Portugal receives 2.320 billion from NextGenerationEU and already exceeds 78% of its funds

Portugal has already received about 79% of the funds from its Recovery and Resilience Plan (PRR) financed by NextGenerationEU and has fulfilled around 75% of its milestones and targets. The Portuguese Government has committed to executing all grants by August 31, 2026, and not returning funds to Brussels. To collect the rest, Portugal must complete the 96 milestones and targets still pending, submit the final payment requests before the end of September 2026, and pass the formal evaluations by the European Commission and the Economic and Financial Committee. Below I detail the status of payments and the remaining administrative steps.

1. Current status of the Portuguese PRR

According to the European Commission, Portugal's recovery and resilience plan is financed with approximately €21.9–22.2 billion in grants and loans, following successive reprogramming and modifications approved by the EU Council, which validated the amended Portuguese plan in October 2024 for a total of €22.215 billion (€16.325 billion in grants and €5.890 billion in loans), with 40.6% dedicated to climate objectives and 21.1% to digital transition (Council note).

In July 2026, the Commission indicates that, after the ninth payment request, funds disbursed to Portugal under the RRF would amount to €17.230 billion (including pre-financing), representing 78.67% of all plan funds, with 74.54% of milestones and targets already met (statement on the 9th request).

Meanwhile, the Portuguese Government states that the PRR mobilizes €21.905 billion, with €13.5 billion already paid to beneficiaries and €15 billion of European funding received. As of July 28, 2026, 283 of 379 milestones and targets have been met, with 96 remaining to be submitted; the Government expects to complete “all milestones and targets” and execute “all available grants” before August 31, 2026 (Portuguese Government note).

2. Payments made and recent tranches

Recent milestones in the payment schedule include:

• 5th payment (2024): positive preliminary evaluation and subsequent disbursement of €2.9 billion (€1.65 billion in grants and €1.25 billion in loans), linked to 42 milestones and targets (fifth request; joint disbursement).
• Partial suspension and lifting (2024): the Commission had withheld €810 million from the 3rd and 4th tranches due to non-compliance in health reforms and regulated professions; after corrections, it proposed lifting the suspension and paying €714 million, confirming compliance with all pending milestones (decision on suspension).
• 6th payment (June 2025): positive preliminary evaluation of a €1.34 billion request, linked to 32 milestones and targets; with this payment, Portugal would have received €11.4 billion, about 57% of its total allocation at that time (sixth request).
• 7th payment (October 2025): the Commission approved the seventh request of €1.06 billion, submitting its evaluation to the Economic and Financial Committee before payment (seventh request).
• 9th payment (July 2026): positive evaluation of the ninth request for €2.32 billion, based on 22 milestones and 29 targets, with a strong focus on education, waste, circular economy, digitalization, and access to financing (ninth request).

Additionally, the Portuguese Government indicates that the tenth payment request is already being prepared, in which it expects to include the closure of many final milestones (government communication).

3. Formal procedures pending for the last funds

The administrative steps for each new RRF disbursement are standard and apply equally to Portugal and other Member States:

• 1) Fulfill milestones and targets: Portugal must complete the 96 pending milestones and targets before the end of August 2026, according to its own commitment (Portuguese Government).
• 2) Submit payment request: for each tranche (as with the 5th, 6th, 7th, and 9th requests), the Government sends the Commission a detailed request linking each milestone and target to the amount requested (fifth request, sixth, seventh, ninth).
• 3) Commission evaluation: Brussels reviews whether the milestones and targets have been “satisfactorily” met and issues a positive or negative preliminary evaluation. This phase has been seen in several payments and in the lifting of the 2024 suspension (lifting of suspension).
• 4) Opinion of the Economic and Financial Committee (EFC): the Commission sends its evaluation to the EFC, which has four weeks to issue an opinion; only after this opinion can the payment decision be formally adopted (sixth request, 2024 disbursement, ninth request).
• 5) Payment decision and disbursement: the Commission adopts the payment decision and proceeds with the actual disbursement; in cases of partial non-compliance, it may suspend part of the amount, as happened and was later corrected for Portugal in 2024 (suspension and lifting).
• 6) Possible reprogramming: if any project does not finish on time before 2026, Portugal can, and indeed is already doing so, transfer certain investments to other frameworks such as Portugal 2030 to avoid losing PRR resources (Portugal 2030 welcomes projects; PRR reprogramming; PRR revision).

4. Schedule until the end of 2026

According to the Commission, all RRF milestones and targets must be implemented no later than August 2026, and the final payment requests must be submitted before the end of September 2026; from then on, the remaining funds can be evaluated and disbursed before the mechanism concludes at the end of 2026 (ninth request).

In parallel, the Portuguese Government explicitly sets August 31, 2026, as the deadline to execute all PRR grants and complete the 43 planned reforms (Portuguese Government). For projects not completed by that date, it is designing “bridge solutions” via Portugal 2030, EIB, or national budgets, precisely so that the delay of a specific work does not prevent certifying the committed milestone.

5. Risks and room for maneuver

The 2024 experience shows that if the Commission considers a milestone not fully met, it can suspend the corresponding payment totally or partially and grant an additional period to correct it (Portugal suspension case). As the RRF closure approaches, the margin to reopen deadlines will become narrower, so Portugal's main challenge in these months is twofold: to complete the 96 pending milestones and document them very precisely to avoid new suspensions.

In summary, the remaining steps are less regulatory and more about execution and verification: finishing reforms and investments, reprogramming what does not arrive on time to other European funds, and passing, tranche by tranche, the dual scrutiny of the Commission and the EFC before the 2026 closure.

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The European Commission plays a central role in the control and evaluation of the Recovery and Resilience Facility (RRF) funds: it evaluates payment requests based on the fulfillment of milestones and targets, can activate total or partial suspension of payments when non-compliance is detected, and has broad audit and information access powers to protect the EU's financial interests. These powers are set out in Regulation (EU) 2021/241 and detailed in communications and press releases from the Commission itself. Additionally, the RRF is based on a “payment by results” logic, so the Commission only authorizes disbursement when it considers the progress of reforms and investments satisfactory. Below these powers are detailed by blocks: control/evaluation, suspension, and recovery.

Evaluation of plans and payment requests

The RRF Regulation assigns the Commission the competence to evaluate both national recovery plans and each payment request. In press releases about payments to Member States (Spain, Bulgaria, Portugal, Poland, Netherlands, etc.), the same scheme is repeated: the Commission performs a “preliminary evaluation” of whether the milestones and targets linked to a request have been “satisfactorily” met. This can be seen, for example, in Spain's fourth request in the note on Spain's fourth payment request under the RRF (statement on Spain) and in Bulgaria's second request (statement on Bulgaria).

If the preliminary assessment is positive for (almost) all milestones, the Commission sends that evaluation to the Economic and Financial Committee, which has four weeks to issue an opinion. Based on that, the Commission adopts the payment decision. The third annual implementation report of the RRF, where the Commission reviews the mechanism, emphasizes that disbursements depend precisely on this systematic verification of milestones and targets and that more than €267 billion have already been disbursed following this procedure (third annual RRF report).

Supervision, audit, and transparency

In the same annual report, the Commission highlights that it has strengthened control mechanisms and protection of the EU's financial interests. Between September 2023 and August 2024, it carried out seventeen risk-based ex post audits on compliance with milestones and targets and four national system audits, and states that “by the end of 2023 it had audited all Member States at least once” (third annual RRF report).

Moreover, the Regulation requires States to acknowledge in writing the Commission's and other EU bodies' access rights. National orders developing aid charged to the RRF reproduce this requirement: Order TED/765/2024 states that, when requesting aid, the beneficiary agrees to grant the necessary access so that European Commission, OLAF, European Court of Auditors, European Public Prosecutor's Office, and national authorities can exercise their control powers, in application of Article 22.2.e) of Regulation (EU) 2021/241 (Order TED/765/2024). An order from the Basque Country on the UNICO Buildings program reproduces the same clause (UNICO Buildings order).

Politically, the newspaper Demócrata reports how the EU Court of Auditors has criticized “gaps” in traceability and transparency of funds and how the Commission has defended that the RRF model rests on milestones and targets, with “strong transparency measures” such as publishing evaluations, payment requests, and progress reports (article on major recipients; article on supervision failures in Spain).

Suspension of payments

The power to suspend payments is expressly set out in Article 24.6 of the RRF Regulation, cited in several communications. When it finds that one or more milestones or targets have not been met, the Commission can activate the “payment suspension” procedure:

• It informs the Member State which milestones/targets it considers unmet and opens a one-month period for observations.
• After analyzing those observations, if it maintains its position, it suspends the payment totally or partially, applying a common calculation methodology described in an annex to its February 21, 2023 Communication (statement on Spain; statement on Bulgaria).
• The State then has six months to fulfill the pending milestones; if it does, the Commission lifts the suspension and disburses the withheld amount.

In Spain's case, the Commission activated this mechanism in the fourth payment request for a business digitalization target, granting additional time but making a partial payment for the rest of the milestones already met (statement on Spain).

Furthermore, regarding the RRF closure, a communication analyzed by Demócrata emphasizes that after August 31, 2026, no new extensions will be granted and that non-compliance will directly result in proportional aid cuts in the final payments (article on the recovery fund closure).

Recovery of funds and national implementation

Although the specific procedure for recovering funds from final recipients is organized at the national level, these mechanisms respond to requirements of the RRF Regulation. In Spain, for example, the BOE has regulated the return of RRF funds and bodies such as the Health Integrity and Anti-Fraud Committee assume functions of monitoring, evaluation, and designing procedures to recover unduly paid amounts, in line with the anti-fraud principles linked to the RRF (article on the Integrity Committee).

Likewise, the Commission has made clear, regarding the use of recovery funds for pensions in Spain, that it supervises national control systems and can act in cases of fraud, corruption, or conflict of interest if the State does not correct irregularities (article on funds and pensions).

Overall, Regulation (EU) 2021/241 configures a model in which States manage and execute the funds but under intense supervision by the Commission, combining ex ante evaluation of milestones and targets, ex post audits, enhanced transparency, and the possibility of suspending or ultimately reducing aid when agreed conditions are not met.

The legal requirements for Member States to receive payments from the Recovery and Resilience Facility (RRF) are mainly set out in European Union legislation (RRF Regulation), but the available information only includes Spanish regulations for the execution of the Recovery, Transformation, and Resilience Plan (PRTR). From these national regulations, the general scheme can be inferred: RRF funds are linked to specific investments and reforms of the PRTR, managed through regulatory base orders and direct grant royal decrees, subject to management controls, expenditure justification, and territorial distribution. However, the consulted sources do not explicitly include the detailed criteria of the European Commission on verification of milestones and targets, macroeconomic conditionality, or EU-scale audit procedures. Moreover, this is a predominantly European issue, while this assistant specializes in the Spanish regulatory and political context.

1. What Spanish regulations show about RRF execution

Provisions in the BOE related to the PRTR make clear that RRF resources are channeled through aid or subsidy programs designed by Spanish ministries and financed by the European Union–NextGenerationEU or directly by the RRF. Examples include regulatory base orders and aid calls for digitalization, tourism, R&D, or employment policy projects, such as Order ITU/1391/2023 for “Last Mile” digitalization in tourism (Order ITU/1391/2023) or Order ETD/1236/2023 on IPCEI (Order ETD/1236/2023).

Similarly, there are orders and royal decrees regulating aid for digital infrastructures, innovation, sustainable transport, employment programs, and other PRTR investments, all “within the framework of the Recovery, Transformation, and Resilience Plan” and financed by the EU or the RRF: for example, Order ETD/947/2023 (Order ETD/947/2023), Order CIN/644/2023 (Order CIN/644/2023), or the Sustainable Transport Support Program regulated in Order TMA/370/2022 (Order TMA/370/2022).

It is also observed how the Administration adapts and updates regulatory bases to fit the ministerial structure and the PRTR, as in Order ITU/867/2025 (Order ITU/867/2025), or how specific flagship programs are created such as the sectoral 5G (Order ETD/806/2022), aid to research organizations (Order ICT/1521/2021), or direct subsidies linked to specific PRTR components (Royal Decree 991/2021, Royal Decree 937/2021).

2. Requirements derived from these national regulations

Although they do not develop the Commission's criteria to authorize RRF payments to each State, these regulations allow identifying some operational requirements that Spain must internally meet to execute and justify the funds:

• Linkage to PRTR components and investments: aid is always assigned to specific Plan components and projects (e.g., technological programs and PERTEs in Order CNU/462/2024, Order CNU/462/2024, or digital training and new skills programs in Royal Decree 978/2022, Royal Decree 978/2022).
• Establishment of regulatory bases and calls: the use of RRF funds requires detailed regulatory base orders (e.g., in employment and active policies: Order TES/1151/2021, Order TES/1153/2021, Order TES/1121/2021), where eligibility requirements, selection criteria, justification obligations, and controls are set.
• Financial controls, audit, and quality: although details in the consulted sources relate more to audit or general tax matters (e.g., audit quality control standards in the Resolution of April 20, 2022, and its update, ICAC Resolution 2022 and previous standards, amended by Resolution of April 11, 2024), it is a framework also applied to European fund management.
• Territorial distribution and execution by Autonomous Communities: some royal decrees and orders distribute RRF-financed credits among autonomous communities (e.g., Order TES/897/2021 on digital skills and employment policies, Order TES/897/2021, or Royal Decree 477/2021 on self-consumption and renewables, Royal Decree 477/2021), implying execution, control, and reporting obligations for the Autonomous Communities.

3. Limits of available information and reference to the European framework

Numerous national regulations appear in the reviewed sources that develop the PRTR in areas such as tourism (Order CUD/1448/2021), youth employment and “Investigo” programs and first experiences (Order TES/1267/2021, Order TES/1152/2021), training and taxation (Resolution April 26, 2023, Order HFP/94/2023, TS ruling September 28, 2021, Order HAC/342/2021), but they do not detail how the European Commission exactly verifies compliance with RRF milestones and targets nor the EU's internal procedures to authorize payments to each Member State.

Since this is a strictly European mechanism, details on conditionality, European audit, fraud prevention, or payment suspension must be sought in the Regulation (EU) creating the Recovery and Resilience Facility and in the practice of the Commission and the Council, areas in which this assistant is not specialized. Here only what derives from the Spanish PRTR execution regulations can be exposed, without adding European information not appearing in the consulted sources.