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.

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.

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.

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.

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.

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 2026.

These terms are not defined in the NRR. An example could be the failure by a neighbouring third country to take measures to stop or reduce pollution affecting ecosystems in the territory of the Member States.

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).

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)).

According to Articles 3(4) and 3(8) NRR, the improvement of the habitat condition under Art. 4(1) as well as the re-establishment of area of habitat types under Art. 4(4) are to contribute to reaching favourable conservation status for these habitat types. Re-establishment measures taken under Article 4(4) in areas where those habitat types do not occur, are meant to lead, in the end (usually after various stages where these newly established areas are not yet in good condition), to areas of an Annex I habitat type in good condition. In order not to jeopardise the re-establishment efforts, areas where such habitat types were re-established are to be followed up, if needed – i.e. where good condition is not yet reached -, with the measures necessary to achieve (or maintain) good condition. Re-established areas that have as a result become an Annex I habitat but are not yet in good condition should become part of the 100% baseline of targets under Article 4(1).

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 .

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. The following Member States have notified their intention to use Article 4(13) to the Commission: Austria, Belgium, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Lithuania, Netherlands, Poland, Slovenia, Sweden.

If a Member State 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 after restoration (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.
• For areas in good condition or necessary to meet restoration targets (Article 4(12)):
  For these areas, Article 4(13) applies at the latest by the date of publication of the final National Restoration Plan (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 applied and outlines specific monitoring requirements that must be fulfilled in that case. It requires the monitoring of:

• The extent and location of those 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.

The additional monitoring required for Member States applying Article 4(13), outlined in Article 20(1)(j), can be highly targeted, focusing on the areas where significant deterioration is allowed and the areas designated for compensation, which should be clearly identified.

As regards the monitoring of condition of habitat types, the recently published Technical Guidelines for assessing and monitoring the condition of Annex I habitat types may be a helpful support tool for Member States in developing, improving and adapting national monitoring systems under Article 20(1)(h) and (j) NRR. Article 20(5) lays down that the specific monitoring requirements under 20(1)(j) start applying as soon as the notification under Article 4(13) is submitted to the Commission, i.e. in February 2025. However, as stated above, Article 4(13) is a derogation to both Articles 4(11) and 4(12), which follow a different timeline.

Consequently, for areas covered by Article 4(11), this provision requires Member States to put in place measures aiming to ensure that these areas do not significantly deteriorate, without any specific start date, hence from the entry into force of the NRR. The monitoring obligations under Article 20(1)(j) can thus apply as soon as the Member State submits its notification to the Commission (from 19 February 2025, as set out in Article 4(13)).

For areas covered by Article 4(12), this provision requires Member States to endeavour to put in place measures aiming to prevent significant deterioration by the date of publication of the national restoration plan in accordance with Article 17(6) NRR. In practice, Member States who choose to apply Article 4(13) will therefore be able to start applying the specific monitoring requirements under Article 20(1)(j) once they start putting in place the required measures, at the latest by the date of publication of the National Restoration Plans.

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.

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.

According to Article 7(1), when putting in place restoration measures for the purposes of Article 4(1), (4) or (7) or Article 5(1), (2) or (5), Member States may exempt areas used for activities the sole purpose of which is national defence if those measures are deemed to be incompatible with the continued military use of the areas in question.

Article 7(1) does not provide for a general derogation to the restoration targets under Articles 4 and 5 NRR. The use of the derogation is conditional: the activities should have national defence as sole purpose and restoration measures should be deemed incompatible with the continued military use of the area.

If the conditions of Article 7(1) are met, the relevant areas can be exempt from certain restoration measures that are incompatible with the military use (while other types of measures could be considered as compatible with the military use). It is up to the Member State to assess whether the derogation can apply.

The fact that certain areas can be exempt from restoration measures does however not mean that the relevant restoration targets under Articles 4(1), (4) and (7) and 5(1), (2) and (5) can be lowered. It means that, as a consequence of the exemption of certain areas used for military purposes, restoration measures will need to be put in place on other areas, to be determined by the Member State, in order to reach the restoration targets.

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.  

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).

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).

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 2031, Member States shall achieve an increasing trend in the total national area of urban green space as well as an increasing trend in tree canopy cover for each urban ecosystem towards satisfactory levels (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).

Yes. According to Article 14(4), the urban ecosystem area of a city or of a town and suburb shall include (a) either the entire city or town and suburb or (b) parts of the city or of the town and suburb, including at least its urban centres, urban clusters and, if deemed appropriate by the Member State concerned, peri-urban areas. If option (b) is selected, all the urban centres and urban clusters must be included in the urban ecosystem area. However, Member States are free to add other areas located within the same LAU.

In this case only the part of the grid cell located within the boundaries of the local administrative unit (LAU) should be considered, in line with the definition under Article 3(16) NRR and Article 4b(2) Regulation (EC) No 1059/2003.  If any part of a grid cell extends beyond the borders of the LAU in question, that part should not be included in any calculations relating to that LAU (although it may fall within another LAU covered by the Regulation).

Not necessarily. The Urban Ecosystem Area must consist of ‘at least’ the urban centres and urban cluster grid squares withing the relevant LAUs in accordance with Article 14(4)(b), but beyond this Member States are free to define the boundaries of the urban ecosystem area (and any peri-urban area), within the relevant LAU, as they wish. So it does not have to be grid based.

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.

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 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. 

Article 9 NRR requires Member States to take measures to improve river connectivity (by making an inventory of artificial barriers, identifying the barriers to be removed and removing them) 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 resulting from these measures, the use of the methodology from the CIS guidance on criteria for identifying free-flowing river stretches, endorsed by Water Directors in November 2025, available at this link) is recommended.

Fields 9.2.1.1 - 9.2.1.4, 9.3.1.1 and 9.3.1.2, of the uniform format for the National Restoration Plan  set out in Regulation (EU) 2025/912 should be filled-in according to the definition of ‘free-flowing river’ provided in article 3(22). A river only partially corresponding to this definition should not be reported as free-flowing in these fields of the uniform format. The Common Implementation Strategy (CIS) guidance on criteria for identifying free-flowing rivers elaborates on this definition, and its unaltered use is strongly recommended, so as to ensure a coherent assessment of the free-flowing status of rivers at the European scale. It is available at this link.

Notwithstanding the above point, there can be a merit in reporting partial progress, i.e. the increase of free-flowing characteristics with regard to at least some of the assessment criteria laid down in the CIS guidance. Field 9.1.1 (optional free-text box) of the uniform format could, on a voluntary basis, be used by Member States to provide information on partial progress in achieving free-flowing rivers. The issue is currently being discussed in the relevant Commission expert group and an addendum to the CIS guidance on criteria for identifying free-flowing stretches will be discussed in 2026, so as to enable a standardized reporting of such partial progress.

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.

The CIS guidance is the result of a technical exercise done in the framework of the working group ECOSTAT (ECOlogical STATus) of the CIS of the Water Framework Directive 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 and of the NRR. This CIS guidance, endorsed by the Water Directors on 28 November 2025, builds upon an initial version of the methodology developed by the Commission’s Joint Research Centre in 2024, which is now outdated. This CIS guidance is available at this link.

Only the Court of Justice of the European Union is competent to authoritatively interpret Union law. Therefore, as regards the legally binding definition of free-flowing rivers under Article 3(22) NRR, it is not mandatory to use the CIS guidance on criteria for identifying free-flowing river stretches. However, the European Commission advocates for a common approach among Member States, so as to ensure a coherent and comparable assessment of the free-flowing status of rivers at the European scale. To this end, the CIS guidance document on criteria for identifying free-flowing river stetches has been endorsed by the Water Directors in November 2025 as a best practice methodology for assessing whether a river is free-flowing. Member States have the possibility to further refine the methodology described in the CIS guidance at the national level to accommodate local specificities.

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 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.

Yes, the Commission has adopted a delegated Regulation establishing a science-based method for monitoring pollinator diversity and pollinator populations. This common framework ensures that the annual data collected across all national territories is comparable and reliable, providing a clear and statistically robust picture of progress toward the 2030 target. At the same time, the monitoring method provides flexibility to Member States to address local environmental conditions, which means that they can specify for example the conditions under which transect walks or light traps shall be undertaken or placed. The Commission i) provides technical capacity building for pollinator monitoring and identification through the European Pollinator Identification Courses (EPIC), ii) supports administrative capacity building through the European Observation Coordination Centre (EBOCC) and iii) assists with a practical set-up of the monitoring scheme through the Joint Research Centre’s helpdesk.  

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) (in accordance with the relevant IPCC guidelines) based on their national measurements of soil organic carbon concentration combined with national modelling.

• Once implemented, the monitoring requirements under the Soil Monitoring Directive will provide additional, comparable data on Soil Organic Carbon. Synergies will be sought in the monitoring and reporting processes under the SMD and the NRR, in order to reduce the burden on Member States.

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 that has been 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.[1]

Moreover, under the Common Agricultural Policy: [2]

• ‘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 has been made available in the typology of ecosystems accompanying the uniform format for the National Restoration Plan.

Notes

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

[2] 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 an agricultural area is restored and taken out of agricultural use, for example because it is converted/restored to a wetland habitat type, or habitat of a species, the restored area could contribute towards the targets under Article 4 and to Article 11(1), as well as to the targets under Article 11(4), if the area falls under the category of ‘organic soils under agricultural use constituting drained peatlands’. 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).

The grassland butterfly index included in the GBI methodology mentioned in Annex IV NRR covers 17 species. For some Member States, only a number of these species are present on their territory, so the degree of relevance of the index can vary. An approach could be to monitor the GBI based on the species present in the respective Member State and to explain the context and species which could not be monitored in the relevant field of the NRP. However, Article 15(3)j requires to justify that the chosen indicators are suitable to demonstrate the enhancement of biodiversity in agricultural ecosystems within the Member States concerned. As Member States have to select 2 out of 3 indicators for agricultural ecosystems, under Article 11(2), another approach could also be to select the high-diversity landscape features and soil organic carbon indicators, if the GBI is not suitable.

Independently of the NRR requirements, all Member States are encouraged to set up national butterfly monitoring schemes, with all species considered relevant for their ecosystems. The EU- funded EMBRACE project, implemented by Vlinderstichting in collaboration with Butterfly Conservation Europe, the UK Centre for Ecology & Hydrology and Butterfly Conservation UK, is providing support to Member States for that purpose.

The delegated Regulation, published in November 2025, specifies the sampling protocol to be applied in the implementation of the pollinator monitoring method under Article 10, to be executed by skilled experts acting in a professional or voluntary capacity. The monitoring sites are to be selected by a stratified random selection protocol, covering also other ecosystem types than grassland, and ensuring a representative coverage of the whole territory of the Member State. This requirement is not compatible with site selection that citizens typically undertake under the European Butterfly Monitoring Scheme that currently supports the Grassland Butterfly Index (GBI) in most Member States. This scheme is also less stringent with respect to the field monitoring (e.g. in terms of the length of the transect, duration of the observation time, etc), which reinforces the incompatibility with the Article 10 monitoring.

Thus, data generated through GBI monitoring with the method specified in Annex IV, cannot feed into the pollinator monitoring method set by the Delegated Regulation under Article 10. However, data generated through the latter could be taken into account for the calculation of the GBI under Article 11.

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

Yes. Under the Soil Monitoring Directive (SMD) of 12 November 2025, Member States have to monitor, assess and report soil organic carbon stocks in accordance with Regulation 2018/1999 and the 2006 IPCC Guidelines for National Greenhouse Gas Inventories. SMD data collection will be supported by the LUCAS (Land Use and Coverage Area frame Survey) Soil campaign based on Member States’ needs and existing methods. This is compatible with the monitoring methodology set out in Annexes IV and VI NRR. Synergies will be sought in the monitoring and reporting processes under these different legislations, in order to reduce the burden on Member States, taking into account the specificities of the different indicators and within the boundaries of the requirements of each legislative act.

Annex IV NRR states that the methodology to monitor the stock of organic carbon in cropland mineral soils is as set out in Annex V to Regulation (EU) 2018/1999 in accordance with the 2006 IPCC Guidelines for National Greenhouse Gas Inventories and as supported by the Land Use and Coverage Area frame Survey (LUCAS) Soil. According to Article 20(7) NRR, the indicators for agricultural and forest ecosystems are monitored in a manner consistent with the monitoring under Regulations (EU) 2018/841 and (EU) 2018/1999.

Both Article 20(7) and Annex IV emphasise the alignment with the methodologies used under Regulation (EU) 2018/1999 (i.e. the Governance Framework for the Energy Union and Climate Action), which requires the use of “a system for the monitoring of soil carbon stocks, using, inter alia, annual land use/cover area frame statistical survey (LUCAS) datasets.” (see Annex V, Part 3, point (e)). Therefore, Member States may rely on LUCAS in combination with equivalent national data sources, provided methodological consistency with the above-mentioned regulations and with LUCAS is ensured. It should be noted that LUCAS monitoring for soil is being adjusted under the Soil Monitoring Law so the convergence and complementarity with developing national monitoring will increase.   

According to Article 11(2)(b) Member States shall put in place measures which shall aim to achieve an increasing trend at national level of at least two out of three indicators for agricultural ecosystems, including stock of organic carbon in cropland mineral soils.

Measures aiming merely at slowing down the decline in soil organic carbon stocks, rather than aiming at reversing the decline to achieve an increasing trend at national level, would not fulfil the obligation of Article 11(2)(b). It is to be noted that under Article 11(2), the obligation for Member States is framed as an obligation to “put in place measures which shall aim to achieve an increasing trend”. This obligation is met when a Member State has put in place such measures and these measures are suitable to reach the aim of increasing the trend in soil organic carbon at national level.

The view that soil organic carbon stocks cannot increase under climate change is not supported by scientific assessments. For example, the IPCC, while acknowledging that climate change will have significant impacts on soil health indicators such as soil organic matter, highlights with a high level of confidence that soil carbon sequestration is an important strategy to improve crop and livestock production sustainably that could be applied at large scales and at a low cost, if there was adequate institutional support and labour, using agroforestry, conservation agriculture, mixed cropping and targeted application of fertilizer and compost (IPCC AR6 Working Group II,Box 5.4: Soil Health).

If aiming to increase soil organic carbon is harder to achieve in certain regions, Member States could still meet the requirement under Article 11(2)(b) by aiming to increase soil organic carbon levels in other regions, as the increasing trend has to be measured at national level.

The NRR provides a clear process for realistic target-setting. By the end of 2028, the Commission will adopt a guiding framework for defining “satisfactory levels” for agricultural indicators, in accordance with Article 20(10). Member States will then set their national satisfactory levels by 2030, as provided in Article 14(5), taking into account their specific climate, soil and agronomic conditions. This process supports the establishment of targets that are evidence-based and adapted to national circumstances.

A slowing down of a decline in soil organic carbon, instead of an increase (towards a level that is set at national level), would therefore not fulfil the obligation under Article 11(2)(b).

The Regulation does not define the term ‘peatland’. The Regulation does also not define the depth of peat nor the required level of water-table constituting re-wetting. However, recital 59 refers to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories[1]. Moreover, Article 3(23) states that ‘rewetting peatland’ means the process of changing a drained peat soil towards a wet peat soil.

Notes

[1] Publications - IPCC-TFI

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

The NRR does not specify if and how the Member States should inform the Commission of the methodology that Member States may develop under Article 14(7). The information could be expected to be provided when Member States report on monitoring results. The Commission will establish, in due time, the format and process for this reporting, in accordance with Article 21(3). This will 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.

According to the Commission Notice C/2025/980, the baseline is the value of the indicator based on the monitoring data at the date of entry into force of the NRR, or based on the most recent data acquired before the entry into force. If the most recent data is not valid and cannot be used, then this should be justified/explained.

According to the Commission Notice C/2025/980, the baseline value is the value of the HDLF indicator based on the monitoring data at the date of entry into force of the NRR, or based on the most recent data acquired before the entry into force.

The HDLF indicator is composed of up to three elements. For the non-productive elements, monitoring is based on the LUCAS Landscape Features survey and the last survey (2022) can be used as baseline.  For fallow land, monitoring is based on EUROSTAT Farm Structure survey so baseline data at the date of entry into force of the NRR is available. For productive landscape features, as described in Commission Notice C/2025/980, Member States may develop methodologies to complement the methodology referred to in Annex IV NRR, within the framework of the guidance provided by the above-mentioned Notice. Therefore, the baseline for productive landscape features should be the first value measured on or after the date of entry into force of this methodology. For the calculation of the HDLF indicator, the sum of up to three of these elements (depending on Member States’ choice on whether to include also fallow land and productive features) needs to be divided by the Utilised Agricultural Area (UAA), for which baseline data at the date of entry into force of the NRR is available. In any case, the methodology applied by the MS to monitor and calculate its HDLF indicator needs to be consistent over time, to ensure trends can be determined.

LUCAS data could suffice for non-productive landscape features, as described in Annex IV NRR. Data on land laying fallow could be added - although not an obligation - in the way described in the chapter ‘Area of reference’ of the Commission Notice C/2025/980, and if it complies with the criteria in Annex IV of the Nature Restoration Regulation. The methodology adopted for the baseline should then remain consistent throughout monitoring, to be able to calculate trends.

Article 14(7) NRR states that each Member State may develop a methodology to complement the methodology referred to in Annex IV, in order to monitor HDLFs not covered by the common methods. National methodologies may need adjustments at some point, to take into account new knowledge; however, Articles 11(2) and 20(6) refer to measurements until 2030 and every 6 years thereafter. Therefore, a proper assessment of increasing trends requires a methodology that is sufficiently stable over time, so as to not fundamentally alter the consistency of the measurements over time.

Annex IV NRR states that the methodology to monitor non-productive landscape features is as developed under indicator I.21, Annex I of Regulation 2021/2115, as based on latest updated version of LUCAS for landscape elements. The LUCAS Landscape Features (LF) module provides a consistent and comparable quantification of LFs for the EU and Member States level. The LUCAS methodology is updated on a regular basis to enhance the reliability of the data used at EU and national level. The NRR requirement to use LUCAS LF was set to ensure comparability among Member States. To ensure such comparability, Member States should only use LUCAS LF module for non-productive landscape features). Using data from the LUCAS LF surveys also reduces Member States’ monitoring burden.

However, features that may not be included as HDLF can still be recognised in the national restoration plan. Article 11(1) requires Member States to put in place restoration measures to enhance biodiversity in agricultural ecosystems more broadly. Within this framework, ecologically valuable features not captured by the Article 11(2) indicator may still be reported and promoted under Article 11(1).

It is to be noted that other types of high diversity landscape features (fallow land and certain productive landscape features) are to be determined by other methodologies (as set out in Annex IV NRR).

For landscape features covered by common monitoring methods as described in Annex IV of the NRR, these methods should be used. More specifically, the LUCAS methodology should be used for non-productive landscape features.

The LUCAS Landscape Features (LF) Module is a survey based on a model developed to collect and standardize data on non-productive landscape features across the EU. It ensures that the data collected is harmonized and comparable across all EU Member States and it provides a consistent quantification of landscape features for the EU and Member State levels. It is to be noted that he LUCAS methodology is updated on a regular basis to enhance the reliability of the data used at EU and national level.

In order to ensure comparability and consistency in the implementation of the NRR, the identification of non-productive landscape elements should therefore be based on the sampling points included in the LUCAS LF sample dataset, without being complemented by national data sources, based on different sampling points than LUCAS LF.

In order to fall under the category of “high-diversity landscape feature” (HDLF) as described in Annex IV NRR, landscape features (buffer strips, hedgerows, ditches, field strips etc.) need to comply with the two conditions listed in points a) and b) of that Annex. Point a) provides that they cannot be under productive agricultural use (including grazing or fodder production), unless such use is necessary for the preservation of biodiversity, and point (b) that they should not receive fertilizer or pesticide treatment, except for low input treatment with solid manure. As only non-productive landscape features are in the scope of the LUCAS Landscape Feature (LF) methodology, which must be used by Member States to account for the non-productive parts of the HDLF under the NRR, by definition point a) is complied with. Regarding condition b), it can be assumed that the non-productive features monitored by LUCAS LF do not receive fertilizer or pesticide treatment, as such treatment is usually applied for productive purposes.

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 description of the indicator in Annex VI NRR refers to forests dominated by native tree species (see definition in the FAQ above ). While the referenced Forest Europe methodology defines ‘share of forest dominated by introduced species’, it applies the nomenclature of the FAO Forest Resources Assessment, which distinguishes between native species, introduced species and naturalised species. Naturalised species are naturally regenerating introduced species which date of introduction is older than 250 years. They would therefore not be considered as ‘native’ under the NRR.

According to Article 20(11)(b) NRR, the Commission has the possibility to specify, by means of implementing acts, the methods for monitoring the indicators for forest ecosystems listed in Annex VI. This option will be discussed in the NRR expert group.

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.

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).

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

‘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’.

According to Article 20(11)(c), the Commission may develop a guiding framework for defining satisfactory levels for the forest indicators in Article 12(2) and (3). Article 20(11)(b) and (c) provide that the Commission may specify the methods for monitoring the indicators for agricultural and forest ecosystems listed in Annexes IV and VI. Developing such guidance, by means of implementing acts, is optional, not mandatory. The opportunity and scope for such guidance has started to be discussed in the Expert Group on the Nature Restoration Regulation, which  is gathering views from Member States and stakeholders. The Commission will carefully listen to the needs of Member States and also consider the specific situation of each indicator. Alternative options to implementing acts should also be considered if needed, such as non-binding guidance by the Commission (or none at all).

While extraordinary circumstances (such as a bark beetle outbreak) can lead to a significant increase of deadwood volumes, it is important that the baseline captures values and trends in the forest ecosystems at large, at or close to entry into force of the NRR. Article 12(3) specifies that ‘the trend shall be measured in the period from 18 August 2024 until 31 December 2030, and every six years thereafter, until the satisfactory levels as set in accordance with Article 14(5) are reached.’ At the time of reporting, an explanation could be provided on extraordinary circumstances that have influenced the baseline and monitoring.

Annex VI NRR refers to the methodology of FOREST EUROPE for determining and monitoring the deadwood indicators under Article 12(3) NRR and the latest available guidance from Forest Europe recommends  that the measurements should use a 10 cm threshold. The Annex also refers to methodologies applied for the reporting on deadwood carbon stock changes under the LULUCF Regulation, referring to the IPCC Guidelines for National Greenhouse Gas Inventories, whose Good Practice guidelines also refers to a standard 10 cm threshold. Moreover, deadwood with a higher diameter is generally a more suitable biodiversity indicator.

According to Article 20(11)(b) NRR, the Commission has the possibility to specify, by means of implementing acts, the methods for monitoring the indicators for forest ecosystems listed in Annex VI. This option will be discussed in the NRR expert group. In case different diameters are monitored in the ongoing data collection, bridging functions could be applied to obtain comparable data.

Article 12(3) lists standing and lying deadwood as two separate indicators. This separation is also reflected in Annex VI and has ecological reasons. Therefore, one indicator cannot substitute or be combined with the other one for the purpose of demonstrating compliance with Article 12(3). In addition, the uniform format for the national restoration plan treats the two indicators separately.

Annex VI NRR refers to the methodology of FOREST EUROPE and the latest available Forest Europe guidance suggests that for standing deadwood, the height of the snag should be at least 1.3 m while for lying deadwood, the piece should be at least 1m long.

In case different lengths are monitored in the ongoing data collection, bridging functions could be applied to obtain comparable data.

The methodology for the indicator “share of forests with uneven-aged structure” is described in Annex VI NRR ‘as developed and used by FOREST EUROPE, State of Europe’s Forests 2020, FOREST EUROPE 2020, and in the description of national forest inventories in Tomppo E. et al., National Forest Inventories, Pathways for Common Reporting, Springer, 2010.’ The indicator is described as share of forests available for wood supply (FAWS) with uneven-aged structure as compared to even-aged structure in forests’, meaning this refers to the share of the overall area of FAWS.

The exact classification of the developmental phases is currently not foreseen to be part of the monitoring and reporting. According to Article 20(11)(b) NRR, the Commission has the possibility to specify, by means of implementing acts, the methods for monitoring the indicators for forest ecosystems listed in Annex VI. This option will be discussed in the NRR expert group.

The NRR does not specify those aspects of the data collection method. Member States can use their sampling methods as in their National Forest Inventories, taking into account the recommendations of Forest Europe, as referred to in the indicator methodology in Annex VI of the NRR.

According to Article 20(11)(b) of the NRR, the Commission has the possibility to specify, by means of implementing acts, the methods for monitoring the indicators for forest ecosystems listed in Annex VI. This option will be discussed in the NRR expert group.

The threshold of “>50% coverage” indicated in the description of Annex VI is not the satisfactory level for the “share of forest dominated by native tree species”. It indicates the level of coverage above which forest or other wooded land can be considered dominated by native species (i.e. native species exceed 50% in terms of canopy cover or basal area).

For each indicator, the satisfactory level must be established nationally by each Member State. Under Article 14(5) NRR, satisfactory levels must be set through an open and effective process, grounded in the latest scientific evidence and, where applicable, taking into account the guiding framework that may be developed by the Commission under Article 20(11).

Yes, restoration and adaptation go hand in hand: healthy, biodiverse forests are more resilient to droughts, storms and pests, ensuring the long-term productivity and stability of Europe’s forest resource base. 

The NRR supports climate adaptation in forests: restoration aims to make ecosystems more resilient while at the same time ensuring biodiverse nature-near ecosystems.  Several provisions explicitly require taking into account climate change, for example for quantifying the favourable reference area of habitats (Article 14(2)(iii) and identifying areas for certain habitat types to be reestablished (Article 14(2)(iv)).  The non-deterioration rules allow habitat transformations caused by climate change (Articles 4(14)(b), 4(15)(b) and 4(16)(b)). 

Restoration of forest habitats listed under Annex I NRR should be carefully planned to increase their resilience and adaptive capacity. For example, depending on the forest type, such restoration could take the form of measures to diversify forest structure, promoting natural regeneration of climate-resilient native species or, where ecologically justified, assisted migration (the movement of tree species and populations to facilitate the natural expansion of their range in response to climate change). Such actions aim to reinforce the contribution of forest habitats to the NRR objectives as well as to the objectives of the Habitats Directive. 

The NRR also includes derogations on non-fulfilment of certain forest related indicators, in case of habitat transformation directly caused by climate change (Article 12(4)(b)). 

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.