Changes from plenary report to adopted text

Court’s observations

250. Notes that the Court issued a qualified opinion on the legality and regularity of the RRF expenditure for the third consecutive year, following similar conclusions in 2022 and 2023; notes that in 2024, the Court sampled 395 milestones and targets (M&Ts) across 28 grant payments, covering EUR 53,5 billion out of a total EUR 59,9 billion disbursed in 2024 and, while the Court does not provide an error rate due to the RRF’s specific spending model, it estimates that the minimum financial impact of its findings exceeds the materiality threshold; notes with alarm the increasing trend in the overall financial impact of quantitative findings; expresses concerns that, according to the Court’s conclusion, six out of 28 RRF grant payments made in 2024 were affected by quantitative findings, and that five of these payments were affected by material error; notes that in the Court’s opinion, aside from these matters, the RRF expenditure accepted in the 2024 accounts is legal and regular in all material respects;

251. Notes with concern that the Court identified six milestones in five payments that had not been satisfactorily fulfilled; notes that in these cases, the missing elements represented more than a minimal acceptable deviation and that the Commission nevertheless proceeded with the corresponding payments; further notes that in one of the six cases, the Commission in its preliminary assessment relied on data and checks provided by the Member State without performing additional testing to verify their reliability;

252. Notes furthermore that the Court identified an additional 12 cases of weaknesses in the Commission’s assessment which, although they did not impact the satisfactory fulfilment of the milestone or target concerned, revealed that the Commission had not carried out sufficient checks to assess the reliability of data and checks provided by Member States;

253. Notes that, under the RRF, payments by the Commission to Member States are conditional on the satisfactory fulfilment of agreed milestones and targets, rather than on the verification of compliance of individual expenditures with Union and national rules, which makes it challenging to assess compliance with the applicable legal requirements; also notes that the RRF Regulation does not specify criteria for interpreting the term “satisfactory” in relation to the fulfilment of milestones and targets, and that, in the case of qualitative criteria, this assessment depends on multiple judgments, leading to various possible interpretations as to whether milestones or targets have been satisfactorily met; further notes that cases of vaguely defined milestones or targets, which have been identified, result in the criteria for assessing their fulfilment remaining unclear;

254. Notes the Court also identified four cases of vaguely defined milestones or targets, which had also been acknowledged and documented by the Commission in its preliminary assessment; notes that when milestones and targets are defined in vague terms, the criteria for assessing their fulfilment inevitably become vague as well, undermining the robustness and clarity of the assessment process; notes the Commission acknowledges that in some cases milestones and targets set by the Council Implementing Decisions could have been drafted more clearly;

255. Recalls that the RRF super milestones for Poland mandated specific reforms in the field of justice including firstly, the dismantling of the Disciplinary Chamber of the Supreme Court and its replacement by an independent Chamber of the Supreme Court, and secondly, that all judges affected by the rulings of the Disciplinary Chamber had the right to have their case reviewed by the new Chamber within a clear timeframe; is concerned by the continued refusal of the Polish president to sign into law the reforms proposed in 2025 by the Polish Government and adopted by the Polish Parliament concerning the rule of law which aim to implement the recommendations of the European Commission regarding the fulfilment of the judicial milestones under the Recovery and Resilience Plan (RRP); stresses that the fulfilment of judicial-independence milestones, in line with Union law, including the case-law of the European Court of Justice, is essential to ensure legal certainty and protect the Union budget;

256. Notes that the Court has found that projects relating to one milestone and three targets in two payments had begun before the eligibility period; notes that the Regulation stipulates that only measures which started from 1 February 2020 onwards may be financed under the RRF, but does not further define what constitutes the ‘start’ of a measure; notes that, in January 2021, the Commission issued guidance interpreting the ‘start’ of a measure as the beginning of its implementation on the ground, when costs materialise; acknowledges that the Court considers the start of a measure to be the date of the first legal commitment (e.g. contract, purchase order, or financing decision), which constitutes the start of the first activity related to the measure, while the Commission considers the start as the beginning of implementation on the ground when costs materialise; recognises the existence of different interpretations of what constitutes the ‘start’ of a measure under the RRF;

257. Notes that outstanding Union borrowing increased by more than 30 % in 2024, reflecting the Commission’s expanded use of capital markets to finance large-scale programmes such as SURE and NGEU; notes that by 2027 total outstanding borrowing could exceed EUR 900 billion, almost ten times the level recorded in 2020 prior to the launch of NGEU; notes that since December 2022 the Commission has applied a diversified funding strategy as its standard method for raising funds on capital markets, and that at the end of 2024 the nominal value of outstanding Union borrowing stood at EUR 601,3 billion, up from EUR 458,5 billion in 2023; is concerned that the rising level of debt and the associated increase in interest costs will have long-term implications for the Union’s fiscal stability, potentially resulting in greater financial strain and reducing the Union’s capacity to respond to future challenges or invest in key strategic priorities;

258. Notes with concern that annual NGEU-financed RRF grant payments amounted to EUR 55,9 billion in 2024, reaching only around half of the level expected by the Commission in June 2023 (EUR 96,0 billion), reflecting persistent delays in the submission and processing of payment requests; notes, however, that momentum increased toward the end of the year, with 15 Member States submitting payment requests totalling EUR 58,5 billion in December 2024;

259. Notes that by the end of 2024, payments under the RRF amounted to EUR 197,5 billion out of EUR 358,9 billion in committed grants, leaving up to EUR 161,4 billion still to be disbursed by the end of 2026; notes that this substantial volume of outstanding payments, concentrated in the final two years of the instrument, increases the risk of implementation bottlenecks and further delays, particularly in Member States facing structural capacity constraints; stresses that the timely absorption of the remaining RRF grants will depend on the quality and maturity of reforms and investments, the stability of national governance systems, the availability of administrative capacity and technical support, and the Commission’s ability to process a high volume of payment requests efficiently within a compressed timeframe;

260. Notes the Court’s finding that RRF grants implementation was lower than expected, while NGEU top-up absorption accelerated in 2024; notes that annual payments of RRF grants totalled EUR 55,9 billion in 2024, of which EUR 7,9 billion was financed from REPowerEU and EUR 48,0 billion from NGEU grants, and that the annual payments for NGEU-financed RRF grants were only half what the Commission had expected in June 2023 (EUR 96 billion); highlights, however, that 15 Member states had submitted payment requests totalling EUR 58,5 billion in December 2024; notes that with payments by the end of 2024 of EUR 197,5 billion out of EUR 358,9 billion of commitments made, RRF grants of up to EUR 161,4 billion remain available to be paid by the end of 2026;

261. Notes with concern the Commission’s acknowledgment, in its report of 8 October 2025 on the implementation of the RRF, that the pace of implementation differs significantly among Member States, with only six Member States having received payments corresponding to more than 65 % of their total RRF envelope and another four Member States having received more than 50 % of their allocation; expresses concern about the substantial disparities in the absorption of RRF grants to date; stresses that, with less than six months remaining until the August 2026 deadline, the timely and effective implementation of reforms and investments by Member States has become increasingly urgent;

262. Stresses its concern about the Court’s findings in Special Report 22/2024 on double funding resulting from the RRF model; highlights that Member States national plans may include so-called ‘zero cost measures’, i.e. measures estimated to have no costs to be financed by the RRF, and for which no checks for double funding are carried out, as the Commission considers that measures receiving no RRF funds pose no such a risk; notes that the Court reported potential cases of double funding in relation to RRF measures; recalls that the reported finding in Croatia concerns such a zero-cost measure, and that neither the Commission nor the Member State consider that any RRF funds were duplicated; underlines that the Court’s finding reflects a different interpretation of what constitutes “funded” rather than actual double funding; nevertheless stresses that ‘zero-cost measures’ and the absence of systematic cross-checks create a structural blind spot which requires strengthened monitoring and guidance; calls on the Commission to continue monitoring and providing guidance to Member States on the application of the double funding rules, while acknowledging the legal and methodological framework established in the RRF Regulation;

263. Recalls that the Regulation stipulates that, measures and actions relating to previously fulfilled milestones and targets must not have been reversed, and that Member States are required to confirm this non-reversal in the management declarations accompanying their payment requests; deplores the RRF legal framework does not allow the Commission to effectively address reversals after 31 December 2026;

264. Underlines that, in line with Article 12(1) of the Financing Agreement and Article 21(1) of the Loan Agreement, the Commission ‘may carry out verifications, reviews, checks and audits for the implementation of the RRP regarding the information and justification regarding the satisfactory fulfilment of milestones and targets in a payment request’, and that such verifications, reviews, checks and audits may be carried out for a period after the RRF has expired and could help identify cases where information underlying the payment request as submitted by a Member State was not correct;

265. Notes that, under the European Semester, the implementation of measures set out in the medium-term fiscal-structural plans is monitored annually, with Member States submitting progress reports to the Commission; notes that, in line with the guidance to Member States on the information requirements for the medium-term fiscal-structural plans and for the annual progress reports, for the lifetime of the RRF, these reports are required to include information on progress in implementing any of the RRP reforms and investments included in the medium-term fiscal-structural plans; underlines that these reports are essential to ensure transparency, accountability, and the effective use of Union funds, and calls on the Commission to verify that Member States provide complete, timely, and accurate information in line with the objectives of the RRF;

266. Notes that since 2021, the Commission has issued 20 final audit reports covering milestones and targets, containing 591 recommendations to 15 Member States; expresses particular concern that for most (64 %) of the 136 recommendations related to critical and very important findings, the implementation deadline set in the audit report had already passed; notes the Commission acknowledgement that such delays in implementation by some Member States represent 22 % of the total recommendations related to critical and very important findings; notes, further, the Commission’s acceptance of the Court’s recommendation to analyse the reasons for delays in implementation by Member States and its ongoing review of the status of all outstanding recommendations; expects it to urgently address delays in implementing the Commission’s recommendations from the ex-post audits;

267. Recalls that control milestones continued to be added by the Commission following the detection of Member States’ weaknesses in their control systems; notes the Court’s observation that while the Commission has enhanced its checks on public procurement and state aid, Member States’ control systems remain insufficiently effective to ensure compliance; notes the Court identified weaknesses, which pose a risk to the protection of the Union’s financial interests, in 22 individual public procurement procedures including lack of checks to prevent or detect conflicts of interest, weaknesses in justifying the use of urgent procedures and weaknesses in estimating the procurement value and project duration leading to significant differences between the tender documents and the actual contracts signed; notes that the Commission is reviewing its guidance to Member States with a view to improving the related controls at national level; underlines that while compliance with public procurement and state aid rules generally has no bearing on the regularity of RRF payments made by the Commission to Member States, these rules are crucial for ensuring a fully functioning internal market; considers, therefore, that funding must be subject to compliance with applicable internal market rules; recognises the acknowledgement by the Commissioner for Budget, Anti-Fraud and Public Administration during his hearing in the Committee on Budgetary Control on 8 December 2025 that one of the weaknesses which cannot be repeated is the fact that rules on public procurement and state aid are not included as conditions for payment, and the Commission’s commitment to correct this under the next MFF;

268. Notes the Court identified weaknesses, for five Member States, in their management declarations, which are to provide assurance that the information submitted with the payment requests is complete, accurate and reliable; notes the Court’s finding that the five Member States, including Czechia, Spain, France, Croatia and Slovakia, were aware of insufficient evidence for the satisfactory fulfilment of some milestones and targets when submitting the payment request, but that none of them included any reservation in their management declaration highlighting that a milestone/target was only partially fulfilled at the time of the payment request;

269. Expresses concern about the Court’s findings in Special Report 21/2025 ‘RRF support for an improved business environment’; highlights that reforms set out in the national plans differ in scope, nature and ambition, and may not always translate into structural changes in the business environment; also expresses disappointment that milestones and targets are generally limited to measuring legal ‘outputs’, mostly the adoption of laws, rather than their results, and therefore, the payment conditions were fulfilled once the laws were adopted, not when the laws have shown their effects; notes that many reforms were already envisaged before the RRF, but that the RRF’s financial support helped ensuring that the reforms were implemented at that moment in time;

Audit and control

270. Notes the Court’s observation that, as regards serious irregularities not corrected by the Member State, the Director-General of DG ECFIN qualified its assurance with a reservation following the high risk identified in one Member State, namely Czechia, due to two individual cases of conflict of interest for which there is no information on further corrective action taken by Czechia at this stage and for which the Commission had not yet launched corrective actions; notes that this reservation concerns two RRF payments, and that the Commission also assessed 22 payments as medium risk and six payments as low risk of serious irregularities; notes with concern the Court’s view that, as the risk assessment criteria are broadly aligned with those applied for checks in areas such as public procurement and state aid, the overall assessment may not fully capture the level of underlying risk;

271. Is concerned by the Court reporting that information available to the Commission on detected fraud is limited and underlines the need to improve information flows with a view to ensuring the protection of the financial interests of the Union, particularly through enhanced precautionary measures; highlights that, at the end of 2024, the EPPO was handling 311 active cases related to NGEU, and that all but four of these concerned the RRF, representing approximately 17 % of all active expenditure fraud investigations; notes that the estimated damage to the Union’s financial interests is EUR 2,8 billion, representing 30 % (2023: 25 %) of the overall estimated damage resulting from all Union expenditure fraud; highlights, however, that the EPPO had only officially notified the Commission of 75 cases related to the RRF, and that 80 % of these notified cases related to one measure in a single Member State, Italy; also notes the EPPO finding that national law enforcement authorities remained the main source of reporting, with 90 % of the new investigations opened based on their information; also notes from the Court’s Special Report 06/2026 ‘Tackling fraud in the RRF’ that Member States had reported 51 cases of suspected fraud to DG ECFIN from the start of the RRF in 2021 until end of 2024; is concerned that reports from Union institutions, bodies, offices and agencies, including the Commission, account for less than 1 % of the new EPPO investigations opened in 2025, raising further concerns on the Commission’s ability to oversee the RRF; is also alarmed that since the RRF implementation is less than halfway to completion, EPPO expects the number of cases will continue to grow; stresses that the figures presented by the EPPO confirm that the risk of fraud is present in the RRF; stresses that this situation showcases the need to further strengthen national detection and reporting capacities, the cooperation with the EPPO and the Commission, and the overall effectiveness and consistency of anti-fraud systems across the Union; emphasises that protecting the Union's funds and taxpayers’ money requires a robust, coordinated and well-resourced anti-fraud framework at both Union and national level;

272. Welcomes the reforms carried out by Bulgaria and the progress achieved in 2025, during which the country received approximately 31 % of its total allocated RRF funding through two tranches amounting to EUR 1,91 billion; acknowledges key reforms in the area of public procurement and judicial transparency; notes that, on 3 November 2025, the Commission adopted an Implementing Decision on the partial suspension of the disbursement of the second instalment of the non-repayable support for Bulgaria as one milestone related to the anti-corruption reform had not been deemed fulfilled satisfactorily; acknowledges the efforts undertaken by the Bulgarian government to introduce reforms aiming to ensure a politically independent appointment of the Anti-corruption Commission; notes that the Commission’s Implementing Decision further acknowledges that the National Assembly retains a predominant role in both the nomination and appointment of the management of the Anti-corruption Commission; notes that Bulgaria has six months to revise the legislative framework to reach the required threshold; underlines that the suspension should only be lifted when Bulgaria has taken the necessary measures to ensure satisfactory fulfilment of the milestone;

273. Notes the Court’s repeated findings of certain national audit authorities’ shortcomings in terms of scope, quality, documentation and reporting; stresses the need for a clear framework of responsibilities to guarantee quality and consistency; insists that audit bodies in Member States comply with internationally accepted audit standards; warns that failure to do so undermines the reliability of their work and poses risks to the Single Audit approach;

274. Regrets the incomplete audit trails observed by the Court in the RRF, which weaken traceability and limit the ability of Parliament and the Court to exercise scrutiny; stresses that all Commission databases and information systems used for the collection, exchange and monitoring of data between the Commission and the Member States must be accessible to the Court; underlines that the Court should have direct and prompt access to the original data as recorded in the system, without prior modification, aggregation or editing by national authorities or Commission services; emphasises that such access is essential to ensure the independence, reliability and effectiveness of audits and to uphold transparency and accountability in the implementation of the Union budget;

275. Expresses concern that audits of RRF and other performance based instruments focus on system audits rather than controls on actual expenditure incurred; warns that such system audits may not reveal underlying issues which can spill over and seriously undermine the sound financial management of the Union budget and the protection of the financial interest of the Union; calls on the Commission to take decisive corrective measures, strengthen audit and accreditation procedures, and ensure that similar systemic failures cannot recur, while respecting the principle of proportionality regarding reporting and documentation duties;

276. Considers that the RRF constitutes a constitutional test for democratic accountability, given its size, speed and exceptional delivery model; recalls that the RRF is financed through substantial common European borrowing and therefore requires the highest standards of financial responsibility, transparency and value for money for Union taxpayers; stresses that Parliament’s role as discharge authority is meaningful only if transparency, traceability, objective application of the rules and verification standards are applied rigorously and consistently across all Member States and if the assessment of milestones and targets is carried out in a fully objective and non-politicised manner ensuring equal treatment of Member States; considers that any shift towards performance-based instruments must be accompanied by parliamentary scrutiny in order to guarantee democratic accountability; opposes any proposal that would upset the institutional balance and undermine Parliament’s role as discharge authority;

Transparency

277. Notes that for 2024 the Court assessed the national systems of five Member States to assess whether they were capable of tracking RRF funds from the national budget down to final recipients and beyond, as well as providing data on expenditure incurred by final recipients; notes the Court’s observation that traceability of RRF funds is not systematic across Member States, and that the systems in place in two Member States did not ensure the systematic collection of data on expenditure incurred by final recipients of RRF funds; regrets the Court’s finding that, despite the Commission’s guidance on the methodology to be followed by Member States for publishing the 100 biggest final recipients, significant variations in the type of information published occur; expresses serious concern that such shortcomings in transparency and traceability risk undermining public trust and effective democratic scrutiny of RRF expenditure; also notes that two Member States reported amounts allocated (i.e. budgeted) or disbursed but in some cases only to the level of intermediate bodies, and in some cases combined with national funding, and that one Member State only reported data related to measures with milestones and targets submitted for payment to the Commission, which did not fully reflect implementation of ongoing measures;

278. Recalls that Article 22(2)(d)(ii) of the RRF Regulation (EU) 2021/241 obliges Member States, for the purpose of audit and control, to collect comparable information on the use of RRF funds, including on the names of final recipients, contractors and sub-contractors, and beneficial owners; recalls, further, that while the Regulation does not oblige Member States to collect and publish information about expenditure incurred by final recipients in pursuit of milestones or targets nor to provide such information with their RRF payment requests, they are however required to publish this information about the 100 ‘final recipients’ receiving the largest amounts of funding under the RRF; notes that the Commission position, presented in its Guidance on Recovery and Resilience Plans, describes a final recipient as the ‘last entity receiving funds that is not a contractor or subcontractor’; expresses deep concern over this interpretation of the concept of ‘final recipient’, and reiterates its view that this contradicts the existing legislation; stresses that it expects the Commission to enforce compliance with existing legislation and to use all means at its disposal to ensure that Member States provide, a complete and meaningful list of final recipients, excluding merely intermediary entities such as ministries or managing authorities; underlines that, to ensure transparency, the Parliament will consider all available measures to enforce compliance, and to prevent a similar interpretation from being applied to the transparency provisions in other financial regulations; considers that persistent failure to ensure meaningful publication of final recipients seriously calls into question the Parliament’s ability to grant discharge on an informed basis recalls that the Parliament has repeatedly raised serious concerns in previous discharge resolutions regarding the RRF, including on the transparency of final recipients; considers that the Commission should start infringement proceedings and that it should act without undue delay to fully exercise its powers as guardian of the Treaties against Member States to ensure that citizens and stakeholders have full access to this information; should it fail to do so, Parliament will consider all appropriate measures within its prerogatives to ensure compliance, including legal action; stresses that full and reliable information on the final recipients is essential in order to prevent misuse of funds, detect fraud and ensure equal standards of accountability across all Member States;

279. Reminds the Commission that the letter and spirit of the RRF Regulation must be strictly followed, and that the adoption of guidelines or other internal documents must be fully in line with the results of the negotiations between the co-legislators; believes that this has not been the case when the Commission adopted the provisions related to the interpretation of what a ‘final recipient’ is in its Guidance on RRPs;

280. Highlights furthermore that, on 4 February 2025, for the purposes of discharge under Article 319 TFEU, Members of the Committee on Budgetary Control requested that the Commission provide for each Member State the list of the 100 largest natural persons or entities receiving funds under the RRF, including contractors and subcontractors; finds it unacceptable that only six Member States shared the requested data with the Commission services, and that a Member State expressed its intention to share the list in the future, while three other Member States indicated they would not submit the data, claiming that the request was not in line with the reporting requirements under the RRF Regulation, while the remaining 17 Member States failed to react to the Commission’s request;

281. Highlights the RRF's crucial contribution to preventing a severe economic downturn and social crisis following the COVID-19 pandemic and its ability to provide a strong crisis response tool;

Recommendations

282. Calls on the Commission to act on the Court’s recommendations from its 2024 Annual Report to ensure that the Commission:

(i) perform sufficient substantive testing to ensure the reliability of the information supporting the Member States’ compliance with the Council Implementing Decisions requirements when assessing milestones and targets supported primarily by monitoring or implementation reports, instead of relying on Member States’ data and checks;

(ii) analyse the reasons for delays for the implementation by Member States of recommendations linked to critical or very important findings and consider applying flat rate reductions;

283. Furthermore, calls on the Commission to:

(i) closely monitor the continued fulfilment of milestones and targets, in particular those related to audit, monitoring and control, and ensure an adequate monitoring of the state of implementation of various milestones and targets at different point in time after the expiry of the RRF with the options provided under the Financing and Loan Agreements and the European Semester;

(ii) work closely with Member States to ensure that milestones and targets, in particular those of a structural nature or linked with CSRs, are fully and diligently implemented;

(iii) implement stricter verification mechanisms to prevent the inclusion of pre-existing projects that do not provide added value under the RRF framework;

(iv) ensure full compliance with the RRF milestones and only disburse funding if milestones continue to be met;

(v) establish, without any further delay, a binding interinstitutional arrangement ensuring the Court’s full, systematic and real-time access to all the relevant databases including Arachne and Fenix;

(vi) consistently and accurately apply the provisions related to the ‘final recipients’ of the RRF Regulation by revising its Guidance on RRPs, to communicate with Member States on the correct application of the definition of ‘final recipients’, to ensure Member States collect and provide information on the last entities receiving funds, excluding intermediary entities such as ministries or managing authorities, making this information available to the discharge authority by the last RRF payments’ deadline, and start infringement proceedings if necessary;

(vii) ensure greater transparency in the RRF through the timely publication of Commission assessments, national reports, audits and recovery actions in an accessible and verifiable format, enabling proper scrutiny by Parliament, the Court and citizens; supports a layered approach to access—full real-time access for the Court, unrestricted information rights for Parliament, and transparent public access in line with CJEU rulings—while ensuring compliance with GDPR and Union data protection rules; stresses that published data must reflect actual project implementation and results;

(viii) ensure consistent performance information, in the post-2027 MFF, by establishing a single set of clearly defined policy areas and a consistent methodology to link challenges, objectives, measures, funding and performance indicators to one or more policy areas, including through the use of harmonised reporting frameworks and measurable, comparable indicators across all Member States, enabling a clear assessment of results, efficiency and value for the Union's funding;

(ix) strictly apply the provisions of the RRF Regulation, including those regarding suspension of payments or recoveries of amounts, in particular if the protection of the financial interests of the Union is not ensured;

(x) mandate interoperable, automated cross-checks across RRF, cohesion and direct management instruments and to report annually to the discharge authority about detected double funding cases;

(xi) work closely with Member States, in particular those facing structural capacity constraints, by providing targeted technical assistance, guidance and administrative support in order to ensure the full and effective implementation of RRF investments and reforms across all Member States;

(xii) strengthen monitoring mechanisms and ensure that reforms and investments financed under the RRF remain operational and deliver durable impact beyond the disbursement period, in order to protect the Union’s financial interests and taxpayers’ money;

(xiii) propose, for post-2026 instruments and regulation revisions, an obligation for Member States to report suspected fraud and irregularities using a harmonised taxonomy aligned with OLAF/EPPO standards;

(xiv) perform a macroeconomic evaluation with the objective of assessing the effectiveness and efficiency of Union support to Member States through the RRF, including the extent to which support has been timely and proportional to the intended objectives of the Facility, notably recovery from the COVID-19 crisis, and share it with the discharge authority;

(xv) call for the introduction of predictive analytic tools powered by AI as well as machine learning capabilities that would enable auditors to conduct real-time risk assessments and identify anomalies more effectively.