The final sprint of the Recovery Plan is underway; from 31 May, no further changes to the NRRPs

Brussels – Europe charts the final course for NextGenerationEU. And, with the guidelines for the closure of the Recovery and Resilience Facility, a strict countdown begins, compelling Member States to make a final push towards the 2026 deadline. The European Commission published today, 4 May, the operational guidelines for the final phase and closure of the Recovery and Resilience Facility, the cornerstone of the NextGenerationEU plan.

 The document sets a very short deadline for national governments to make changes to the plans. In other words, Member States intending to propose amendments to their National Recovery and Resilience Plans (NRRP) must do so no later than 31 May 2026. “For any request for amendment submitted after that date, the Commission cannot commit to completing its assessment in time for the Council to adopt the revised decision by 31 August 2026,” specifies the Berlyamont Palace.

What is the Recovery and Resilience Facility (RRF) and how does it work?

The Recovery and Resilience Facility is a temporary instrument established in 2021 to support post-pandemic economic recovery and strengthen the resilience of Member States through reforms and investment. Together with around €80 billion in supplementary funding, such as the European Regional Development Fund (ERDF) and the European Social Fund (ESF+), the Recovery and Resilience Facility aims to support the broader “Next Generation” plan, which totals €750 billion. Unlike traditional European funds, the RRF is based on a performance-based funding model. 

The process is simple but rigorous: funds are not disbursed based on incurred expenditure, but only once the State has demonstrated that specific milestones and final objectives have been met. Once these commitments have been fulfilled, countries submit a payment request to the Commission, which verifies that the requirements have indeed been met before proceeding with the disbursement. All targets must be completed by 31 August 2026, with final payments due by 31 December of the same year. Any financial commitment not honoured by this final deadline will be subject to automatic decommitment and will thus be definitively forfeited. A key point is that, although payments end in 2026, reporting and monitoring will continue for years to ensure that reforms are not “reversed” once the money has been received.

Italy’s reaction and Fitto’s comments

Italy, which has recently received approval for the payment of the ninth instalment of its NRRP, amounting to €12.8 billion, appears to be closely monitoring this closure phase. The Vice-President and Commissioner for Cohesion and Reforms, Raffaele Fitto has welcomed the new guidelines on social media and emphasised that the government is already working to optimise resources: “The guidelines serve to clarify, simplify, and accelerate—our priorities—the reporting and evaluation phase regarding the achievement of objectives, facilitating the management of payment requests,” he wrote, adding that the new flexibility introduced “allows and encourages Member States to submit targeted revisions by 31 May” and that “in a difficult and delicate phase such as this, it is essential to work together to direct resources where they are most strategic and necessary.”

The Bulgaria case and the concerns of the European Court of Auditors

Other countries face even greater challenges in practice. Bulgaria has recently submitted a request to revise its plan to postpone two key deadlines for establishing a politically independent anti-corruption body. This move came after the Commission froze payments worth around €367.3 million due to the failure to meet these targets. As confirmed by the Berlaymont during its daily press briefing, the Bulgarian proposal is currently being assessed by the authorities in Brussels.

Although Bulgaria’s situation is unique, it forms part of a broader trend of slowdowns that have affected several EU countries in the past and could affect the ability to meet upcoming deadlines. According to data from the European Court of Auditors as of the end of 2023, the proportion of payment claims submitted relative to those initially forecast for the EU-27 average stood at 70 per cent. In absolute terms, in 2023 Member States had requested a total of €228 billion, a figure approximately €45 billion (16.5 per cent) lower than the €273 billion initially estimated. This trend indicates that the uptake of funds was proceeding with some delays, posing a real risk to the completion of several measures. The Court’s data revealed significant scepticism among national coordinating bodies regarding compliance with the timetable: around 27 per cent of respondents considered it unlikely or very unlikely that all planned investments could actually be completed by the final deadline of 31 August 2026. 

In this delicate balance between the need to streamline procedures and the risk that some investments may remain unfinished, the success of the final phase will be the ultimate test of the credibility of a Europe that has staked everything on its ability to turn reforms into tangible results.