A Commission notice published today sets out the operational timeline and procedural obligations for the final phase of the Recovery and Resilience Facility. The milestone deadline is absolute, and after that date, suspension procedures shall be replaced by direct reduction decisions, and no further plan amendments are possible.
The Recovery and Resilience Facility, established by Regulation (EU) 2021/241 in February 2021 and funded through the €723.8 billion NextGenerationEU instrument, enters its final months of operational life. Commission Notice C/2026/2614, published on 4 May 2026, consolidates the procedural framework for closure and establishes a set of binding and indicative deadlines that national authorities need to observe for the remainder of 2026.
The central deadline in the notice is 31 August 2026, by which all milestones and targets across all 27 Member State recovery and resilience plans must be satisfactorily completed. Any action taken after that date is legally irrelevant to the payment assessment: the RRF Regulation is explicit that only measures implemented by 31 August count. Member States wishing to submit amendments to their Council implementing decisions, to revise targets that have become unachievable, must submit those requests to the Commission by 31 May 2026 at the latest, leaving the Commission enough time to assess and the Council to adopt before the August hard stop. All Member States have either already amended their plans or are currently in the process of doing so.
The notice introduces a significant procedural shift for non-fulfilment situations arising after 31 August. Until that date, the standard response to an unmet milestone is a payment suspension, giving the Member State six months to take remedial action. After 31 August, suspension becomes legally inapplicable — there is no longer time for remediation. Instead, the Commission will move directly to a proportionate reduction procedure under Article 24(8) of the RRF Regulation: the Member State receives a preliminary assessment of non-fulfilment, has two months to submit observations, and the Commission then either maintains or withdraws the reduction. Payments for fulfilled milestones in the same payment request proceed in parallel, independently of the reduction procedure on the contested items.
The payment request deadline is 30 September 2026, accompanied by management declarations and summaries of audits. Following submission, the Commission has two months to issue a preliminary assessment to the Economic and Financial Committee, which it intends to do by 20 November 2026. The EFC is expected to provide its opinion by 8 December 2026, enabling the Commission to authorise payments by 18 December and disburse by 31 December 2026 — the absolute payment deadline under the RRF Regulation. Given the compressed timeline, the notice strongly urges Member States to share supporting evidence with Commission services informally and in advance, before the formal submission, particularly for sampled milestones where iterative exchanges are normally required.
Obligations do not end on 31 December 2026. The notice confirms that control, audit, and anti-fraud obligations under the Financing and Loan Agreements have no end date. Ex-post controls and audits — covering fraud, corruption, conflicts of interest, and double funding — are expected to run through 2027 and potentially into 2028. Data must be retained until at least 31 December 2031. Reporting on common indicators continues twice yearly through 2027 with a final round in February 2028. Green bond-related climate expenditure reporting runs until 31 December 2031 or until the full estimated cost of each climate-tagged measure is reported, whichever comes first. Irregularities must continue to be reported via the Irregularity Management System and to OLAF, without time limit.
