Description:
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 20223
.
For readers’ convenience, this blog includes in an annex the text of the RRF Regulation as amended
by the Commission’s REPowerEU proposal4
. All references to articles in this blog are to that text
unless stated otherwise.