In preparation for the EU’s next Multiannual Financial Framework (MFF 2028-2034), the European Commission has presented a proposal for a regulation for the National and Regional Partnership Plans (NRPP). Members of the European Parliament submitted more than 6000 amendments to the Proposal. The Hungarian environmental NGO “Clean Air Action Group” (CAAG) has assessed these amendments and made proposals for 17 new ones in its endeavour to help achieve the environmental and climate objectives of the EU. Below, we provide an overview of the suggestions that CAAG considers to be included in the NRPP Regulation.

Ensuring the effectiveness of the Union’s financial governance

Firstly, the new MFF must enforce the implementation of the additionality principle effectively, i.e., EU funding by no means should merely substitute for funding from national budgets. For this purpose, the Commission should prepare a methodology to verify and monitor compliance with the principle of additionality at each stage of the NRPP’s design, implementation and evaluation to ensure transparent and comprehensive monitoring of EU spending.

To achieve the EU’s environmental and climate policy objectives, it must also be ensured that the objectives of national funding do not conflict with those of EU funding. For example, it is unacceptable that European money is used for the renovation of railway infrastructure while the money thus saved in the national budget is used to support motorway construction.

Non-repayable discretionary funding raises serious concerns about fair competition between companies. Such subsidies risk providing an unmerited advantage for some companies at the expense of others. Thus, the NRPP Regulation should clearly state that such funding is incompatible with the EU’s basic principles.

The MFF should help to ensure that not only vulnerable households but also middle-income ones will not bear the burden of the transition to climate-neutrality.

The Regulation should require full alignment with and comprehensive coverage of the relevant Country-specific Recommendations addressed to the Member State in the framework of the European Semester. It should be clearly stated that all challenges and priorities need to be addressed, especially considering the emergency to invest and implement a just transition and sustainable development.

Ending the compromises on high environmental standards

The Regulation should require Member States to unequivocally ensure the implementation of the principle of non-regression. Thus, any legal or institutional setback in the level of social rights or environmental protection should be qualified by the Commission as a non-fulfillment of the horizontal condition of complying with the provisions of the Charter of Fundamental Rights of the European Union, and thus it should initiate formal non-compliance and suspension procedures.

Climate mitigation and adaptation may succeed only if biodiversity protection and restoration are ensured. It is essential that projects that achieve carbon neutrality do not come at the expense of local ecosystems and biodiversity. No projects should have negative environmental impacts even if they contribute to the climate goals. For instance, no financial support should be allocated to road and aviation infrastructure.

Build on existing strengths and resources

The conditions for monitoring should be adequate to ensure that the partnership principle is properly applied with a balanced representation of partners, and transparency across all phases of the Plan. Thus, the regional and local authorities should be able to present their observations and proposals for remedial measures on the NRPPs in accordance with the subsidiarity principle. To ensure meaningful public participation, the NRRP Regulation should also envisage appropriate financing for social partners to enable them to provide unbiased expertise and fair involvement. Notwithstanding, reviews of the implementation of the plans should take place several times during the year to ensure effective oversight and transparency.

Already existing EU and Member State databases should be used to publish information, as this would save money and enhance transparency, thus helping to guarantee the overall sound financial governance of the European Union and its Member States.

Discouraging and Encouraging: A Transition Under Debate

It is encouraging to see that many of the amendments drafted by MEPs bring about significant improvements in the areas mentioned above. For example, deputies are concerned about the Member States' obligation to properly implement adaptation and mitigation of climate change measures. The importance of sustainability and the affirmation of innovative environment-specific objectives within the national plans are concrete incentives to take the best track possible towards a socially just transition leading to a carbon-neutral Europe. However, the adoption of certain other amendments of MEPs would represent a step backwards in terms of the core principles and overarching values of the EU. It is therefore important to draw attention and raise awareness about each party’s voting intentions and the implications their decisions will have on our citizens’ lives.