Frequently Asked Questions

Since the entry into force of the Nature Restoration Regulation (NRR) on 18 August 2024, the work is focusing on implementation. A key milestone will be the submission of national restoration plans (NRPs) by Member States.

Member States will have to submit to the Commission their draft NRP by 1 September 2026. The Commission will assess each draft NRP within six months and may address its observations on the draft plan to the Member States. Six months later (~1 September 2027), Member States will have to submit and publish their final NRP. By July 2032, Member States are to revise their NRP for the first time.

The Commission will continue supporting Member States in the development of their NRP. In order to achieve the restoration targets in the NRR, the implementation of restoration measures must already start and not wait until the national restoration plans have been finalised.

The below table lists ‘deliverables’ foreseen in the NRR. Some must be adopted by the Commission, while others have an optional character (they ‘may’ be adopted).

Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment (the “SEA Directive”) sets out that an environmental assessment must be carried out for plans and programmes identified as likely to have significant effects on the environment.

Article 14(20) NRR, which lays down rules for the way NRPs should be prepared with regard to public participation and consultation, makes a reference to the SEA Directive. It provides that consultations on NRPs must comply with the requirements of the SEA Directive. This provision however does not set out whether, beyond public consultation, other rules relating to environmental assessment apply to NRPs.

According to Article 3(1) of the SEA Directive, performing a SEA is mandatory for certain types of plans and programmes which are likely to have significant environmental effects. According to Article 3(2), this includes plans and programmes "which are prepared for agriculture, forestry, fisheries, energy, industry, transport, waste management, water management, telecommunications, tourism, town and country planning or land use[1] and which set the framework for future development consent for projects listed in Annexes I and II to Directive 2011/92/EU" (the "Environmental Impact Assessment (EIA) Directive”).

As was clarified by the Court of Justice, the requirement, according to which the plan or programme concerned must set the framework for future development consent of projects listed in Annexes I and II of the EIA Directive, must be regarded as met where that plan or programme establishes a significant body of criteria and detailed rules for the grant and implementation of one or more of those projects, inter alia with regard to the location, nature, size and operating conditions of such projects, or the allocation of resources connected with those projects. By contrast, that requirement is not met in the case of a plan or programme which, while targeting projects listed in Annexes I and II of the EIA Directive, does not lay down such criteria or detailed rules[2].

The NRR leaves Member States a large margin with regard to the choice of the concrete restoration measures to put in place, provided the targets and obligations under Articles 4 to 13 are complied with, and does not prescribe that the NRPs should necessarily set detailed rules regarding individual projects.

It is therefore for each Member State to verify, depending on the measures to be included, if their draft NRP meets the conditions requiring the application of the SEA Directive in full. In doing so, Member States should consider the specific content of the NRP and in particular the extent to which it conditions future decisions on projects, for example with regard to their nature, location, size and operating conditions. It is important to note that irrespective of the applicability of the SEA Directive, effective public participation is a self-standing requirement in case a plan touches upon environmental issues.[3]

If an SEA is needed, it has to be conducted during the preparation of the NRP, prior to its finalisation in accordance with Article 17(6) NRR.

More information:

• Commission guidance on the SEA Directive

• Case law on the SEA Directive

Notes

[1] The fact that the main objective of a plan or programme is the protection of the environment, which includes protection of the landscape, does not mean that that plan or programme may not also ‘concern’ one of the sectors listed in Article 3(2)(a) of that directive, including town and country planning or land use (see Bund Naturschutz in Bayern eV, C-300/20, EU:C:2022:102, paragraph 51, and case law cited).

[2] See Bund Naturschutz in Bayern eV, paragraph 62 and 63.

[3] Aarhus Convention Article 7.

Some restoration measures implemented or started before 18 August 2024 may have not yet reached their full effect.

Member States could include such measures in the NRP if:

• the measure is corresponding to the definition of restoration provided in Article 3(3), and
• the measure is showing the envisaged improvement-effect but the intended full impact of the measure (e.g. full recovery to the good condition of an area of a habitat type or reaching satisfactory levels for the indicators referred to in Articles 8 to 12) has not been achieved yet.

When the restored area has fully recovered or reached the intended state, any subsequent measures on the same area aiming at ensuring the sustained effects of restoration measures (e.g. recurring management) could be considered as non-deterioration measures in the meaning of Articles 4(11), 4(13), 5(9) or 5(10) or as one of the provisions referred to in Article 15(3)(q).

These considerations are without prejudice to the specific case of barrier removals for which Article 15(3)(i) states that the NRP includes the length of free-flowing rivers to be achieved by the removal of barriers estimated from 2020 to 2030.

According to Article 3(4) NRR, the term ‘good condition’ relates to ‘areas of a habitat type’. To fulfil the requirements of the NRR, in particular those related to Articles 4 and 5, data on the condition of habitat types are needed at local level in a spatially explicit way to enable Member States to put the necessary restoration measures in place where needed. Member States have a surveillance obligation under Article 11 of the Habitats Directive and report the results of this surveillance in the frame of the 6-yearly progress reporting under Article 17 of that Directive (see guidance and reporting format as available here:  Habitats Directive Art 17 ).  In addition, the Commission is in the process of establishing, with the support of a contractor, technical guidelines for monitoring and assessing condition of Annex I habitat types (to be finalised in Q3 of 2025).

Article 3(5) refers to ‘good environmental status’ as defined in Article 3(5) of Directive 2008/56/EC (Marine Strategy Framework Directive). The NRR does however not refer to the term of ‘good ecological status’ as defined under the Water Framework Directive. 

In the frame of the reporting requirements under Article 17 of the Habitats Directive, the ‘quality of a habitat’ is assessed at the level of the biogeographic region in a Member State. However, to fulfil the requirements of the NRR, data on habitat quality are likely to be needed at lower levels in a spatially explicit way in order to enable Member States to put the necessary restoration measures in place where needed.

Article 14(5) does not refer to the requirements in Directive 2001/42/EC, as is the case in Article 14(20). It is for Member States to determine how they ensure this open and effective process.

Art 14(20) stipulates that Member States shall ensure that the preparation of the restoration plan is open, transparent, inclusive and effective and that the public, including all relevant stakeholders, is given early and effective opportunities to participate in its preparation. In addition, it is stated that consultations shall comply with the requirements set out in Directive 2001/42/EC. 

The detailed arrangements for public participation, such as the exact timing and timeframes for expressing an opinion, are to be determined by the Member States in accordance with the rules set out under EU and national law. In any case, they should ensure a meaningful participation at the different stages of the public participation process, taking duly into account the public’s input and making the choice of selected options transparent, preferably reflecting on the preferences expressed by the public.

For urban and agricultural ecosystems and for pollinators, the satisfactory level should not be indicated in the national restoration plan, because Article 14(5) specifies that Member States, when setting the satisfactory levels, have to take into account the guiding framework to be established by the Commission by 31 December 2028 under Article 20(10). For forest ecosystems, Member States have the option to already include a satisfactory level for forest indicators in their first National Restoration Plan, as the Commission is not obliged - but has the option - to establish a guiding framework under Article 20(11). If the Commission adopts a guiding framework (implementing act), and if the initial satisfactory level in the Member State’s National Restoration Plan deviates from this guiding framework, then the Member State may need to revise the satisfactory level and include it in their revised National Restoration Plan.

When the Commission, in consultation with the NRR Expert Group and subject to the opinion of the NRR Committee, establishes a guiding framework by implementing act, it is binding. However, a guiding framework would leave some flexibility to Member States to set their satisfactory level, within the framework provided in the implementing act.

Guidance is available on setting favourable reference values (FRVs) as part of the guidance for reporting under Article 17 of the Habitats Directive. It can be found on the “Reference portal for reporting under Article 17 of the Habitats Directive” (Habitats Directive Article 17) through this link: https://cdr.eionet.europa.eu/help/habitats_art17/Reporting2025/Final%20Guidelines%20Art.%2017_2019-2024.pdf/   
See page 20 – 31 for species and page 69 – 76 for habitat types.

The guidance on FRVs is currently being improved and will be made available as a separate document in the course of 2025.

The term ‘remaining habitat types’ is used in the context of derogations (see Article 4(2) and 4(5)) that a Member State may, but does not have to, make use of.

In Article 4(3), "remaining habitat types" refers to all Annex I habitat types besides those very common and widespread habitat types that cover more than 3% of the Member State’s European territory for which a Member States makes active use of the derogation as set out in Article 4(2).

In Article 4(6), "remaining habitat types"refers to all those Annex I habitat types for which a Member State does not apply the derogation as set out Article 4(5) (i.e. for which the Member State does not set a lower percentage threshold for reaching the favourable reference area (FRA) targets than specified in Article 4(4)).

Article 4(13) introduces a derogation, that allows for a more flexible implementation approach for the non-deterioration requirements set out in Article 4(11) and 4(12), outside Natura 2000 sites. If a Member State wants to make use of this implementation approach, Article 4(13) sets out that it needs to notify the Commission of its intention to apply this paragraph by 19 February 2025. This notification must be made only once and is valid for the time the regulation is in force.

If a Member States has chosen to apply Article 4(13), it must ensure compliance with the following conditions:

• Any decision to apply the derogation to a specific area would need to demonstrate that there is an absence of alternatives, as set out in Article 4(13). The need for such justification should be reflected in the national framework established to implement this derogation.

• Establish a system of effective compensatory measures for each significant deterioration that occurs (in accordance with Articles 15(3)(g)(i)).

• Ensure compliance with non-deterioration requirements at a biogeographic level for each habitat type and species habitat (in accordance with Article 4(13)).

• Define a targeted monitoring framework for Article 4(13) (in accordance with Articles 20(1)(j))) and comply with the reporting obligations under Articles 21(1)(b) and 21(2)(b) in addition to other monitoring and reporting requirements of the regulation.

• Demonstrate how the objectives and targets of Articles 1, 4, and 5 will still be met (in accordance with Article 15(3)(g)(ii)).

Time of application of Article 4(13)

Article 4(13) is a derogation to Articles 4(11) and 4(12), which apply to different areas and follow a different timeline. Article 4(13) therefore starts to apply depending on the type of area under consideration:

• For areas subject to restoration measures and areas where good condition and/or sufficient quality of species habitats has been reached (Article 4(11)):
  For these areas Article 4(13) applies from the time of notification to the Commission and for both habitat types and habitats of species.
  
  Important note: Areas showing continuous improvement in their condition cannot deteriorate simultaneously. This means that areas subject to restoration measures that have not yet reached a good condition still fall under Article 4(13).

• For areas in good condition or necessary to meet restoration targets (Article 4(12)):
  For these areas, Article 4(13) applies once the final National Restoration Plan is required to be published (within six months from the date of receipt of observations from the Commission as set out in Article 17(6), which means by September 2027 at the latest). It should be taken into account however that continuing deteriorations until that date are likely to increase the restoration obligation.

Monitoring requirements

Once a Member State has notified its intention to apply Article 4(13), it must comply with both, the general monitoring obligations outlined (and in particular those in Article 20(1) (a), (h) and (i)), and the specific additional monitoring requirements provided under Article 20(1)(j).

Article 20(1)(h) and (i) require the monitoring of habitat condition and quality of habitats of species:   

• 20(1)(h): Monitors the area and condition of the areas covered by the habitat types listed in Annexes I and II.
• 20(1)(i): Monitors the area and quality of the habitat of the species referred to in Article 4(7) and Article 5(5).

These provisions ensure that deteriorated or deteriorating areas are properly tracked. The monitoring requirements under Article 20(1) (h) & (i) have no specific starting date and are therefore applicable from the entry into force of the regulation.

Article 20(1)(j) is applicable only when Article 4(13) is used and outlines specific monitoring requirements that must be fulfilled in that case. It requires the monitoring of:

• The extent and location of areas that have significantly deteriorated and will be compensated for.
• The extent and location of areas subject to compensatory measures taken.
• The effectiveness of compensatory measures put in place.

These specific monitoring requirements take effect as soon as a Member State submits its notification to the Commission (from 19 February 2025, as set out in Article 4(13)), in accordance with Article 20(5).

Article 4(17) is an outcome-based requirement, namely that the restoration measures taken by a Member State under Article 4 show a result on the ground and increase the overall area of habitat types that are in good condition and species habitats with sufficient quality and quantity.  

The 90% reference in Article 4(17)(a) is informed by the threshold recommended in the guidance for assessing favourable conservation status for habitat types under the Habitats Directive[1]. This guidance recommends to use an indicative threshold of 90% of the habitat type area to be in ‘good’ condition as the threshold to conclude on the ‘favourable’ structure and functions’ parameter.

Notes

[1] See relevant format (with assessment matrix) and guidance in the reference portal: cdr.eionet.europa.eu/help/habitats_art17/Reporting2025/Final Guidelines Art. 17_2019-2024.pdf/

The NRR states that, for the purpose of Article 4(1) (the provision that refers to improvement of condition of areas of habitat types), Member States shall, as appropriate, until 2030 give priority to restoration measures in areas that are located in Natura 2000 sites. Recital 28 justifies this prioritisation by referring to the essential role those sites play for nature conservation. However, Member States can also restore outside Nature 2000 if appropriate. This is also underlined by Recital 28 which clarifies that Member States retain the possibility to put in place restoration measures beyond the Natura 2000 network in order to give the necessary flexibility to Member States to make large scale restoration efforts. For other types of measures, such as the re-establishment of areas of habitat types, the restoration of habitats of species, non-deterioration measures or measures contributing to Article 12, there is no such requirement to prioritise restoration measures in Natura 2000 sites.

The objectives of the NRR and the Birds and Habitats Directives are closely interlinked, as set out in Recitals 26 and 27 of the NRR. Implementation measures taken under the Birds and Habitats Directives could therefore contribute to reaching the restoration targets set out in the NRR for terrestrial, freshwater marine, agricultural and forest ecosystems.

As explained in the reply to the above question “Can restoration measures implemented or started before 18 August 2024 be included in the NRP?”, measures started before the entry into force of the NRR could also, under certain conditions, be taken into account as restoration measures under the NRR. This applies also to measures necessary to achieve good condition of a habitat type area that have been put in place under the Birds and the Habitats Directive before the entry into force of the NRR:  if the measures have not yet achieved full recovery of the area, i.e. the condition of the area is improving but the area is still not in good condition, such restoration measures could count under the NRR for the 30% target in Article 4(1).

The groups of habitat types are defined in Annex I. The targets for 2040 and 2050 refer to the area covered by each group, while the target for 2030 refers to all groups together (i.e. the area of all Annex I habitat types taken together).

Article 4(7), on restoration measures for habitats of species, refers to measures that are taken in addition to the measures for habitat types in Article 4(1) and 4(4) and which are necessary to improve the quality and quantity of those habitats, including by re-establishing them and by enhancing connectivity. Regarding species habitats, Article 4(11) refers to measures ensuring that areas subject to restoration under Article 4(7) show a continuous improvement of the quality of the habitats of the species, as well as to measures ensuring that areas, in which the sufficient quality of the habitat of species has been reached, do not significantly deteriorate. Non-deterioration measures under Article 4(11) include measures (that might well overlap with the restoration measures) that ensure the full effect of the restoration measures can unfold and apply to all areas where restoration measures are taken to either improve, re-establish or connect species habitats.  In all cases the species habitat should show continuous improvement in quality and not significantly deteriorate.

According to Article 4(11), second paragraph, Member States have to put in place measures aiming to ensure that areas in which good condition has been reached, and in which the sufficient quality of the habitats of the species has been reached, do not significantly deteriorate. According to Recital 37, this obligation applies to areas of habitat types subject to restoration measures – i.e. that are currently under restoration - or that have been under restoration and have reached good condition. Other areas of habitat types that were already in good condition before the entry into force of the NRR would fall under Article 4(12).

It means that the obligations and objectives of Directive 92/43/EEC are not affected by the application of these provisions .

Such situations can occur in nature conservation. Potential conflicts should be identified, analysed and priorities need to be set, for example based on what is considered the more important conservation interest in a particular area, a region, a country or the EU.

The NRR defines ‘good condition’ in Article 3(4) as a state where a habitat’s key characteristics, including its structure, functions and typical species or typical species composition, ensure its long-term maintenance and contribute to achieving both favourable conservation status under the Habitats Directive and good environmental status under the Marine Strategy Framework Directive (MSFD). The ‘condition’ of a habitat is assessed in a particular location and represents just one parameter for the assessment of the conservation status under the Habitats Directive and the good environmental status under the MSFD, both of which are to be assessed at larger geographical scales (biogeographical region and MSFD regions or sub-regions, respectively).

Assessing habitat condition under the NRR should rely, as much as possible, on the methodologies and indicators established by Member States for the implementation of the Habitats Directive and the MSFD.

Data collected under the MSFD, particularly on biodiversity, seafloor integrity, and ecosystem functioning, can and should be used for implementing the NRR. This includes data coming from the monitoring programmes about the condition of habitats, pressures and data about the measures taken under programmes of measures. 

The monitoring requirements of the NRR can build upon the existing frameworks and methodologies established under the MSFD. By using the knowledge, data, and infrastructure developed for MSFD monitoring, Member States can develop a consistent approach to assessing marine habitats under the NRR. This also offers an opportunity to integrate NRR-specific requirements into the broader marine monitoring framework, improving data coherence and reducing duplication of effort. Since the obligations under the NRR build on the MSFD but also include more detailed obligations, additional and more targeted monitoring efforts will probably be necessary in some cases to fully meet the NRR's specific monitoring requirements.

The threshold values established under the MSFD can play an important role in informing the implementation of the NRR. These thresholds provide clear benchmarks for achieving certain targets. For example, restoration targets for Group 7 (soft sediments) are aligned with threshold values for adverse effects established under the MSFD, ensuring that the work done under the MSFD directly supports the restoration and assessment efforts under the NRR.  

We can confirm that this approach is acceptable. Habitat types from groups 1–6 that are currently not present can be included under group 7 in the initial contextual information of the NRP. However, the NRP should also outline the planned re-establishment of these habitat types in line with the associated 2030, 3040, 2050 targets for re-establishment of habitat types from groups 1-6 under Article 5(2).

Yes. Article 14(14)(d) NRR requires Member States to take into account, where applicable, marine strategies for achieving good environmental status for all Union marine regions prepared in accordance with Directive 2008/56/EC (MSFD).

The table below summarises the data sets that should be used for implementing the urban targets of the NRR.

As Member States are free to establish their urban ecosystem area (UEA) boundaries anywhere within the LAU - as long the UAE consists of at least the urban centres and urban cluster – there is no obligation to set any specific peri-urban area (at 1km, or any other distance). It is, however, strongly recommend that a peri-urban area is included around the built-up area of the city to avoid any unwanted displacement of development to an area just outside the current built-up area.

Article 3(20) and (21) provides definitions of urban green space and urban tree canopy cover.  The official datasets, as specified in the NNR, to measure and monitor urban green spaces and urban tree canopy cover are produced and maintained by Copernicus Land Service. However, according to Articles 3(20) and 3(21), if available, Member States can also calculate the areas of urban green space and tree canopy cover on the basis of other appropriate supplementary data. Supplementary data can be used to improve or complement the information already included in the datasets provided by the Copernicus Land Monitoring Service.

Yes. The definition of ‘urban centres’ and ‘urban clusters’ in Article 3(16) NRR refers to the grid-based typology established in accordance with Article 4b(2) of Regulation (EC) 1059/2003. That provision mentions explicitly that “the grid-based typology shall be established at the 1 km² grid resolution level” for urban centres and urban clusters.

Article 20(10) NRR provides that the Commission shall, by 31 December 2028, establish a guiding framework for setting the satisfactory levels referred to in Article 8(2) and (3) by means of implementing acts. The guiding framework will therefore be discussed in the NRR Expert Group and eventually agreed by the NRR Committee.

Yes, Member States can select different options of Article 14 (4) for each municipality individually, should they wish to do so.

Article 19(1) NRR provides that each Member State shall review and revise its National Restoration Plan (NRP) and include supplementary measures by June 2032 and June 2042. Reviews shall be carried out in accordance with Articles 14 and 15, considering progress made in the implementation of the plans, the best available scientific evidence as well as available knowledge of changes related to climate change. Given the reference to Article 14 and in the absence of specific provisions limiting the possibility to update the urban ecosystem area mapping exercise in 2032, the 2032 revision of the NRPs could provide an opportunity to revise the boundaries/definition of the urban ecosystem areas mapped in the first NRP. However, this possibility is to be seen in the context of Article 8 which requires that from 2030 onwards all urban ecosystem areas must show an increasing trend towards a satisfactory level of urban green space and tree canopy cover (that will have been established by 2030 as set out in Article 14(5)(d) and (e)). Therefore, any changes in ecosystem area boundaries in 2032 would need to be duly justified to show that they would ensure the continued effective implementation of the Regulation.

Reporting and setting satisfactory levels should be based on the best Local Administrative Units / Grid Cell classification, as close to 2024 as possible (entry into force of the Nature Restoration Regulation). The Local Administrative Unit classification for 2024 will be available in 2025. The best available data on urban centres and urban clusters comes from 2021 and is already available. The revision of the National Restoration Plans will be an opportunity to make revisions from 2032 if appropriate due to changes in the classification that have taken place (see the answer to the question on urban ecosystem area definition above for more details).

Article 9 applies to any river in the geographical scope of the NRR, as set out in Article 2.  It is not limited to water bodies reported under the Water Framework Directive (WFD). More generally, it is worth noting that Article 9 targets the removal of barriers to “the connectivity of surface waters”. Surface waters also include lakes and coastal waters.

The objective to restore 25,000 km is an EU-level objective, set out in the EU Biodiversity Strategy for 2030. It is not ‘split up’ in quantitative targets per Member State. Each Member State has to indicate in its draft NRP how much it will contribute, so that the Commission can evaluate this contribution when it assesses the draft NRP under Article 17(2)(c).

Measures taken under the WFD can help Member States to comply with Article 9 NRR, as river continuity, connection to groundwater bodies, and structure of the riparian zone, which are among the relevant criteria listed in Annex V WFD for assessing the ecological status of a river under the WFD, pertain respectively to longitudinal, vertical, and lateral connectivity, which are the three dimensions of connectivity tackled by Article 9 of the NRR. However, that provision has more stringent connectivity objectives, since it aims at removing artificial barriers, while under the WFD, mitigating them (for example with a fish pass in the case of barriers to longitudinal connectivity) can be considered as sufficient to reach the environmental objectives. Besides, the NRR tackles the removal of lateral barriers more explicitly than the WFD, as well as the restoration of the related floodplains, so that it looks at the river ecosystem in a wider sense.

The provision refers to rivers (and related floodplains) restored under Article 9(2) and Article 9(3). However, it is to be noted that the WFD includes a non-deterioration provision in Article 4(1)(a) (i) that applies to all water bodies in the scope of that Directive and that river continuity is one of the hydromorphological quality elements listed under Annex V WFD for the assessment of the status of water bodies for the purpose of the WFD.

Article 9 of the NRR requires Member States to take measures to improve river connectivity to contribute to the restoration targets under Article 4, as well as to the target of 25 000 km of free-flowing rivers set out in the EU Biodiversity Strategy for 2030.

In order to help Member States estimate the number of km of free-flowing rivers, the use of the methodology developed by the JRC (JRC technical report on free-flowing rivers) is recommended.

The JRC technical report on free-flowing rivers is the result of a technical exercise done in the framework of the work of the working group ECOSTAT (ECOlogical STATus) of the Common Implementation Strategy (CIS) of the WFD to help Member States identify stretches of rivers that are free-flowing or that can become free-flowing by removing certain barriers. It is a non-binding guidance document the use of which is recommended by the European Commission, so as to ensure a coherent assessment of the contribution of Member States to the objectives of the Biodiversity Strategy 2030.

Although an initial version of the report was published, the work is still in progress, and the methodology is currently being tested on a wider scale to establish if it is fit for purpose and user-friendly. This sort of “sensitivity analysis” will allow the core group of ECOSTAT working on free-flowing rivers to make adjustments and adapt the methodology, and finetune with the objective of publishing it as a CIS guidance document endorsed by the Water Directors in Autumn 2025.

The 25 000 km of free-flowing rivers target is set out in the biodiversity Strategy 2030, which was published in 2020. Hence, in accordance with Article 15(3) (i) NRR and Recital 50, which provides that the restoration of at least 25 000 km needs to be compared to 2020, 2020 is the starting point for estimating the length of free-flowing rivers.

The 25 000 km should be additional to the length of free-flowing rivers in 2020 – if a river stretch was restored before 2020 or was always free-flowing, it cannot be included in the NRP.

Article 3(22) of the NRR states that ‘free-flowing river’ means a river or a stretch of river the longitudinal, lateral and vertical connectivity of which is not hindered by artificial structures forming a barrier and the natural functions of which are largely unaffected. The term barrier is thus to be understood as an artificial structure and hence as a physical obstacle, likely to have an impact on river ecosystem connectivity (impeding migration of aquatic species or connection to flood plains for example). Natural obstacles are not considered as barriers.

Article 9 of the NRR requires the removal of artificial barriers to the connectivity of surface waters to contribute to the NRR’s restoration targets (specified in Article 4) and fulfilling the objective of restoring at least 25 000 km of rivers into free-flowing river by 2030.

Dams and weirs are examples of artificial barriers in the longitudinal dimension, and their removal will contribute to Article 9 targets by restoring longitudinal connectivity. Dykes are examples of barriers in the lateral dimension and their removal will contribute to Article 9 targets by providing more space to river dynamics and restore lateral connectivity.  In this regard it is important to note that it is for Member States to identify the barriers that need to be removed and that they should primarily target obsolete barriers, which are no longer needed for renewable energy generation, flood protection or other uses.

The formulation in Annex VII NRR, which includes examples of restoration measures, ‘remove longitudinal and lateral barriers’ means removing barriers which are situated across the main flow of the river as well as along the river on the floodplain.

The 25,000 km of free-flowing rivers target by 2030 is an EU-level target set in the European Biodiversity Strategy for 2030. Article 9 NRR requires Member States, by removing barriers and restoring connectivity, to contribute to this EU-level target. As stated in Article 9(1), the obligations under Article 9 however also aim to contribute to meeting the restoration targets set out in Article 4 to restore habitats and therefore continue to apply even after 2030. 

Only the Court of Justice of the European Union is competent to authoritatively interpret Union law. However, the European Commission advocates for a common approach among Member States. As such, the unaltered use of the JRC methodology is strongly recommended, so as to ensure a coherent assessment of the free-flowing status of rivers at the European scale. In order to foster the wide use of the methodology, its revised version, currently in development with the aim to be a user-friendly and fit-for-purpose tool, will be published as a guidance document endorsed by the Water Directors in autumn 2025.

The monitoring methods are specified in Annex IV of the NRR. Sources of relevant data and guidance are indicated below.

a) Grassland Butterfly index (GBI):

• Butterfly Conservation Europe (BCE) is responsible for the European Butterfly Monitoring Scheme (eBMS) and the calculation of the GBI from these data.

• The GBI on a national (or regional) level has to be calculated, produced and published by each National or Regional co-ordinator of the Member State Butterfly Monitoring Scheme (BMS), or, in cases where there are more BMS's per country, this can be done on country level by co-operation between all the co-ordinators in a particular country. 

• Member States are invited to contact BCE in order to get in touch with their national coordinators for the BMS, and to see the stage of development of the national GBI.

b)    Stock of organic carbon in cropland mineral soil

• Currently, this indicator can be calculated based on comparable data available at national level based on LUCAS Soil Module and the CAP Context Indicator for arable land https://agridata.ec.europa.eu/extensions/DashboardIndicators/Soil.html (the units are different, therefore, a conversion is needed).

• The latest data point is 2018. Samples collected in 2022 are currently being analysed and an update should be available during 2026.

• Member States may also have data relevant for calculating this indicator in their reporting under the Regulation on land use, land use change, and forestry (LULUCF), based on their national measurements of soil organic carbon concentration combined with national modelling. However, those data may not be comparable between countries.

• The methodology in Annex IV of the NRR also refers to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories, which describe the use of a tiered approach to estimate/assess national inventories of greenhouse gas fluxes (emissions and sinks).

• A proposal for a Directive on Soil Monitoring and Resilience is currently being discussed. If adopted, its monitoring requirements would provide the best available, comparable data on SOC concentration as key input for the NRR indicator.

c)     Share of agricultural land with high-diversity landscape features:

This indicator is composed of different elements:

• The I.21 indicator under Regulation (EU) 2021/2115 on Strategic Plans under the Common Agricultural Policy for the landscape features and areas, based on the latest update of LUCAS for landscape features, 2024 update: JRC Publications Repository - Estimation of the share of Landscape Features in agricultural land based on the LUCAS 2022 survey
  

• For Land Laying Fallow: Farm Structure Surveys (now called ‘Integrated Farm Statistics Survey’)
  

• where applicable, for high diversity landscape features not covered by the methodology above (productive trees part of sustainable agroforestry systems, trees in extensive old orchards on permanent grassland, and productive elements in hedges):  methodology developed by Member States in accordance with Article 14(7) of the NRR and with the related Guidance adopted by the Commission.
  This means that the data to be used depends on the Member States’ choice of methodology.

d)    Common farmland bird index:

• Bird monitoring schemes are in place in all EU Member States. They are produced and owned by Birdlife in 21 Member States, by museums of natural history, research institutes, state institutes, universities in 6 Member States. The European Bird Census Council (EBCC) and the PanEuropean Common Bird Monitoring Scheme (PECBMS) use the national monitoring schemes to create the EU index and can play a facilitating role for questions addressed to the national monitoring schemes.

• A national Common Farmland Bird Index is produced in all EU Member States annually, the information is publicly available in 13 Member States, is used in 22 Member States and can be shared with national authorities in 25 Member States.

• Overview: Countries | PECBMS - PECBMS.

• This means practically all Member States already have access to the data required for the index.

According to Art 11(2), the indicator trend should be ‘measured in the period from 18 August 2024 until 31 December 2030, and every six years thereafter, […]’.

Art 20(3) provides: ‘The monitoring in accordance with paragraph 1, points (b), (c), (d), (e) and (f), shall start on 18 August 2024.’ Whereby (c) refers to 3 of the indicators of agricultural ecosystems and (d) refers to the Common Farmland Bird indicator.

So the baseline should be the first value of the indicator measured on or after the date of entry into force. In practice, in absence of a monitoring value at or soon after the entry into force, the most recent available value could also be used as a baseline (for indicators that are already being monitored and reported).

For the Common Farmland Bird Index, the baseline is more specifically defined in Art 11(3): ‘indexed on 1 September 2025 = 100’.

There is no definition of agricultural ecosystems in the NRR. 

In recital 59 of the NRR , ‘agricultural use’ is explained as ‘grassland and cropland use’. Recitals 54 to 56 also include useful elements explaining Article 11. The meaning of ‘ecosystem’ is defined in Article 3(1).

The typology of ecosystems[1] that is being developed to support Member States in filling in the uniform format of the National Restoration Plan, includes a description of croplands and grassland ecosystems, which can be used as a basis to determine areas included in agricultural ecosystems.

In addition, the Food and Agricultural Organisation (FAO) defines Agricultural ecosystems as those "ecosystems that are used for agriculture". Agro-ecosystems comprise polycultures, monocultures, and mixed systems, including crop-livestock systems, agroforestry, agro-silvo-pastoral systems, pastures and fallow lands. Their interactions with human activities are determinant.[2]

Moreover, under the Common Agricultural Policy: [3]

• ‘Agricultural area’ has to be defined by Member States in their CAP Strategic Plans ‘in such a way as to comprise arable land, permanent crops and permanent grassland, including when they form agroforestry systems on that area.’

• ‘Agricultural activity’ has to be determined ‘in such a way that it allows to contribute to the provision of private and public goods through one or both of the following: (a) the production of agricultural products, which includes actions such as raising animals or cultivation including by way of paludiculture, where agricultural products means products listed in Annex I to the TFEU with the exception of fishery products, as well as cotton and short rotation coppice; (b) the maintenance of the agricultural area in a state which makes it suitable for grazing or cultivation, without preparatory action going beyond the use of usual agricultural methods and machinery.’

In summary, ‘agricultural ecosystems’ in the context of Article 11 of the NRR could be understood as ecosystems occurring in cropland and grassland that are managed through agricultural practices. A (non-binding) description will be available in the typology of ecosystems accompanying the uniform format for the National Restoration Plan.

Notes

[1] This will be made available on the NRR Reference Portal (https://biodiversity.europa.eu/europes-biodiversity/nature-restoration/reference-portal-for-nature-restoration-regulation)

[2] Source: Sustaining the Multiple Functions of Agricultural Biodiversity. Background Paper 1: Agricultural Biodiversity, FAO, Issues Paper: The Multifunctional Character OF Agriculture and Land

[3] Regulation (EU) 2021/2115, https://eur-lex.europa.eu/eli/reg/2021/2115/2024-05-25/eng

A single restoration measure put in place on one area can contribute to several restoration targets. If under Article 11(4) an area with organic soils is rewetted and taken out of agricultural use, for example because it is converted/restored to a natural wetland habitat type, the restoration could contribute towards the targets under Article 4 for the restoration of a habitat, as well as to Article 11(4), as the restoration of organic soils under agricultural use, through rewetting or other measures, is the explicit objective of Article 11(4). It should however be noted that restoring organic soils under agricultural use under Article 11(4) does not necessarily mean taking agricultural land out of production: restored or rewetted peatlands can continue to be used productively in alternative ways (e.g. paludiculture, low-intensity grazing).

Land that was already abandoned and is no longer under agricultural use, would not be considered an agricultural ecosystem. If such land is restored to a habitat type, the restoration could contribute to Article 4 and/or, if it is restored to an agricultural ecosystem such as grassland, it could contribute to Article 11.

However, it is to be noted that when it comes to ‘counting’ the area in km² for the purpose of the relevant section in the NRP, an area will only count once when calculating the overall contribution to the EU target set out in Article 1(2).

The increasing trend is to be measured for the indicator at national level. Similarly, the satisfactory level applies to the indicator at national level.

The guidance is available here:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ%3AC_202500980&qid=1739516368582

The modalities of informing the Commission of this methodology are not specified in the NRR. This could be discussed in the NRR Expert Group, which aims among others at fostering coordination and exchange of information and best practices among Member States.

Annex IV describes three productive high-diversity landscape features elements, namely productive trees part of sustainable agroforestry systems, trees in extensive old orchards on permanent grassland and productive elements in hedges. Annex IV provides that these can be considered as high-diversity landscape features if they comply with certain conditions. Article 14(7) moreover states that each Member State may develop a methodology to monitor these productive elements. Therefore, it is not an obligation for Member States to include them in the monitoring.

See EUROSTAT glossary on ‘Utilized Agricultural Area’:
https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Glossary:Utilised_agricultural_area_(UAA)

The description of the indicator and the monitoring methods are specified in Annex IV of the NRR. For the high-diversity landscape features not covered by the common methodology, guidance is provided in the Commission Notice C/2025/980.

The Regulation does not define the term ‘peatland’. However, it is a well-known term for which definitions exist. Recital 59 refers to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories[1].

Notes

[1] Regulation (EU) No 691/2011:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02011R0691-20250101

According to Art 12(2) and 12(3) of the NRR, Member States have to achieve an increasing trend at national level ‘measured in the period from 18 August 2024 until 31 December 2030, and every six years thereafter […]’.

Art 20(3) provides: ‘The monitoring in accordance with paragraph 1, points (b), (c), (d), (e) and (f), shall start on 18 August 2024.’ Whereby (e) and (f) refer to the indicators in forest ecosystems.

So the baseline should be the first value of the indicator measured on or after the date of entry into force. In practice, in the absence of a monitoring value at or soon after the entry into force, the most recent available value could also be used as a baseline (for indicators that are already being monitored and reported).

Article 3 (14) defines ‘native tree species’ as ‘a tree species occurring within its natural range, past or present, and dispersal potential, i.e. within the range it occupies naturally or could occupy without direct or indirect introduction or care by humans;’

The NRR does not set numerical criteria (e.g. for the natural range), but guidance is available in  the Guidelines on Biodiversity-Friendly Afforestation, Reforestation and Tree Planting, section 1.3.2.

The regulation does not include a definition of the term ‘forest’, neither does it refer to other definitions.  However, a useful definition is provided in the forest accounts module of the Regulation on European environmental economic accounts[1], in the EU Regulation on deforestation-free products[2], and by the Food and Agricultural Organisation (FAO)[3], namely: ‘forest’ means land spanning more than 0,5 hectares with trees higher than 5 metres and a canopy cover of more than 10%, or trees able to reach those thresholds in situ, excluding land that is predominantly under agricultural or urban land use.

The Commission is offering, in support to Member States in the preparation of their National Restoration Plans, a note on the use of an (non-binding) ecosystem typology.  The note will be uploaded on the NRR reference portal.

Notes

[1] Regulation (EU) No 691/2011, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02011R0691-20250101

[2] Regulation (EU) 2023/1115, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231461

[3] Global Forest Resources Assessment 2000, FAO, Appendix II: Terms and Definitions, https://www.fao.org/4/Y1997E/y1997e1m.htm#bm58

This is explained in Recital 63: ‘When planning and putting in place the restoration measures necessary to enhance biodiversity in forest ecosystems and when setting satisfactory levels for biodiversity indicators for forests, Member States should take into account the risks of forest fire, based on local circumstances. Member States should make use of best practices to reduce such risks, particularly as described in the Commission’s Guidelines on land-based wildfire prevention issued in 2021.’

The abovementioned guidelines are available here:
https://op.europa.eu/en/publication-detail/-/publication/4e6cc1f1-8b8a-11eb-b85c-01aa75ed71a1

Article 12(1) states that Member States shall put in place the restoration measures necessary to enhance biodiversity of forest ecosystems, in addition to the areas that are subject to restoration measures taken under Article 4(1), (4) and (7). This provision therefore aims at covering other areas than those covered by measures taken under Article 4, and thus its scope goes beyond the habitats listed in Annex I and beyond Natura 2000 areas. Recital 62 explains, in relation to Article 12, that ‘Restoration measures need to be put in place to enhance the biodiversity of forest ecosystems across the Union, including in the areas not covered by habitat types falling within the scope of Directive 92/43/EEC.’ It also explains that the indicators are needed because of the absence of a common method to measure the condition of forest ecosystems that would allow for the setting of specific restoration targets for forest ecosystems.

‘Enhanced connectivity’ and ‘landscape diversity’ are not the only guiding factors to consider under Article 14(6). They are prominent examples - factors to consider “in particular”- as provided in Article 14(6)).  That Article sets out one of the steps to take in the preparation of the national restoration plan, which is to identify and map areas in need of restoration, with as examples the areas that, due to intensification or other management factors, are in need of enhanced connectivity and landscape diversity. The fact that Article 12(3) sets different indicators to be increased, indicates that there are also other factors to be considered than those in Article 14(6).

Article 14(6) can be seen as a preparatory step in relation to Article 15(3)(a) which refers to ‘the quantification of the areas to be restored to meet the restoration targets set out in Articles 4 to 12 based on the preparatory work undertaken in accordance with Article 14 and indicative maps of potential areas to be restored’.

Article 13 requires Member States to aim to contribute to the EU-level commitment of planting at least three billion additional trees by 2030, when planning and implementing Articles 4 and Articles 8 to 12. As mentioned in recital 64) of the NRR: ‘An online tree counter is available as a tool to record contributions to and progress on the commitment and Member States should document trees planted in the tool.’ The recital also refers to the Commission Guidelines of 17 March 2023 on biodiversity-friendly afforestation, reforestation and tree planting. It is for Member States to plan the concrete implementation. Natural regeneration is considered and also recommended practice for increasing the number of trees under the 3 billion trees pledge (SWD(2021) 651 final).  

Under Article 13(2), Member States have to ensure that their contribution to fulfilling the commitment of planting 3 billion additional trees is achieved in full respect of ecological principles, and that the measures to achieve that commitment ‘shall be based on sustainable afforestation, reforestation and tree planting’. As indicated in recital 64, the framework of ecological principles is articulated in the Commission Guidelines of 17 March 2023 on biodiversity-friendly afforestation, reforestation and tree planting.

Recital 64 also refers to the online tree counter where Member States should document trees planted under the commitment of planting 3 billion additional trees. The Commission website on Three Billion Additional Trees by 2030 explains the procedure to do so.

Article 21(1)(d) of the NRR specifies that Member States will have to report, at specified intervals, their contribution to the commitment referred to in Article 13. Article 21(3) states that the format, structure and detailed arrangements for the presentation of the reporting information required will be established by means of implementing acts. The Commission will investigate if the information that Member States provide in the online tree counter could be re-used to pre-fill the NRR reporting format for the obligation under Article 13, but this cannot yet be confirmed.

Article 13 relates explicitly to the planning of additional trees. The meaning of additionality is explained in the Commission Staff Working Document ‘The 3 Billion Tree Planting Pledge For 2030’. Replacing existing trees with more biodiversity-friendly resilient trees can be considered to fulfil additionality.
In case of replacement of existing trees (for example  replanting native trees or more resilient trees), it is recommended to also apply the principle of “the right tree in the right place for the right purpose”, in line with the Commission Guidelines of 17 March 2023 on biodiversity-friendly afforestation, reforestation and tree planting, under the New EU Forest Strategy for 2030.