COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Germany Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 10158/21 and ST 10158/21 ADD 1) on the approval of the assessment of the recovery and resilience plan for Germany

EN EN
EUROPEAN
COMMISSION
Brussels, 16.11.2023
SWD(2023) 371 final
COMMISSION STAFF WORKING DOCUMENT
Analysis of the recovery and resilience plan of Germany
Accompanying the document
Proposal for a COUNCIL IMPLEMENTING DECISION
amending Implementing Decision (EU) (ST 10158/21 and ST 10158/21 ADD 1) on the
approval of the assessment of the recovery and resilience plan for Germany
{COM(2023) 726 final}
Offentligt
KOM (2023) 0726 - SWD-dokument
Europaudvalget 2023
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Table of contents
1. Executive summary...............................................................................................................................2
2. Objectives of the modification of the plan............................................................................................3
3. Summary of the assessment of the plan................................................................................................5
3.1. Comprehensive and adequately balanced response to the economic and social situation ............5
3.2. Link with country-specific recommendations and the European Semester ..................................6
3.3. Growth potential, job creation, economic, institutional and social resilience, European Pillar of
Social Rights, mitigating the impact of the crisis, and social territorial cohesion and convergence ........7
3.4. The principle of ‘do no significant harm’ .....................................................................................8
3.5. Green transition.............................................................................................................................8
3.6. Digital transition .........................................................................................................................10
3.7. Lasting impact of the plan...........................................................................................................11
3.8. Milestones, targets, monitoring and implementation..................................................................12
3.9. Costing .......................................................................................................................................12
3.10. Controls and audit.......................................................................................................................13
3.11. Coherence ...................................................................................................................................14
ANNEX I: Climate tracking and digital tagging ........................................................................................16
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1. EXECUTIVE SUMMARY
After having recovered from the COVID-19 pandemic, the German economy is currently
showing weak growth performance, under exceptional economic circumstances,
characterised by the war of aggression against Ukraine and the need to accelerate the green
energy transition. Russia’s war of aggression against Ukraine has led to a surge in energy and
commodity prices in Germany as well as to a higher awareness of the need of energy security and
autonomy. At the same time, the maximum financial contribution available for Germany under the
Recovery and Resilience Facility (RRF) was updated on 30 June 2022 and resulted in an increased
contribution for Germany. On 15 September 2023, Germany submitted a request to update its
recovery and resilience plan. For the update of its recovery and resilience plan (RRP), Germany
has relied on Article 18(2) of Regulation (EU) 2021/241 as the legal basis to take into account its
updated maximum financial contribution with the aim to accelerate its green and energy transition
and address its current challenges, including those identified in the country specific
recommendations to Germany in 2022 and 2023.
The update of German RRP includes one new investment and two scaled-up investments as
follows:
• Investment 1.1.6 (Federal support for efficient heat networks) is a new measure. It consists
of a funding scheme to invest in the construction, expansion and transformation of district
heating systems to integrate renewable energy and waste heat.
• Amendments to investment 1.2.1 (Support for the construction of charging infrastructure)
in order to scale up the existing investment by adding an additional 289 000 recharging
points in residential buildings.
• Amendments to investment 1.2.3 (Support for the replacement of the private vehicle fleet)
in order to scale up the existing investment by promoting an additional 399 450 electric
vehicles.
Based on the assessment of the submitted modification, the German modified plan receives
an A-rating on all criteria, except for costing, where the plan receives a B-rating (unchanged
from the original plan assessment).
(1)
Balanced
Response
(2)
CSRs1
(3)
Growth,
jobs…
(4)
DNSH2
(5)
Green
target
(6)
Digital
target
(7)
Lasting
impact
(8)
M & T3
(9)
Costing
(10)
Control
Systems
(11)
Coherence
A A A A A
(47.0%)
A
(48.1%)
A A B A A
1
Country specific recommendations.
2
Do no significant harm.
3
Milestones and targets.
3
2. OBJECTIVES OF THE MODIFICATION OF THE PLAN
2.1 The updated plan addresses Germany’s newly emerged challenges.
In 2022, Russia’s war of aggression against Ukraine led to a surge in energy and commodity prices
in Germany and the EU as a whole as well as to a higher awareness of the need of energy security
and autonomy. In line with the country specific recommendations 2022.4 focusing on reducing
overall reliance on fossil fuels and improving energy efficiency and 2023.4 focusing on energy
efficiency measures in building, including through investment in heating systems, the updated
RRP contributes towards the decarbonisation of the heating systems.
The new and upscaled measures add a significant additional contribution to the green transition
pillar by reducing the reliance on fossil fuels and increasing energy efficiency and security.
Therefore, the RRP continues to address the main challenges identified in relevant country-specific
recommendations.
2.2 Overview of the new and modified components and their associated estimated costs.
The main elements of the updated RRP are listed below by component.
Component 1.1 Decarbonisation using renewable hydrogen in particular:
New investment 1.1.6 Federal support for efficient heat networks:
The investment in green district heating networks is designed to encourage the development of
customized strategies to decarbonise and develop district heating networks. The measure consists
of financial support to investment projects to decarbonise existing district heating systems, as well
as investment projects for the construction of new district heating networks, expanding the share
of heat from renewable sources and waste heat.
Component 1.2 Climate friendly mobility
Scaled-up investment:1.2.1 Support for the construction of charging infrastructure
In accordance with Article 18(2) of Regulation (EU) 2021/241, Germany proposes to increase the
ambition of this investment by increasing the target of recharging points in residential buildings
from 400 000 in the original plan to 689 000 in the revised plan.
Scaled-up investment:1.2.3 Support for the replacement of the private vehicle fleet
In accordance with Article 18(2) of Regulation (EU) 2021/241, Germany proposes to increase the
ambition of this investment by promoting an additional 399 450 vehicles under the measure.
Table 1: New and modified components and associated costs
Component Status Costs (EUR million)
1.1 Decarbonisation using renewable hydrogen in
particular
Modified 570
1.2. Climate friendly mobility Modified 1 820
4
Other elements not covered by assessment criteria
The description of aspects related to administrative organisation, gender equality and equal
opportunities for all, consultation process, security self-assessment for digital investments and the
planned communication strategy as reflected in the previous Staff Working
Document (2021) 163 final/2 remains valid.
Consultation process
The updated RRP explains that consultations with stakeholders (Länder, social partners, welfare
organisations, environmental associations, representatives of civil society) have taken and will
continue to take place over the course of the implementation of the plan on a regular basis.
In preparation of the updated plan, the German authorities held meetings with the Länder (29
August 2023), social partners and welfare organisations (22 March 2023 and 7 July 2023) as well
as environmental associations (26 April 2023). During these meetings the measures envisaged for
the update of the plan were presented to the stakeholders and discussed. Individual questions were
answered, and comments and suggestions were taken into account when finalising the measures
for the plan.
Feedback received during the original consultation process, most notably with regard to the need
to invest in the expansion and transformation of district heating systems to integrate renewable
energy and waste heat, has been considered in the new measure 1.1.6 Federal support for efficient
heat networks. To ensure ownership by the relevant actors, it will remain crucial to involve all
local authorities and stakeholders concerned, including social partners, throughout the
implementation of the investments and reforms included in the updated RRP.
State aid
State aid and competition rules fully apply to the measures funded by the Recovery and Resilience
Facility. Union funds channelled through the authorities of Member States, like the RRF funds,
become State resources and can constitute State aid. When this is the case and State aid is present,
these measures must be notified and approved by the Commission before Member States can grant
the aid, unless those measures are covered by an existing aid scheme or comply with the applicable
conditions of a block exemption regulation, in particular the General Block Exemption Regulation
(GBER) declaring certain categories of aid compatible with the internal market in application of
Articles 107 and 108 TFEU4
. When State aid is present and it requires notification, it is the duty
of the Member State to notify State aid measures to the Commission before granting them, in
compliance with Article 108(3) TFEU. In this respect, the State aid analysis carried out by
Germany in the recovery and resilience plan cannot be deemed a State aid notification. In as far as
4
Annex to the Communication to the Commission of 9 March 2023 on the Approval of the content of a draft for a
Commission Regulation amending Regulation (EU) No 651/2014 declaring certain categories of aid compatible with
the internal market in application of Articles 107 and 108 of the Treaty and Regulation (EU) 2022/2473 declaring
certain categories of aid to undertakings active in the production, processing and marketing of fishery and aquaculture
products compatible with the internal market in application of Articles 107 and 108 of the Treaty; available at:
https://competition-policy.ec.europa.eu/system/files/2023-
03/GBER_amendment_2023_EC_communication_annex_0.pdf
5
Germany considers that a specific measure contained in the recovery and resilience plan entails de
minimis aid or aid exempted from the notification requirement, it is the responsibility of Germany
to ensure full compliance with the applicable rules.
3. SUMMARY OF THE ASSESSMENT OF THE PLAN
3.1. Comprehensive and adequately balanced response to the economic and social
situation
The modifications to Germany’s RRP do not change, and rather confirm and strengthen the
previous assessment that the RRP is a comprehensive and adequately balanced response to
the economic and social situation. With the modifications, Germany does not remove nor reduce
any investment or reform but reinforces two existing investments and adds one additional
investment contributing to the first pillar, green transition. The updated RRP still covers in a
comprehensive manner the six pillars structuring the scope of application of the Facility (Article
3 of Regulation (EU) 2021/241), namely: (i) green transition, (ii) digital transformation, (iii) smart,
sustainable and inclusive growth, (iv) social and territorial cohesion, (v) health and economic,
social and institutional resilience, and (vi) policies for the next generation. The coverage of the
German plan’s components towards the six pillars is summarised in Table 2. All pillars are covered
by at least one component, while a component may contribute to several pillars.
Table 2: Coverage of the six pillars of the Facility by the new or modified RRP components
Components
Green
transition
Digital
transition
Smart,
sustainable
& inclusive
growth
Social and
territorial
cohesion
Health, and
economic,
social and
institutional
resilience
Policies for
the next
generation
1.1. Decarbonisation using
renewable hydrogen in particular
● ● ○
1.2. Climate-friendly mobility ● ●
1.3. Climate-friendly renovation
and construction ● ○ ○
2.1. Data as the raw material of the
future ○ ● ● ○
2.2. Digitalisation of the economy ○ ● ○ ○ ○ ○
3.1. Digitalisation of education ● ● ● ○ ●
4.1. Strengthening social inclusion ○ ○ ● ●
5.1. Strengthening a pandemic-
resilient healthcare system ● ● ○ ●
6.1. Modern public administration ● ○ ○ ●
6.2. Reducing barriers to
investment
○ ○ ○ ● ○ ○
Key: ‘●’ investments and reforms of the component significantly contribute to the pillar;
‘○’ the component partially contributes to the pillar.
6
Green transition
Germany’s updated plan focuses significantly on supporting the green transition, with three
components dedicated to this pillar and three other components also contributing. Modifications
of both new and scaled-up measures increase the contribution of the revised plan to this pillar. The
climate contribution now stands at 47.0%, compared to 42.4% in the original plan, that was already
above the target of 37%.
Digital transformation
The digital transformation still represents a significant part of Germany’s updated plan. The
updated RRP continues to significantly contribute to promoting the digital transformation in a
variety of areas, including public administration and public services, private sector, education,
research and innovation, health. The increased importance of measures without digital aspects
have reduced the contribution of the updated plan to the digital pillar from 52.6% in the original
plan to 48.1%, yet this remains more than double the target of 20%.
***
The nature and extent of the proposed modifications to Germany’s recovery and resilience plan
do not have a material impact on the previous assessment (rating of A) and the modified plan
represents a comprehensive and adequately balanced response to the economic and social
situation, thereby contributing appropriately to all six pillars referred to in Article 3 of the RRF
Regulation, taking the specific challenges and the financial allocation of Germany into account.
3.2. Link with country-specific recommendations and the European Semester
The modifications to Germany’s RRP confirm and strengthen the previous assessment that the
RRP is contributing to effectively addressing all or a significant subset of the country-specific
recommendations addressed to Germany. As the maximum financial contribution for Germany has
been adjusted upwards, all 2022 and 2023 country-specific recommendations are considered in the
overall assessment.
Notably, the updated plan contributes to addressing the country-specific recommendations 2023.4
and 2022.4 to step up energy efficiency measures in buildings. It does so through investments in
new and existing heating systems and by funding feasibility studies and transformation plans,
which enable operators of district heating networks to develop long-term strategies to decarbonise.
The scheme provides investment aid for district heating networks, renewable heat generation
facilities and measures needed to integrate renewable heat and waste heat, including efficiency
measures and storage units, and incentivises the implementation of decarbonisation strategies.
Efficient district heating can contribute to reducing emissions and boosting energy efficiency in
the energy, industry and buildings sector. The measure is in line with the country-specific
recommendations to step up efforts to save energy and substitute fossil fuels.
In line with the country-specific recommendations 2022.4 focusing on reducing overall reliance
on fossil fuels and improving energy efficiency and country-specific recommendation 2023.4 to
step up energy efficiency in the transport sector, the updated plan makes a sizeable effort to
7
accelerate investments in climate-friendly mobility. The original RRP contains measures to
promote the sale of electric vehicles, supporting battery–electric vehicles. This effort was
complemented by support for the construction of charging infrastructure. The updated plan
includes a scale up of the measures 1.2.1 “Support for the construction of charging infrastructure”
and 1.2.3 “Support for the replacement of the private vehicle fleet“. The measures under
component 1.2 Climate-friendly mobility are expected to support Germany in reaching its GHG
emission reduction targets in the transport sector. The support scheme for e-vehicles (1.2.3) is
expected to directly boost demand for these types of passenger cars by means of targeted support,
while measure 1.2.1 is expected to improve the necessary charging infrastructure.
***
The nature and extent of the proposed modifications to Germany’s recovery and resilience plan
do not have a material impact on the previous assessment (rating of A) and the modified plan
contributes to addressing all or a significant subset of challenges identified in the country-specific
recommendations, or challenges in other relevant documents officially adopted by the Commission
under the European Semester, and of the adequacy of its response to the economic and social
situation of Germany.
3.3. Growth potential, job creation, economic, institutional and social resilience,
European Pillar of Social Rights, mitigating the impact of the crisis, and social
territorial cohesion and convergence
As part of the modification of the RRP, Germany has reinforced support for the charging
infrastructure and replacement of the private vehicle fleet and committed to a new measure
expanding district heating. All modifications contribute to reducing reliance on fossil fuels and
considering the geopolitical concerns regarding the availability of fossil fuel sources, this also
contributes to increasing the socio-economic resilience of Germany.
Stylised simulations by the Commission services estimate that the updated RRP, including the
increased financial contribution, together with the rest of measures of the European Union
Recovery Instrument, have the potential to increase the GDP of Germany by between 0.4 % and
0.8% by 2025, not explicitly including the possible positive impact of structural reforms.
***
The nature and extent of the proposed modifications to Germany’s recovery and resilience plan
do not have a material impact on the previous assessment (rating of A) and the modified plan does
not alter the plan’s impact on the growth potential, job creation, and economic, social and
institutional resilience of Germany, on contributing to the implementation of the European Pillar
of Social Rights, including through the promotion of policies for children and youth, and on
mitigating the economic and social impact of the COVID-19 crisis, thereby enhancing the
economic, social and territorial cohesion and convergence within the Union.
8
3.4. The principle of ‘do no significant harm’
Germany has submitted two scaled up measures, one related to the support to electric vehicles and
one related to charging infrastructure for electric vehicles that have already been assessed as
compliant with the do-no-significant-harm principle under the original RRP. In fact, the ambition
of the measures supporting electric vehicles has increased by restricting the scope of the measure
to purely electric vehicles as per the new funding guidelines from 17 November 2022 and entering
into force as of 1 January 20235
.
In addition, a new measure has been submitted that provides support for green district heating
systems. The measure does not provide support to heat sources using fossil fuels and focuses on
the integration of waste heat and renewable heat sources, such as thermal solar, heat pumps and
sustainable biomass. New green district heating networks have to be supported by at least 75%
renewable energy sources and waste heat, an ambition that goes beyond the definition of “efficient
district heating systems” as set out in Article 2(41) of the Energy Efficiency Directive. Beyond
this, the measure has been assigned a 100% climate coefficient under Intervention Field 034bis0
in accordance with the methodology set out in Annex VI to the RRF Regulation.
Taking into consideration the assessment of all the measures envisaged, no measure for the
implementation of reforms and investments projects included in Germany’s modified recovery and
resilience plan is expected to do a significant harm to environmental objectives within the meaning
of Article 17 of Regulation (EU) No 2020/852 (the principle of ‘do no significant harm’). This
would warrant a rating of A under criterion 2.4 of Annex V to the RRF Regulation.”
The nature and extent of those proposed modifications Germany’s recovery and resilience plan do
not have a material impact on the previous assessment (rating of A) and no measure for the
implementation of reforms and investment projects included in the modified plan is expected to do
a significant harm to environmental objectives within the meaning of Article 17 of Regulation (EU)
No 2020/852 (the principle of ‘do no significant harm’),.
3.5. Green transition
The updated plan continues to fulfil the elements corresponding to the assessment criterion 2.5 of
Annex V to the RRF Regulation6
. The updated plan continues to contain measures that effectively
contribute to the green transition, notably the climate change objectives.
The modified measures aid emission reduction and improve the sustainability in the transport
sector through the timely deployment of zero-emission vehicles and electric charging
infrastructure. The measure on federal funding for efficient heating networks aids emission
reduction in the heating and cooling sector through enabling the replacement of higher-carbon
alternatives, notably coal cogeneration plants, with heat from renewable sources and waste heat,
5
BAnz AT 09.12.2022 B1.
6
Regulation (EU) 2021/241.
9
and through decarbonising and expanding district heating and systems, thus increasing the
sustainability of energy infrastructure.7
The modified elements have indirect positive effects on
biodiversity through decreasing the emission of air pollutants both in the transport and in the
heating and cooling sectors and through their contribution to climate change mitigation.
In accordance with Article 17 of Regulation (EU) 2021/241, the updated RRP is consistent with
the information included in the National Energy and Climate Plan 2021-2030 (NECP). The federal
funding programme for efficient heating networks is explicitly mentioned in the NECP8
and aims
to contribute to achieving net-zero greenhouse gas emissions in the heating and cooling sector as
well as related sectors (building and industry) by 2045 as well as interim targets in the NECP and
the targets in Articles 23 and 24 of the revised Renewable Energy Directive9
.
In its recovery and resilience plan, Germany provides a table indicating for each measure whether
it contributes 0%, 40% or 100% to climate change or environmental objectives. Germany indicated
that the current climate and digital tracking should continue to apply to modified measures and
provided an additional table as well as justification for the new measure on federal funding for
efficient heating networks. The climate tracking of the modified elements at 100%, have been
assessed by the Commission as having been correctly assigned in accordance with the
methodology set out in Annex VI to the RRF Regulation (see also Annex 1 on climate tracking
and digital tagging). Thereby, the climate contribution of the plan increases from the original
42.4% to 47.0%.
Table 3: Climate contribution per component
Component
Total
cost
Climate
related Climate contribution
(EUR million)
(% of cost of
component)
(% of non-
repayable
allocation)
1.1 Decarbonisation using renewable
hydrogen in particular 3 708 3 708 100.0% 13.2%
1.2 Climate-friendly mobility 7 149 6 326 88.5% 22.6%
1.3 Climate-friendly renovation and
construction 2 574 2 523 98.0% 9.0%
2.1 Data as the raw material of the
future 2 684 150 5.6% 0.5%
2.2 Digitalisation of the economy 3 019 460 15.2% 1.6%
3.1 Digitalisation of education 1 206 0 0.0% 0.0%
4.1 Strengthening social inclusion 1 174 0 0.0% 0.0%
7
As supporting evidence to the submission of the modified plan, Germany provided a scientific study on the
envisioned district heating measure. As about three-quarters of district heating production is attributable to the direct
use of fossil fuels, in particular coal and gas power plants, and renewable energies for district heating are more costly
than fossil fuel alternatives (scientific study on district heating, p. 6), the investments envisioned under this measure
can be expected to make a targeted contribution to decarbonisation.
8
German Integrated National Energy and Climate Plan (2019), p. 44.
9
Renewable Energy Directive (2018/2001/EU).
10
Component
Total
cost
Climate
related Climate contribution
(EUR million)
(% of cost of
component)
(% of non-
repayable
allocation)
5.1 Strengthening of a pandemic-
resilient healthcare system 4 275 0 0.0% 0.0%
6.1 Modern public administration 2 920 0 0.0% 0.0%
6.2 Reduction of barriers to investment 42 0 0.0% 0.0%
Total 28 750 13 167 45.8% 47.0%
Note: The table shows the cost of the components without VAT. For some measures Germany indicated that the
gross costs may include VAT, which for this table was deducted assuming that the full VAT rate of 19% applies.
This results in a potentially lower estimate for the measure cost without VAT. Reflecting this, the contribution to
climate purposes is estimated to be at least 47.0%. For further details, please see the tagging at measure level in
Annex 1.
The nature and extent of the proposed modifications to Germany’s recovery and resilience plan
do not have a material impact on the previous assessment (rating of A) and the modified plan
contributes to the green transition and to the climate target.
***
3.6. Digital transition
The modified German RRP continues to follow the methodology for digital tagging set out in
Annex VII to the RRF Regulation, by identifying intervention fields, and corresponding
coefficients for the calculation of support to the digital objectives, for each measure (the table in
Annex I presents the detailed application of the digital tagging methodology). It should be noted
that the tagging and the estimated expenditure of existing measures has not been altered. On this
basis the assessment as reflected in the previous SWD(2021) 147 final is maintained for all
measures. The measures supporting digital objectives account for an amount which represents
48.1% of the modified RRP’s total allocation calculated in accordance with the methodology set
out in Annex VII of that Regulation.
Table 4 –Digital contribution per component
Component
Total
cost Digital related Digital contribution
(EUR million)
(% of cost of
component)
(% of non-
repayable
allocation)
1.1 Decarbonisation using renewable
hydrogen in particular 3 708 0 0.0% 0.0%
1.2 Climate-friendly mobility 7 149 0 0.0% 0.0%
11
Component
Total
cost Digital related Digital contribution
(EUR million)
(% of cost of
component)
(% of non-
repayable
allocation)
1.3 Climate-friendly renovation and
construction 2 574 0 0.0% 0.0%
2.1 Data as the raw material of the
future 2 684 2 684 100.0% 9.6%
2.2 Digitalisation of the economy 3 019 2 664 88.2% 9.5%
3.1 Digitalisation of education 1 206 1 206 100.0% 4.3%
4.1 Strengthening social inclusion 1 174 319 27.2% 1.1%
5.1 Strengthening of a pandemic-
resilient healthcare system 4 275 3 684 86.2% 13.1%
6.1 Modern public administration 2920 2920 100.0% 10.4%
6.2 Reduction of barriers to investment 42 0 0.0% 0.0%
Total 28 750 13 476 46.9% 48.1%
Note: The table shows the cost of the components without VAT. For some measures Germany indicated that the gross costs may
include VAT, which for this table was deducted assuming that the full VAT rate of 19% applies. This results in a potentially
lower estimate for the measure cost without VAT. Reflecting this, the digital contribution is estimated to be at least
48.1%. For further details, please see the tagging at measure level in Annex 1.
***
The nature and extent of the proposed modifications to Germany’s recovery and resilience plan
do not have a material impact on the previous assessment (rating of A) and the modified plan does
not alter the contribution of the plan to the digital transition and to the digital target.
3.7. Lasting impact of the plan
The updated RRP is expected to have an additional lasting impact in particular with regard
to the green transition. The modified RRP increases the ambition of the initial plan as a whole,
notably, the increased support for expanding the charging infrastructure and replacing the private
vehicle fleet may increase scale effects through accelerating the transition. The expansion of
district heating networks results in the provision of infrastructure contributing to energy efficiency
with a long lifetime. It aims to ensure the carbon neutrality of the heating network by 2045.
***
The nature and extent of the proposed modifications to Germany’s recovery and resilience plan
do not have a material impact on the previous assessment (rating of A) and the modified plan does
not alter the lasting impact of the measures proposed by Germany.
12
3.8. Milestones, targets, monitoring and implementation
The original assessment regarding ensuring effective monitoring and implementation of the
RRP remains mostly the same. The existing monitoring and control system for the updated
German RRP enables an adequate monitoring of the plan’s implementation. The structure tasked
with the implementation, monitoring and reporting of the RRP is still in place, the coordination
unit in the Federal Ministry of Finance and the line Ministries continue to have clearly assigned
responsibilities and adequate structure for implementing the plan, monitoring progress and
reporting. The overall arrangements proposed by Germany in terms of organisation of the
implementation of the reforms and investments remain credible. The milestones and targets that
accompany the new and modified measures, are clear and the proposed indicators for those
milestones and targets are relevant, acceptable, and robust.
At the same time, in its audit on the protection of the financial interests of the Union (PFIU) the
Commission found shortcomings regarding the staffing level of the coordinating body, and noted
that even if the coordinating body created an overview of measure implementation, it still has
difficulties to closely monitor and control the implementing bodies’ activities, potentially
emerging risks or hurdles related to the particular measures.
***
The nature and extent of the proposed modifications to Germany’s recovery and resilience plan
do not have a material impact on the previous assessment (rating of A) and the modified plan does
not alter the adequacy of the arrangements proposed by Germany to ensure the effective
monitoring and implementation of the plan.
3.9. Costing
Germany has provided detailed information on the estimated costs for the updated RRP,
including the new investment measure in component 1.1. The estimated costs of the new
investment and the scaled-up investments are reasonable and in line with the nature and type of
the envisaged investments. Most of the calculations are clearly explained and well substantiated
by supporting documents, allowing to identify the methodology used.
Reasonable costs
Germany accompanied its claims with actual data and supporting evidence for unit cost estimates,
together with adequate explanation for the calculation methodology. Overall, the assumptions used
by Germany to estimate the costs of the new and for the two measures where the level of required
implementation has been increased provide a reasonable explanation of the key cost drivers of the
measures. The calculations are generally clearly spelled out allowing to identify the methodology
used.
Plausible costs
13
Most of the estimated costs of the new and the two measures where the level of required
implementation has been increased are in line with the nature and the type of the envisaged
investments. Overall, the cost estimates of the new measure and the measures where the level of
required implementation has been increased, are assessed as plausible.
No double funding Germany has indicated that the costs to be financed by the RRF will not be
funded by other Union funding sources. More specifically, Germany committed to ensure that no
double funding with other funding instruments will occur in the case of complementary actions
are undertaken by other Funds as it may be the case with the complementary funding by the
European Regional Development Fund (for energy efficiency measures /heat networks).
Commensurate and cost-efficient costs
The estimated total costs of the updated RRP are in line with the principle of cost-efficiency and
are commensurate to the expected national economic and social impact. The updated RRP,
including the new investment and the two up-scaled measures, is expected to effectively address a
significant subset of challenges identified in the country-specific recommendations (CSRs). In
particular the new measures and the up-scaled measures are expected to address challenges
identified in CSRs in the field of energy and green transition, notably the modified plan addresses
the country-specific recommendations 2023.4 and 2022.4 focusing on energy efficiency measures
in buildings, including through investment in heating systems as well as the country-specific
recommendation 2022.4 focusing on reducing overall reliance on fossil fuels and improving
energy efficiency and country-specific recommendation 2023.4 specifically mentioning energy
efficiency in the transport sector.
***
The justification provided by Germany on the amount of the estimated total costs of the modified
recovery and resilience plan is to a medium extent reasonable, plausible, in line with the principle
of the cost-efficiency and is commensurate to the expected national economic and social impact.
Germany provided sufficient information and evidence that the amount of the estimated cost of the
reforms and investments of the modified recovery and resilience plan to be financed under the
Facility is not covered by existing or planned Union financing.
This would warrant a rating of B under criterion 2.9 of Annex V to the RRF Regulation.
3.10. Controls and audit
The previous assessment on the adequacy of the control and audit arrangements presented by
Germany in the RRP to prevent, detect and correct corruption, fraud and conflicts of interest when
using the funds provided under the Facility, including the arrangements aimed to avoid double
funding from the Facility and other Union programmes, had concluded that these arrangements
are adequate. This warranted a rating of A under the assessment criterion 2.10 of Annex V to the
RRF Regulation.
14
The modifications to the original plan as such do not affect the original assessment. However, in
the context of the modification of the German RRP, its audit and control system needs to be
reassessed on the basis of criteria 2.10 of Annex V of the RRF Regulation.
Robustness of internal control system and distribution of roles and responsibilities
The original assessment finding that the internal control system is robust, with a clear distribution
of roles and responsibilities, and the bodies are independent in their functioning, remains the same.
Adequacy of control systems and other relevant arrangements
The original assessment regarding the adequacy of the control systems and other relevant
arrangements remains mostly the same.
Adequacy of arrangements to avoid double EU funding
The original assessment regarding the adequacy of the control systems and other relevant
arrangements remains mostly the same.
Legal empowerment and administrative capacity of control function
The original assessment regarding the adequacy of the control systems and other relevant
arrangements remains mostly the same.
Conclusion
The chapter of the plan on audit and control and the additional information provided gives a rather
complete description of the arrangements for the implementation and control of Germany’s RRP.
The chapter provides the details for all the entities and gives reasonable assurance that there is a
sound structure in place to monitor, implement and control the allocated funds from the RRF.
***
The nature and extent of the proposed modifications to Germany’s recovery and resilience plan
do not have a material impact on the previous assessment (rating of A) and the modified plan does
not alter the adequacy of the control and audit arrangements proposed by Germany.
3.11. Coherence
The original RRP is structured around 10 components. Within each component, the reforms and
investments are targeted to achieve coherent objectives and their expected results reinforce each
other. The planned actions in the different components are also coherent and complementary, with
structural reforms accompanying planned investments in order to reinforce their impact. Further,
there is consistency and intrinsic complementarity among the measures from different
components. In order to promote greater consistency among instruments, and in particular with the
European cohesion policy funds, a balanced territorial allocation of resources was encouraged.
The original assessment concluded that the RRP included to a high extent (Rating A) measures for
the implementation of reforms and public investment projects that represent coherent actions.
15
The modification to the RRP concerns two of the existing components, including one new measure
and the scaling up two existing measures. The proposed modifications made to the existing
components do not alter the overall coherence of the plan, considering the way the components
are mutually reinforcing and complementary. The proposed modifications further reinforce the
reduction of greenhouse gas emissions and promote the use of renewable energy, which is
particularly important in the context of reducing dependency on fossil fuels. The modifications do
not have contradictory aims or possible negative effects on one another.
***
The nature and extent of the proposed modifications to Germany’s recovery and resilience plan
do not have a material impact on the previous assessment (rating of A) and the modified plan does
not alter the coherence of the actions proposed by Germany.
16
ANNEX I: CLIMATE TRACKING AND DIGITAL TAGGING 10
Measure
ID
Measure/Sub-Measure Name
Budget
(EUR m)
Climate Digital
Int. Field Coeff.
Int.
Field
Coeff.
1.1.1.1
Hydrogen projects within the framework
of IPCEIs: part 1
500 022 100%
1.1.1.2
Hydrogen projects within the framework
of IPCEIs: part 2
500 027 100%
1.1.1.3
Hydrogen projects within the framework
of IPCEIs: part 3
500 033 100%
1.1.2
Funding programme for decarbonisation
in industry
449.3 022 100%
1.1.3
Pilot scheme for climate action contracts
based on the principle of Carbon
Contracts for Difference
550 027 100%
1.1.4
Project-related climate protection
research
50.4* 022 100%
1.1.5
Flagship projects for research and
innovation in the context of the National
Hydrogen Strategy
588.2* 022 100%
1.1.6
Federal support for efficient heat
networks (BEW)
570 034bis0 100%
1.2.1
Support for the construction of charging
infrastructure
960.1 077 100%
1.2.2.1
Funding for the development of electro-
mobility: R & D, mobility concepts
42* 022 100%
1.2.2.2
Funding for the development of electro-
mobility: zero-emission vehicles
21* n/a** 100%
1.2.3.1
Support for the replacement of the private
vehicle fleet: zero-emission vehicles
2 764 n/a** 100%
1.2.3.2
Support for the replacement of the private
vehicle fleet: hybrid vehicles.
1 296 n/a** 40%
1.2.4
Extension of the initial registration period
for granting the ten-year tax exemption
for purely electric vehicles
295 n/a** 100%
1.2.5
Support for purchases of buses with
alternative propulsion
1 085 na** 100%
1.2.6.1
Support to promote alternative rail
propulsion: electric rolling stock
182 072bis 100%
1.2.7.1
Promotion of the industries involved in
hydrogen and fuel cell applications in
transport: part 1
229.4* 022 100%
1.2.7.2
Promotion of the industries involved in
hydrogen and fuel cell applications in
transport: part 2
229.4* n/a** 100%
1.3.2
Municipal living labs for the energy
transition
57 025 40%
10
While the total cost of Germany’s recovery and resilience plan exceeds the total allocation of non-repayable
financial support to Germany, Germany will ensure that all spending related to the investments mentioned in the
following table as contributing to climate objectives are fully financed by the funds from the Recovery and Resilience
Facility.
17
Measure
ID
Measure/Sub-Measure Name
Budget
(EUR m)
Climate Digital
Int. Field Coeff.
Int.
Field
Coeff.
1.3.3
Building renovation: federal funding for
energy-efficient buildings
2 500 025bis 100%
2.1.1.1
Innovative data policy for Germany:
overall strategy high-performance
computing
21*
021quat
er
100%
2.1.1.2
Innovative data policy for Germany: ideas
competition and piloting of data
fiduciaries
45.4* 009bis 100%
2.1.1.3
Innovative data policy for Germany:
research network depersonalisation
37.8* 009bis 100%
2.1.1.4
Innovative data policy for Germany:
support programme anonymisation
25.2* 009bis 100%
2.1.1.5
Innovative data policy for Germany:
National Research Data Infrastructure
(Nationale Forschungsdaten-
infrastruktur) and data literacy
50.4* 108 100%
2.1.1.6
Innovative data policy for Germany: PhD
programme in data sciences
5.5* 108 100%
2.1.1.7
Innovative data policy for Germany:
incentives for the after-use of data
4.2* 108 100%
2.1.1.8
Innovative data policy for Germany:
long-term competence monitoring
8.0* 108 100%
2.1.1.9
Innovative data policy for Germany: data
literacy courses for students
8.8* 108 100%
2.1.1.10
Innovative data policy for Germany:
toolbox data literacy
8.4* 108 100%
2.1.1.11
Innovative data policy for Germany:
innovation process ‘architectures,
institutions and spaces for the data
society’
6.7* 108 100%
2.1.1.12
Innovative data policy for Germany:
establishment of data cooperations
11.3* 011 100%
2.1.1.13
Innovative data policy for Germany: data
literacy in the federal administration: data
laboratories, Chief Data Scientists and
competence building
200.8* 108 100%
2.1.2
IPCEI microelectronics and
communication technologies
1 500
021quat
er
100%
2.1.3.1
IPCEI Next Generation Cloud
Infrastructure and Services (IPCEI CIS):
emission reduction and energy efficiency
criteria
375 055bis 40%
021quat
er
100%
2.1.3.2
IPCEI Next Generation Cloud
Infrastructure and Services (IPCEI CIS)
375
021quat
er
100%
2.2.1.1
Vehicle manufacturer/supply industry
investment programme: digitalisation of
production as a boost for productivity and
resilience: greenhouse gas emission
reduction or energy efficiency criteria
650 010ter 40% 010ter 100%
2.2.1.2
Vehicle manufacturer/supply industry
investment programme: digitalisation of
427.1 010ter 100%
18
Measure
ID
Measure/Sub-Measure Name
Budget
(EUR m)
Climate Digital
Int. Field Coeff.
Int.
Field
Coeff.
production as a boost for productivity and
resilience
2.2.1.3
Vehicle manufacturer/supply industry
investment programme: new innovative
products as the key to vehicles and
mobility of the future - automated driving
392.67 009bis 100%
2.2.1.5
Vehicle manufacturer/supply industry
investment programme: finding joint
solutions, building regional innovation
clusters
232.4 019 40%
2.2.2
Federal programme ‘Building continuing
education and training networks (CET
networks)’
31.9* 016 40%
2.2.3
Digitalisation and Technology Research
Centre of the Bundeswehr (dtec.bw)
588.2* 009bis 100%
2.2.4
Promoting the digitalisation of rail by
replacing conventional interlocking/fast-
track programmes to speed up the roll-out
of the ‘Digital Rail Germany’ (SLP)’
500 070 40% 070 100%
3.1.1
Investment programme for teacher
devices
420.2* 012 100%
3.1.2 Education platform 529.4* 012 100%
3.1.3 Educational centres of excellence 172.3* 108 100%
3.1.4
Modernisation of the Federal Armed
Forces’ educational and training facilities
84* 012 100%
4.1.3 Apprenticeships support 725 099 40%
4.1.5 Digital pension overview 28.8* 011 100%
5.1.1
Strengthening the digital and technical
resources of the public health service
684* 011 100%
5.1.2 Programme to future-proof hospitals 3 000 095 100%
6.1.1 European identity ecosystem 168.1* 011 100%
6.1.2
Digitalisation of the administration –
implementation of the Online Access Act
2 521* 011 100%
6.1.3
Digitalisation of the administration –
modernisation of registers
231.1* 011 100%
* Budget figures are rounded to hundred thousands. The table shows the cost of the measures without VAT. For most measures
this equals the cost included in the recovery and resilience plan. However, for measures marked with an asterisk (*), Germany
indicated that their cost may include VAT, and in this table the cost is shown while taking away the full amount of potential VAT
for these measures (assuming that the maximum VAT rate of 19% fully applies). For the original plan in 2021 Germany submitted
two cost estimates. Using the same categories, the amended RRP has a gross value of EUR 30 181 006 986 that includes VAT for
some measures, while a net value of at least EUR 28 749 958 599 excludes VAT.
** The ‘Methodology for climate tracking’ annexed to the Recovery and Resilience Facility Regulation does not set out intervention
fields that would allow for climate or environmental tracking of electric vehicles or plug-in hybrid vehicles, except for vehicles for
urban transport falling under intervention field 074. According to Article 18(4)(e) of the Regulation, the methodology should
however ‘be used accordingly for measures that cannot be directly assigned to an intervention field listed in Annex VI’. In this
context, the Commission has applied a 100% climate contribution coefficient for zero-emission vehicles of all categories (this
includes battery electric and fuel cell/hydrogen-powered vehicles); a 40% climate contribution coefficient for plug-in hybrid light-
duty vehicles; and, in line with the criteria under the Taxonomy Regulation, a 100% climate coefficient for low-emission heavy-
duty vehicles.