recommendations of the report are compliant with the DNSH requirement and the six
environmental objectives.
i.
The measures that form part of the recommendations of the report will contribute to
climate change mitigation. The expected saving of CO2 emissions as a result of the proposed
trial road network are 22 000 tonnes of CO2 for the proposed trial period of 15 years (page
10 of the report). Secondly, the recommended initiatives lead to decreased emissions and
thereby supports climate change mitigation. The proposed initiatives have the potential to
reduce fuel use, increasing fuel efficiency, and significantly reducing greenhouse gas
emissions (page 14 of the report). The report presents options based on the best available
technology for double-trailer trucks (pages 45-46 of the report), given that zero-emission
technology does not apply for double trailers since there is no market for that technology
for
double
trailers
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/690888/IPOL_STU(2021)69
0888_EN.pdf (pages 35-38). This thereby justifies DNSH compliance with the climate change
mitigation objective since the initiative leads to decreased emissions for double-trailer
trucks and would make use of the best-available technologies in the market.
ii.
The measures that form part of the recommendations from the report will not significantly
harm climate change adaptation. They will not lead to the construction of new roads, as the
trial will be made on an existing road network and will therefore not entail the construction
of additional roads. They only apply to existing roads. As mentioned above, the presented
recommendations will furthermore minimize the need for road changes (page 53 of the
report) as they will entail only minimal improvements in the existing network to allow
double trailers to circulate. This thereby justifies DNSH compliance with climate change
adaption objective.
iii.
The measures that form part of the recommendations from the report will not significantly
harm the sustainable use and protection of water and marine resources. The report
encourages the usage of sustainable road transport and limits the usage of polluting and
emitting vehicles. The measures are not expected to have an implication for the use and
protection of water services. This thereby justifies DNSH compliance with the objective on
sustainable use and protection of water and marine resources.
iv.
The measures that form part of the recommendations will not significantly harm circular
economy, including waste prevention and recycling. The report quantifies the potential
reductions in emissions. The measures will not lead to significant inefficiencies in the use of
resources nor to increase the generation of waste, taking into account both the direct and
primary indirect effects across the life cycle, which justifies DNSH compliance with the
circular economy objective, including waste prevention and recycling.
v.
Furthermore, the measures that form part of the recommendations will not significantly
harm pollution prevention and control to air, water or land. The recommendations from the
report would, if enacted, indirectly reduce emissions of pollutants into air, water and land
because the report shows that emissions will be reduced. The socio-economic analysis
provided (page 10 of the report) estimates the reduction of air pollution to entail a socioeconomic benefit of DKK 6 million. This thereby justifies DNSH compliance with the objective
on pollution prevention and control to air, water or land.
vi.
Lastly, the measures that form part of the recommendations will not significantly harm the
protection and restoration of biodiversity and ecosystems. The proposed trial road network
is not located in or near biodiversity-sensitive areas (including the Natura 2000 network of
50

protected areas, UNESCO World Heritage sites and Key Biodiversity Areas, as well as other
protected areas). Pollutants are strictly regulated in Danish environmental laws and their
emissions will not be impacted by the recommendations. This thereby justifies DNSH
compliance for the protection and restoration of biodiversity and ecosystems.
The proposed initiative is thereby compliant with the DNSH requirement from the Council
Implementing Decision.
Furthermore, in line with the description of the measure, an analysis shall be carried out by the
Danish Road Directorate and the Danish Road Traffic Authority. This analysis is part of the report
quoted above, which provides the evidence for the fulfilment of the milestone. It was prepared by
the Danish Road Directorate (page 1 of the report) and the Danish Road Traffic Authority
(Færdselsstyrelsen). The Danish Road Traffic Authority was responsible for the preparation of the
sections of the report relating to regulation, EU legislation and the technical conditions of the double
trailers, while the Danish Road Directorate prepared the overall analysis (such as in relation to the
road network and the options considered for the use of double-trailers) and held meetings with the
organisations involved in road freight transport (page 7) in order to facilitate the preparation of the
report.
Furthermore, in line with the description of the measure, the analysis shall cover the efficiency of
the road design, planning and test rides. On page 10, the report acknowledges that the road network
for double trailers will require a specific road design to allow for an efficient circulation of double
trailers, in particular to facilitate their manoeuvring and parking.
The efficiency of the road design is also reflected by page 8 of the selection of the double-trailer trial
road network, close to the largest areas of transport and logistics, with access to the motorway
network within a range of 5 km.
The report nonetheless highlights that further discussions with municipalities and stakeholders will
have to take place after the publication of the report to ensure the efficiency of the road design
(page 10), in particular regarding the specific improvement works required at local level.
Lastly, on page 10, the report indicates that funds will need to be allocated for an efficient
administration of the scheme that would include implementing solutions to ensure that vehicles use
only the permitted road network.
In terms of planning, on page 10, the report considers that the test rides shall be conducted for a
period of five years.
Furthermore, in line with the description of the measure, based on the analysis it shall be possible
to decide which reconstructions can and shall be carried out in order to ensure both traffic safety
and traffic flow on the certain road network. As indicated above, the report recommends that the
pilot road network should cover approximately 900 km (page 7 of the report) of existing roads,
divided into approximately 865 km of motorways, 15 km of other national roads and 25 km of
municipal roads. The area is composed of ten logistic hubs, of which six are located in municipal
areas, three public ports and one on private land. The network recommended for the trial is shown
page 13 of the report.
In order to ensure both traffic safety and traffic flow, the report recommends that concrete and
targeted road improvements should be made on the road network. It explains (page 10) that the
use of double trailers will trigger a cost of around DKK 34.5 million needed for road conversion and
DKK 1.5 million for the update of traffic counting equipment and IT development of systems, for the
experimental road network.
The traffic flow of the selected road network was taken into consideration (page 8). It will be close
to the largest areas of transport and logistics, and warrant access to the motorway network within
a range of 5 km.
Commission Preliminary Assessment: Satisfactorily fulfilled

51

Number: 49

Related Measure: C5.I8. Subsidy scheme to green ferries

Name of the Milestone: A political agreement has been adopted among a majority of parties in
the Danish Parliament on green transition of ferries.
Qualitative Indicator: The government and parliament reach a political
agreement on the specific green maritime sector which is signed and
published at the relevant ministry’s website.

Time: Q2 2021

Context:
The objective of the measure is to subsidize the purchase of zero or low emission ferries or
retrofitting of existing ferries (15 ferries in total).
Milestone 49 covers the political agreement between the government and parliament on the
subsidy scheme for the green transition of ferries. The subsidy scheme must co-finance the
acquisition of new green ferries, or the retrofitting of existing ferries or charging infrastructure. The
beneficiaries must be municipalities. The subsidy percentage must be of 15-25%. The following
criteria must be used for the subsidy: (i) the CO2 effect and environmental effect per invested DKK;
(ii) the funds shall only be used for investments in new green ferries, retrofit or other necessary
infrastructure such as charging stations for the ferries. No further legislation is necessary beyond
the political agreement.
Milestone 49 is the first step of the implementation of the investment, and it will be followed by
target 50, consisting in the purchase or retrofitting of at least 15 green ferries. The investment has
the final expected date for implementation in Q4 2025.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
ii.

Summary document duly justifying how the milestone (including all the constitutive
elements) was satisfactorily fulfilled.
Political agreement on the green transition of the specific maritime sector of 19 April 2021
(‘Aftale mellem regeringen (Socialdemokratiet), Radikale Venstre, Socialistisk Folkepari,
Enhedslisten og Alternativet om: Udmontning af midler fra gron transportpulje II til
omstilling af indenrigsfaerger’), with a majority of 96 votes out of 175. The political
agreement was published on 19 April 2021 on the website of the Danish Ministry of
Transport.
Link to the publication: https://www.trm.dk/media/jn1bqy2t/endelig-aftaletekst-omgroen-transportpulje-ii-final-a-1.pdf

The authorities also provided:
i.

Addendum to the political agreement on the green transition of the specific maritime
sector of 23 September 2021 (‘Tillaegsaftale til aftale 19 april 2021 mellem regerinen
(Socialdemokratiet), Radikale Venstre, Socialistisk Folkeparti, Enhedslisten og Alternativet
om: Udmontning af midler fra gron transportpulje II til omstilling af indenrigsfaerger’). It was
published on 23 September 2021 on the website of the Danish Ministry of Transport.
Link to the publication: https://www.trm.dk/media/fdmjl2p5/tillaegsaftale-til-aftale-omgroen-transportpulje-ii.pdf

Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all
constitutive elements of the milestone.

52

The government and parliament have reached a political agreement on the subsidy scheme for
the green transition of ferries:
Denmark provided the political agreement of 19 April 2021 and its addendum from 23 September
2021. As explained in the summary document and evidenced by the political agreement, the
agreement has been adopted between five out of ten parties (the governing party Social Democratic
Party (Socialdemokratiet), as well as the parties Radical Left (Radikale Venstre), Socialist People's
Party (Socialistisk Folkeparti), Unity Party (Enhedslisten) and Alternative Party (Alternativet)) with
the majority of members from the Danish parliament (page 1 in political agreement on the green
transition of the specific maritime sector from 19 April 2021). At the time, the parties represented
a majority of 96 seats out of 179 seats as per the website of the Parliament: https://www.ft.dk//media/sites/ft/pdf/folkestyret/valg-og-afstemninger/folketingsvalg-fra-1953.ashx
In addition, the addendum to the political agreement has been adopted between five out of ten
parties (the governing party Social Democratic Party (Socialdemokratiet), as well as the parties
Radical Left (Radikale Venstre), Socialist People's Party (Socialistisk Folkeparti), Unity Party
(Enhedslisten) and Alternative Party (Alternativet) with the majority of members from the Danish
parliament on 23 September 2021 (page 1 in the addendum to the political agreement from 23
September 2021).
The Council Implementing Decision states that the political agreement should be reached and
signed. In accordance with Danish parliamentary procedures, political agreements are not signed.
They are agreements amongst legislative coalitions obliging the parties to vote in favour of the
agreed law or legislative package in Folketinget and give all parties in the conciliation community a
veto right in relationship to amendments to the consensual legislation. Nonetheless, the agreement
of the political parties is evidenced by the publication of the document and the presence of the
respective parties on the first page of the agreement. On this basis, it is considered that this
constitutive element of the milestone is satisfactorily fulfilled.
The subsidy scheme shall co-finance the acquisition of new green ferries, retrofitting existing
ferries or charging infrastructure.
Page 2 of the political agreement on the green transition of the specific maritime sector from 19
April 2021 specifies that the subsidy scheme co-finances the acquisition of new green ferries,
retrofitting existing ferries or charging infrastructure.
The beneficiaries shall be municipalities.
Page 2 of the political agreement of the specific maritime sector of 19 April states that: ‘1. In the
light of the results of the ferry analysis, the entire pool of DKK 200 million is allocated to the
conversion of municipal domestic ferries.’
The subsidy percentage shall be of 15-25%. The following criteria shall be used for the subsidy:
The CO2 effect and environmental effect per invested DKK.
Page 2 of the political agreement specifies that ‘The pool is allocated on the basis of the principle of
technology neutrality. The subsidy will amount to 20% of the investment for part exceeding the
investment volume on a similar diesel ferry. The rest of the investment is subsidised by 15%. For
retrofit, 25 % grants are granted.’
The addendum to the political agreement includes a new wording: ‘The subsidy will amount to 25%
of the investment, irrespective of whether it involves the purchase of a ferry or retrofit of an existing
ferry’. With this addendum to the political agreement, the subsidy amounts up to 25% of the
investment, regardless of whether project regards a new acquisition of a new ferry or retrofit of an
existing ferry, which is thereby in line with the Council Implementing Decision milestone
requirement.
On the allocation criteria, the political agreement of 19 April specifies on page 2 that:
53



The criteria for the subsidy will be as (i) CO2 reduction by krone spent and achieved via
economies of scale and (ii) reduction of other emissions.
These criteria are in line with the Council Implementing Decision, which specifies the criteria for the
subsidy as follows: the CO2 effect and environmental effect per invested DKK.
The funds shall only be used for investments in new green ferries, retrofit or other necessary
infrastructure such as charging stations for the ferries.
As mentioned above under the point ‘The subsidy scheme shall co-finance the acquisition of new
green ferries, retrofitting existing ferries or charging infrastructure’, page 2 of the political
agreement of 19 April 2021 includes this specific requirement.
No further legislation is necessary as the political agreement along with finance act 2021 provide
the relevant legal basis.
The political agreement of 19 April 2021 and the addendum to political agreement of 23 September
2021 are the relevant legal basis, therefore no further legislation is necessary.
Commission Preliminary Assessment: Satisfactorily fulfilled

Related Measure: C7.I1: Research in green solutions: Carbon capture and storage
or use of CO2
Name of the Milestone: Selection of mission roadmaps for 'carbon capture and storage or use of
CO2'.
Qualitative Indicator: Innovation Fund Denmark has selected the
roadmaps for the mission 'carbon capture and storage or use of
Time: Q3 2021
CO2'
Context:
The measure aims at providing the public and private sectors with incentives to boost research and
development, particularly in innovative green technologies in carbon capture and storage or use of
CO2.
Milestone 64 requires Innovation Fund Denmark to select the roadmaps to propose ideas for work
streams and activities to overcome challenges that Denmark is facing in regard to research and
development, for the mission for 'carbon capture and storage or use of CO2' on the basis of an open
call. This is the first of the four missions of the research programme to accelerate the development of
climate-friendly technology solutions.
Milestone 64 is the first step of the implementation of the investment, and it will be followed by
targets 65 and 66, related to selection and funding of at least one public-private partnership on 'carbon
capture and storage or use of CO2'. The investment has a final expected date for implementation in
Q4 2022.
Number: 64

Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive
elements) was satisfactorily fulfilled.
ii.
the selected and published roadmaps for the mission for ‘carbon capture and storage or use
of CO2’:
a)
The Green CCUS Roadmap - Towards a fossil free future published on the website
of Innovation Denmark on 16 August 2021.
54

b)

Mission CCUS Roadmap – a roadmap for Carbon Capture, Utilisation and Storage
published on the website of Innovation Denmark on 16 August 2021.
Link to the publication: https://innovationsfonden.dk/da/p/innomissions/mission-drivengreen-research-and
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
Innovation Fund Denmark has selected the roadmaps.
In August 2021, two selected roadmaps for the mission for ‘carbon capture and storage or use of CO2’
were published by Innovation Fund Denmark in their website following the launch of the open call for
Innomission partnerships and subsequent independent evaluation process.
To propose ideas for work streams and activities to overcome challenges that Denmark is facing in
regard to research and development, for the mission for 'carbon capture and storage or use of CO2'.
Both selected roadmaps, ‘The Green CCUS’ and ‘The mission CCUS’, propose ideas for work streams
and activities to overcome challenges that Denmark is facing in regard to research and development
for the related mission. As indicated in pages 11-16, ‘The Green CCUS’ roadmap focuses on technology
development within carbon capture at point sources, biogas upgrading and methanisation, uptake and
storage in biomass and ecosystems, storage in geological repositories and minerals, pyrolysis, biochar
and storage in soils and sediments, carbon storage in the built environment, biorefinery for chemicals
and materials, direct CO2 air capture, CO2 for fuels, chemicals, and carbon-rich materials, and sector
coupling. ‘The Mission CCUS’ roadmap outlines possible work streams focusing on CO2 capture (page
11), CO2 storage and transport (pages 12 to 15), and CO2 utilization (page 16).
The roadmaps provide a comprehensive overview of the steps to be taken to achieve the two goals
outlined by the government (i.e. (i) 70% reduction of greenhouse gas emissions (GHG) in Denmark by
2030 and net-zero emissions by 2050 and strengthen environment and nature; and (ii) contribute to
increased competitiveness of the Danish businesses and industries) and form the basis for the call for
‘Innomission partnerships’. As a basis for outlining work streams and activity ideas, roadmaps describe
the global position of the field and an evaluation of key challenges and corresponding Danish
strongholds (page 11 of the Green CCUS Roadmap; pages 7-9 of the Mission CCUS roadmap) and
provide an analysis of specific paths of action and effort needed, i.e. work streams and activity ideas,
in regard to technology, implementation and financing, to achieve specific goals, critical milestones
and inflection points within the mission (pages 20-27 of the Green CCUS Roadmap and pages 10-29 of
the Mission CCUS roadmap).
Moreover, the proposed partnership initiatives aim to establish an appropriate balance between the
activities suggested by both roadmaps to secure both short term impacts and long-term innovation
efforts along the value chain covering CO2 capture, intermediate/permanent storage, infrastructure/
transport and sector coupling activities.
Furthermore, in line with the description of the measure, the objectives of the partnerships under this
mission are to develop cost-effective CO2 capture solutions from the largest emitters or from the
atmosphere and store carbon or use it in new climate neutral energy sources. The partnerships achieve
these objectives, because they create economic incentives to use carbon capture and storage or use
of CO2 and strengthen the research in the geological preconditions for storing CO2 in Denmark,
developing the material to capture carbon, and developing methods of analysis that may monitor and
prevent leakage as follows: Mission 1 roadmaps were specifically evaluated on their potential to form
the basis of a partnership with the objectives to develop cost-effective CO2 capture solutions from the
largest emitters or from the atmosphere and store carbon or use it in new climate neutral energy
sources. Concretely, first roadmap, ‘The Mission CCUS’ focuses on economic incentives to use carbon
capture and storage or use of CO2 in the implementation gap analysis (page 19). The roadmap also
suggests research in storage in geological repositories and minerals (pages 13 – 14), in the
55

development of materials to capture carbon in research in utilization of CO2 for fuels, chemicals, and
carbon-rich materials (page 16) and in digital technologies such as real-time secure monitoring of CCUS
(page 17). The second roadmap, ‘The Green CCUS’ addresses cost reduction of carbon capture (table
1 page 12), research and development needs regarding storage of CO2 in the Danish underground
(pages 13 – 15), the use of CO2 for chemicals and materials (pages 16 – 17), and optimization of
monitoring procedures in relation to CO2 storage.
Furthermore, in line with the description of the measure, in its review of applications for this mission,
Innovation Fund Denmark took into account the relation with the development and demonstration
project of CO2 storage sites in depleted oil and gas fields in the Danish sector of North Sea that are
initiated in component 2.3 on “Energy efficiency, green heating and Carbon Capture and Storage”, to
avoid any overlaps: Concretely, one of the evaluation criteria in the open call for partnerships was that
the plan for organizing the partnerships must ensure continuous alignment of the roadmaps with other
initiatives such as, for instance, the initiative in component 2.3 (evaluation criteria no. 2 'Execution –
implementing the roadmaps, on p. 6 of the call for applications). Additionally, the Mission CCUS
roadmap takes into account the relation to the initiative concerning component 2.3 on “Energy
efficiency, green heating and Carbon Capture and Storage, where the initiative is mentioned as part of
the financial roadmap for the mission as the initiative offers specific funding for offshore storage
options (page 28).
On the basis of an open call.
In accordance with the requirement of the Council Implementing Decision on selecting roadmaps on
the basis of an open call, the call was publicly announced on the website of Innovation Fund Denmark
in
January
2021
with
application
deadline
in
May
2021 (https://innovationsfonden.dk/da/p/innomissions/roadmaps-mission-driven-green-research).
The call was open for all relevant actors from multiple fields of research and development areas which
were invited to take part in the development of mission roadmaps. This included knowledge
institutions, Research and Technology Organisations (GTS institutes), companies (start-ups, SMEs,
large companies), investors, municipalities, cluster organisations, etc. Innomission roadmaps were
evaluated on their overall impact and value creation potential for the Danish businesses and society
including their potential for securing existing- and creating new jobs and export of green solutions. For
the purpose of evaluating the robustness of the Innomission roadmap as well as the impact and value
creation the following criteria were used: Impact, Innovation and Excellence. Roadmaps were
evaluated by international peers and Innovation Fund Denmark's Board of Directors.
Commission Preliminary Assessment: Satisfactorily fulfilled

Related Measure: C7.I2: Research in green solutions: Green fuels for transport
and industry
Name of the Milestone: Selection of mission roadmaps for ‘green fuels for transport and industry’
Qualitative Indicator: Innovation Fund Denmark has selected the roadmaps for
Time: Q3 2021
the mission ‘green fuels for transport and industry’
Context:
The measure aims at providing the public and private sectors with incentives to boost research and
development, particularly in innovative green technologies in green fuels for transport and industry.
Milestone 67 requires Innovation Fund Denmark to select the roadmaps to propose ideas for work
streams and activities to overcome challenges that Denmark is facing in regard to research and
development, for the mission for 'green fuels for transport and industry’ on the basis of an open call.
This is the second of the four missions of the research programme to accelerate the development of
climate-friendly technology solutions.
Number: 67

56

Milestone 67 is the first step of the implementation of the investment, and it will be followed by
targets 68 and 69, related to the selection and funding of at least one public-private partnership on
‘green fuels for transport and industry’. The investment has a final expected date for implementation
in Q4 2022.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive elements)
was satisfactorily fulfilled.
ii.
The decisions of the Innovation Fund Denmark selecting the roadmaps on 18 June 2021.
iii.
The selected and published roadmaps for the mission for ‘green fuels for transport and
industry’:
a)
Green Fuels in Transport and Industry published on the website of
Innovation Denmark on 16 August 2021.
b)
Leveraging Danish strengths to mature and scale up e-fuels for transport
published on the website of Innovation Denmark on 16 August 2021.
Link to the publication: https://innovationsfonden.dk/da/p/innomissions/mission-drivengreen-research-and
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
Innovation Fund Denmark has selected the roadmaps.
In August 2021, two selected roadmaps for the mission for ‘green fuels for transport and industry’
were published by Innovation Fund Denmark following the launch of the open call for Innomission
partnerships and subsequent independent evaluation process.
The Board Decision of the Innovation fund Denmark selecting the roadmaps demonstrates that
Innovation Fund Denmark selected the roadmaps.
To propose ideas for work streams and activities to overcome challenges that Denmark is facing in
regard to research and development, for the mission for ‘green fuels for transport and industry’.
Both selected roadmaps, ‘Green Fuels in Transport and Industry’ and ‘Leveraging Danish strengths to
mature and scale up e-fuels for transport’, propose ideas for work streams and activities to overcome
challenges that Denmark is facing in regard to research and development for the related mission. The
first roadmap, ‘Green Fuels in Transport and Industry’, pages 8 to 15 and 16 to 24, proposes an
approach towards achieving climate neutrality by 2050 taking into account the national set goals for
CO₂ reductions in 2030, scarcities in the availability of resources along the path, actions needed in
relation to investments, and identified gaps regarding research and development in the area of
transport for heavy-consumption means of transport (road transport, heavy-duty transport, air
transportation, etc.) including a strong focus on supporting a market for hydrogen through clear
support for planned large-scale Power-to-X demonstration plants and the required increase in power
production capacity; The second roadmap, ‘Leveraging Danish strengths to mature and scale up efuels for transport’, on pages 13 to 25 and 26-27, describes pathways focusing on such as hydrogen
electrolysis, storage, transport and distribution, carbon capture and green sources of fuels.
Furthermore, in line with the description of the measure, the objective of this mission is to develop
new solutions to create new green fuels, including green hydrogen, and demonstrate how Power-toX systems may be integrated in the overall energy system. Investing in targeted research-,
development and demonstration efforts to bring currently costly green fuels to a level of technological
maturity facilitates commercial use and deployment of such technologies at a larger scale:

57

The first roadmap ‘Green Fuels in Transport and Industry’ emphasizes that technological development
within the main technological pathways outlined in the roadmap (1. Green hydrogen (for heavy duty
land transport), 2. Intermediary fuels (green methanol - MeOH/Dimethyl ether - DME and Bio-oil), and
3. Green fuels for shipping and aviation) is vital to increasing efficiency, bringing down the cost of
green fuels and bringing forth a transition where technologies can be deployed at a larger scale
(roadmap pages 2-3).
The second roadmap ‘Leveraging Danish strengths to mature and scale up e-fuels for transport’
focuses on how an R&D effort within the main technological pathways for renewable hydrogen
(hydrogen electrolysis, storage, transport and distribution, Carbon Capture, E-Methanol, Aviation (eKerosene), and shipping (e-Ammonia)) and power-to-X can bring technologies to a maturity level that
will reduce the cost of green fuels (roadmap pages 27 – 28).
On the basis of an open call.
In accordance with the requirement of the Council Implementing Decision on selecting roadmaps on
the basis of an open call, the call was publicly announced on the website of Innovation Fund Denmark
in
January
2021
with
application
deadline
in
May
2021 (https://innovationsfonden.dk/da/p/innomissions/roadmaps-mission-driven-green-research).
The call was open for all relevant actors from multiple fields of research and development areas which
were invited to take part in the development of mission roadmaps. This included knowledge
institutions, Research and Technology Organisations (GTS institutes), companies (start-ups, SMEs,
large companies), investors, municipalities, cluster organisations, etc. Innomission roadmaps were
evaluated on their overall impact and value creation potential for the Danish businesses and society
including their potential for securing existing- and creating new jobs and export of green solutions. For
the purpose of evaluating the robustness of the Innomission roadmap as well as the impact and value
creation the following criteria were used: Impact, Innovation and Excellence. Roadmaps were
evaluated by international peers and Innovation Fund Denmark's Board of Directors.
Commission Preliminary Assessment: Satisfactorily fulfilled

Related Measure: C7.I3: Research in green solutions: Climate- and environment
friendly agriculture and food production
Name of the Milestone: Selection of mission roadmaps for ‘climate- and environment friendly
agriculture and food production'.
Qualitative Indicator: Innovation Fund Denmark has selected
the roadmaps for the mission ‘climate- and environment friendly Time: Q3 2021
agriculture and food production’.
Context:
The measure aims at providing the public and private sectors with incentives to boost research and
development, particularly in innovative green technologies in climate- and environment friendly
agriculture and food production.
Milestone 70 requires Innovation Fund Denmark to select the roadmaps to propose ideas for work
streams and activities to overcome challenges that Denmark is facing in regard to research and
development, for the mission for ‘climate- and environment friendly agriculture and food
production’ on the basis of an open call. This is the third of the four missions of the research
programme.
Milestone 70 is the first step of the implementation of the investment, and it will be followed by
targets 71 and 72, related to funding at least one public-private partnership on ‘climate- and
environment friendly agriculture and food production'. The investment has a final expected date for
implementation in Q4 2022.
Number: 70

58

Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the target (including all the constitutive elements)
was satisfactorily fulfilled.
ii.
The selected and published roadmap for the mission for ‘climate- and environment friendly
agriculture and food production’: AgriFoodTure roadmap published on the website of
Innovation Denmark on 16 August 2021.
Link to the publication: https://innovationsfonden.dk/da/p/innomissions/mission-drivengreen-research-and
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all
constitutive elements of the milestone.
Innovation Fund Denmark has selected the roadmaps.
The Council Implementing Decision states mission roadmaps would be selected by Innovation Fund
Denmark. Denmark has provided one roadmap instead of multiple. The selected roadmap selected
by Innovation Fund on the basis of an open call, AgriFoodTure, is based on collaborative efforts
between universities, industry and organisations and provides all required elements stemming from
the Council Implementing Decision. On this basis, it is considered that this constitutive element of
the milestone is satisfactorily fulfilled.
In August 2021, the selected roadmap for the mission for ‘climate- and environment friendly
agriculture and food production' was published by Innovation Fund Denmark following the launch
of the open call for Innomission partnerships and subsequent independent evaluation process.
To propose ideas for work streams and activities to overcome challenges that Denmark is facing
in regard to research and development, for the mission for ‘climate- and environment friendly
agriculture and food production'.
The selected roadmap, ‘AgriFoodTure’ proposes ideas for work streams and activities to overcome
challenges that Denmark is facing in regard to research and development for the related mission.
The ‘AgriFoodTure’ roadmap describes research and innovation needs within for instance new
breeding techniques in plant-based food production (pages 15 – 16), new precision farming
technologies (pages 8 – 9), new cultivation and fertilization methods and systems (pages 7 – 8). It
identifies four major tracks/work streams where efforts are needed within: A) Future land use and
management (pages 7 - 9), B) Animal-based food production (pages 10 – 13), C) Plant-based food
production (pages 14 – 17), and D) Biotechnology-based food production and alternative protein
sources (pages 18 – 21). The roadmap provides a comprehensive overview of the steps to be taken
to achieve the goals outlined by the government and forms the basis for the call for Innomission
partnerships. As the basis for identifying work streams and activity ideas, the roadmap describes the
global position of the field and an evaluation of key challenges and corresponding Danish
strongholds (pages 2-4) and provides an analysis of specific paths of action and effort, such as work
streams and activity ideas, needed, in regard to technology, implementation and financing, to
achieve specific goals, critical milestones and inflection points within the mission (pages 7-27).
The ‘AgriFoodTure’ roadmap was specifically evaluated on its potential to accomplish the objective
of the mission objective, including the description of type of activities that are to be funded within
the mission, as described above. The mission roadmap (phase 1) describes pathways focusing on
the contribution to the overall goals of (i) 70% reduction of carbon emissions by 2030 compared
with 1990 levels and (ii) carbon neutrality no later than 2050. The roadmap outlines gaps, solutions,
and Danish strongholds relevant for achieving the overall goals of reduction of greenhouse gas
59

emissions, increase of biodiversity, reduction of pesticide use and nutrient runoff. As this is a highly
complex task, complementary expertise and collaboration involving research, innovation, and
implementation in all steps of the value chain are required and the roadmap includes four major
development paths, where largest efforts are needed. The focus of the first path, ‘Future land use
and management’ is to maintain sustainable production and earnings. The focus of the second path,
‘Animal-based food production’ is to reduce emissions and bring research and innovation into the
area of new breeding techniques. The third one, ‘Plant-based food production’ aims at delivering on
precision agriculture techniques and reduction of pesticide use and nutrient runoff. Finally, fourth
and last path ‘Biotechnology-based food production and alternative protein sources’ aims at
maintaining sustainable production and bringing research and innovation into the area of food
production. In addition, the roadmap also addresses cross cutting issues (e.g. cross-disciplinary
collaboration in accounting greenhouse gas emission reductions, digitalisation, incentives,
documentation and regulation) and data-driven governance elements given the task at stake.
On the basis of an open call.
In accordance with the requirement of the Council Implementing Decision on selecting roadmaps
on the basis of an open call, the call was publicly announced on the website of Innovation Fund
Denmark
in
January
2021
with
application
deadline
in
May
2021
(https://innovationsfonden.dk/da/p/innomissions/roadmaps-mission-driven-green-research). The
call was open for all relevant actors from multiple fields of research and development areas which
were invited to take part in the development of mission roadmaps. This included knowledge
institutions, Research and Technology Organisations (GTS institutes), companies (start-ups, SMEs,
large companies), investors, municipalities, cluster organisations, etc. Innomission roadmaps were
evaluated on their overall impact and value creation potential for the Danish businesses and society
including their potential for securing existing- and creating new jobs and export of green solutions.
For the purpose of evaluating the robustness of the Innomission roadmap as well as the impact and
value creation the following criteria were used: Impact, Innovation and Excellence. Roadmaps were
evaluated by international peers and Innovation Fund Denmark's Board of Directors.
Commission Preliminary Assessment: Satisfactorily fulfilled

Related Measure: C7.I4: Research in green solutions: Circular economy focusing
on reuse and reduction of plastic and textile waste
Name of the Milestone: Selection of mission roadmaps for ‘circular economy focusing on reuse
and reduction of plastic and textile waste.
Qualitative Indicator: Innovation Fund Denmark has selected
the roadmaps for the mission ‘circular economy focusing on
Time: Q3 2021
reuse and reduction of plastic and textile waste’.
Context:
The measure aims at providing the public and private sectors with incentives to boost research and
development, particularly in innovative green technologies in circular economy focusing on reuse
and reduction of plastic and textile waste.
Milestone 73 requires Innovation Fund Denmark to select the roadmaps to propose ideas for work
streams and activities to overcome challenges that Denmark is facing in regard to research and
development, for the mission for ‘circular economy focusing on reuse and reduction of plastic and
textile waste’ on the basis of an open call. This is the fourth of the four missions of the research
programme.
Milestone 73 is the first step of the implementation of the investment, and it will be followed by
targets 74 and 75, related to funding at least one public-private partnership on ‘circular economy
Number: 73

60

focusing on reuse and reduction of plastic and textile waste’. The investment has a final expected
date for implementation in Q4 2022.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive
elements) was satisfactorily fulfilled.
ii.
The selected and published roadmap for the mission for ‘circular economy focusing on
reuse and reduction of plastic and textile waste’: Circular economy with a focus on plastics
and textiles, A 2030 & 2050 Roadmap, published on the website of Innovation Denmark on
16 August 2021.
Link to the publication: https://innovationsfonden.dk/da/p/innomissions/mission-drivengreen-research-and
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all
constitutive elements of the milestone.
Innovation Fund Denmark has selected the roadmaps.
The Commission considers that there is a clerical error in the text of the Council Implementing
Decision as regards the qualitative indicators of the milestone and has undertaken the assessment
on a revised basis. Such description links the roadmap for the mission ‘carbon capture and storage
or use of CO2' instead of ‘circular economy focusing on reuse and reduction of plastic and textile
waste'. However, the mission ‘carbon capture and storage or use of CO2’ is linked to Investment 1
‘Carbon capture and storage or use of CO2’ under Component 7, and not with Investment 4 ‘Circular
economy focusing on the use and reduction of plastic and textile waste’ under the same Component.
Against this background, the justification and substantiating evidence provided by the Danish
authorities cover all constitutive elements of the milestone.
The Council Implementing Decision states mission roadmaps would be selected by Innovation Fund
Denmark. Denmark has provided one roadmap instead of multiple. The selected roadmap selected
by Innovation Fund on the basis of an open call, “Circular economy with a focus on plastics and
textiles, A 2030 & 2050 Roadmap”, is based on collaborative efforts between universities, industry
and organisations and provides all required elements stemming from the Council Implementing
Decision. On this basis, it is considered that this constitutive element of the milestone is satisfactorily
fulfilled.
In August 2021, the selected roadmap for the mission for ‘circular economy focusing on reuse and
reduction of plastic and textile waste’ was published by Innovation Fund Denmark following the
launch of the open call for Innomission partnerships and subsequent independent evaluation
process.
To propose ideas for work streams and activities to overcome challenges that Denmark is facing
in regard to research and development, for the mission for ‘circular economy focusing on reuse
and reduction of plastic and textile waste.
The roadmap proposes three tracks or possible work streams with a focus on 1. Plastics, 2. Textiles,
and 3. A common track (page 9). The timeline for three tracks (plastics, textile, and a common track)
is presented in the roadmap on pages 20-23. The initiatives are grouped into circular focus areas:
materials, design & production, systems & services, and recovery. Overall, the roadmap provides a
comprehensive overview of the steps to be taken to achieve the goals outlined by the government
and form the basis for the call for Innomission partnerships. As a basis for identifying work streams
and possible activity ideas, the roadmap describes the global position of the field and an evaluation
61

of key challenges and corresponding Danish strongholds (pages 3-6) and provides an analysis of
specific paths of action and effort, such as work streams and activity ideas, needed, in regard to
technology, implementation and financing, to achieve specific goals, critical milestones and
inflection points within the mission (pages 7-24 and 25-30).
Roadmap for “circular economy with a focus on plastics and textiles” proposes a governance model
with a broad partnership including all Danish Universities, all University Colleges, GTS Institutes, two
Clusters and Museums. Industry stakeholders have been interviewed for feedback and adjustments.
The vision for this roadmap is a Danish society with full circularity by 2050. The roadmap presents a
timeline for realisation of the initiatives divided into activities in the first year and subsequent
activities towards 2030 and 2050 that could result in a significant reduction of greenhouse gas
emissions, fossil fuel and water consumption. Plastics and textiles are faced with common
challenges and would benefit greatly from synergies across sectors. To address the challenges
identified in the roadmap 32 specific initiatives, grouped as 13 plastics, 10 textiles and nine common
initiatives are suggested by Denmark’s leading researchers (pages 25 to 28). The mission will focus
on increasing resource productivity (‘common’ track on pages 22 and 23); decreasing plastic and
textile waste (‘plastics’ and ‘textile’ tracks on pages 20, 21, 22); and increasing the use of reusable
materials (under materials and recovery in the circular focus areas). As a result, all steps in the value
chain will be funded to reduce waste, ranging from product design to consumer behaviour as
initiatives are grouped into circular focus area: materials, design & production, systems & services,
and recovery. The expected impacts of the implementation of this roadmap initiatives will result in
a reduction of CO2 emissions, fossil fuel and water consumption of 63%, 65% and 50% by 2030,
respectively. For 2050, reductions of CO2 emissions, fossil fuel and water consumption of 97%, 95%,
and 60%, respectively. Additionally, 7 500 jobs expected by 2030 and 12 600 in 2050.
On the basis of an open call.
In accordance with the requirement of the Council Implementing Decision on selecting roadmaps
on the basis of an open call, the call was publicly announced on the website of Innovation Fund
Denmark
in
January
2021
with
application
deadline
in
May
2021
(https://innovationsfonden.dk/da/p/innomissions/roadmaps-mission-driven-green-research). The
call was open for all relevant actors from multiple fields of research and development areas which
were invited to take part in the development of mission roadmap This included knowledge
institutions, Research and Technology Organisations (GTS institutes), companies (start-ups, SMEs,
large companies), investors, municipalities, cluster organisations, etc. Innomission roadmaps were
evaluated on their overall impact and value creation potential for the Danish businesses and society
including their potential for securing existing and creating new jobs and export of green solutions.
For the purpose of evaluating the robustness of the Innomission roadmap as well as the impact and
value creation the following criteria were used: Impact, Innovation and Excellence. Roadmaps were
evaluated by international peers and Innovation Fund Denmark's Board of Directors.
Commission Preliminary Assessment: Satisfactorily fulfilled

Number: 76

Related Measure: C7.I5: Incentives to boost R&D in companies
Name of the Milestone: The bill on deductions for research and development work enters into
force
Qualitative Indicator: The bill on deductions for research and development
Time: Q2 2021
work has been adopted by the Danish Parliament and enters into force
Context:
The measure aims at establishing a deduction scheme for all companies to increasingly engage in
research and development investments. Research and development investments will benefit from a
62

tax rebate, implying an economic incentive for such investments. The objective of this investment to
frontload investments in research and development, both in the context of the recovery and in the
coming years by incentivizing companies to increase their overall research and development spending.
Milestone 76 requires the bill on deductions for research and development work to enter into force.
Milestone 76 is the first step of the implementation of the investment that will be followed by target
77, related to 500 firms having used the tax deduction provided by the deductions for research and
development work. The investment has a final expected date for implementation in Q3 2023.
Evidence provided:
In line with the verification mechanism set out in the Operational Arrangements, the following
evidence was provided:
i.
Summary document duly justifying how the milestone (including all the constitutive elements)
was satisfactorily fulfilled.
ii.
Copy of the publication of the law on the green tax No. 2020/1 LSV 178 (Forslag til Lov om
ændring af afskrivningsloven, ligningsloven,pensionsafkastbeskatningsloven og lov om afgift
af svovl (Forhøjelse afgrænsen for straksafskrivning m.v., midlertidig forhøjelse
afafskrivningsgrundlaget for nye driftsmidler, forlængelse af denmidlertidige forhøjelse af
fradrag for udgifter til forsøgs- ogforskningsvirksomhed og forlængelse af bundfradrag i
svovlafgiften) reform including deductions for research and development, published on 8
December 2020, adopted by the Danish Parliament on 13 April 2021 and entered into force
on 21 April 2021. Link: https://www.retsinformation.dk/eli/lta/2021/672
The authorities also provided:
i.
Previous Depreciation Act, No. 242 (Bekendtgørelse af lov om skattemæssige afskrivninger
(afskrivningsloven) cf. Consolidation Act No. 242 of 18 February 2021.
ii.
Previous Tax Assessment Act, No. 806 (Bekendtgørelse af lov om påligningen af indkomstskat
til staten (ligningsloven) cf. Consolidation Act No. 806 of 8 August 2019.
Analysis:
The justification and substantiating evidence provided by the Danish authorities covers all constitutive
elements of the milestone.
The bill on deductions for research and development work has been adopted by the Danish
Parliament and entered into force.
The bill on the green tax reform including the deductions for investments in research and development
was introduced on 8 December 2020 and was adopted by the Danish Parliament on 13 April 2021. The
provisions (Sections 1, No. 5 and Section 2, No. 1.) entered into force on 21 April 2021.
The adopted bill No. 672 of 19 April 2021 was published on the Danish Official Journal online
Retsinformarion.dk.
The measure shall extend the basis for depreciation and the basis for deduction for all private sector
research and development expenses by 130% of in the financial year of 2022.
The adopted bill No. 672 of 19 April 2021 included the deductions for investments in research and
development and the extension of the increased deduction for research and development by 130
percentage points entering into force and effective for the fiscal year of 2022 (Sections 1, No. 5 and
Section 2, No. 1.). The increased deduction for all private research and development was thereby
extended to the fiscal year 2022.
Sections 1, No. 5 and Section 2, No. 1 of the bill relate to investments in research and development.
The bill raised with an additional 25 percentage points for the income year 2021 and 2022 with a ceiling
of 910 million DKK. This is added to the existing deduction for research and development expenses by

63

105 percentage points resulting in 130 percentage points in all private sector research and
development
The deductions for research and development work shall be effective as from the date according to
the law.
The relevant legislative provisions have entered into force on 21 April 2021, increasing an additional
25 percentage points the deduction for research and development expenses, resulting in 130
percentage points in all private sector, for the income year 2021 and 2022 (Sections 1, No.5 and
Section 2, No. 1). Furthermore, in line with the description of the investment, the objective of this
measure shall be to frontload investments in research and development, both in the context of the
recovery and in the coming years by incentivizing companies to increase their overall research and
development spending. This increased deduction included in bill No. 672 with adjustments to (i)
section 6 of the Depreciation Act No. 242 of 18 February 2021 and (ii) section 8 B of the Tax Assessment
Act No. 806 of 8 August 2019 creates an incentive for companies to invest in R&D as it makes it
cheaper, hence more attractive, which is also part of the requirement of investment description in the
Council Implementing Decision.
Additionally, the deduction is also expected to encourage smaller firms to increasingly engage in
research and development, since they qualify for the deduction as well, since the ceiling of 910 million
DKK in the law ensures that smaller companies have a relatively greater advantage than larger
companies. The adjustments made by law No. 672 (i) section 6 of the Depreciation Act No. 242 of 18
February 2021; and (ii) section 8 B of the Tax Assessment Act No. 806 of 8 August 2019 allow all firms
to qualify for the deduction.
Research and development related to exploration and extraction of fossil fuels and raw materials shall
not qualify for the tax deduction. Provisions of the Depreciation Act section 6, subsection 1, No. 3, do
not allow for depreciation on operating assets and ships used for exploration for fossil fuels and other
raw materials. Provisions of the Tax Assessment Act section 8 B, subsection 1, ensure that deductions
for expenses for research and development do not apply to expenses related to exploration for fossil
fuels and other raw materials. Finally, the deduction for expenses used for the extraction of fossil fuels
and other raw materials are not covered by these provisions.
Commission Preliminary Assessment: Satisfactorily fulfilled

64