Modifying the National Recovery and Resilience Plans: existing opportunities and proposed changes under REPowerEU


and Catarina Martin

The Recovery and Resilience Facility (RRF) was adopted as part of the urgent response of the European Union (EU) to the COVID-19 outbreak. So far, the focus has understandably been on implementation of the National Recovery and Resilience Plans (NRRPs). Little attention has been dedicated to anticipating the need and the existing procedures for modifying the plans.

However, the “clock is ticking” on at least two of the three modification options under the current RRF Regulation. Updates should be ready for submission as soon as possible after 1 January 2023 if they are going to reflect the European Commission (EC) updates of the maximum financial contribution published on 30 June 2022. And Member States have only until August 2023 to submit revisions should they choose to request loans. Considering the time needed for prior consultation, assessment and approval, the remaining timeline is tight at best.

The REPowerEU package, tabled by the EC on 18 May 2022, has further complicated matters. It includes a proposal for amending the RRF Regulation which, if adopted “as it stands”, will have a direct impact on the options and timeline for modification of the NRRPs.

This blog aims to clarify the existing and the proposed modification options, and to draw attention to certain implications of their interplay. To the extent that REPowerEU does not replace but instead amends and adds to the options available in the current RRF Regulation, the blog presents also the existing opportunities through the prism of proposed changes. It does so based on the assumption that the REPowerEU proposal to revise the RRF Regulation will be adopted “as it stands” by the end of 2022.

For readers’ convenience, this blog includes in an annex the text of the RRF Regulation as amended by the Commission’s REPowerEU proposal.

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This blog was written by Pavlina Stoykova and Catarina Martin

This blog is part of EIPA broader and ongoing work on the Recovery and Resilience Facility and the Technical Support Instrument. Recent contributions include:

For our next contribution on the topic, we will be looking forward to the European Court of Auditors Special Report on the recovery and resilience plans, forthcoming in autumn of this year.


The views expressed in this blog are those of the authors and not necessarily those of EIPA.

Tags ESIF and recovery & reform