The two dates that mark the end of the Facility
Regulation (EU) 2021/241 provides that national plans must include a timetable of reforms and investments «to be completed by 31 August 2026» (art. 18.4.i) and that the Commission’s decision must set a deadline, no later than that date, for achieving the final milestones and targets (art. 20.5.d). Art. 24.1 adds that payments to the Member State are to be made «by 31 December 2026 at the latest». On 04/06/2025 the Commission published a communication providing guidance on closure, «NextGenerationEU – The road to 2026», which emphasises both dates.
It is important not to confuse the two levels: these dates govern the relationship between the Commission and the Member State. The implementation and justification deadlines for your specific aid are set by the grant rules, the call for applications and the award decision, and may be different.
| Date | What happens | Legal basis |
|---|---|---|
| 31/08/2026 | Deadline for achieving the plan’s final milestones and targets | Arts. 18.4.i and 20.5.d of Regulation (EU) 2021/241 |
| 31/12/2026 | Deadline for the Commission’s payments to the Member State | Art. 24.1 of Regulation (EU) 2021/241 |
| After 2026 | Document retention, checks and, where applicable, repayments | Art. 22.2 of Regulation (EU) 2021/241 and Law 38/2003 |
What the PRTR management system requires
Order HFP/1030/2021 of 29 September sets up the Plan’s management system and passes on to calls for applications obligations that the beneficiary must be able to demonstrate:
- DNSH principle (do no significant harm to the environment), art. 5.
- Prevention of fraud, corruption and conflicts of interest, with an anti-fraud plan and declarations of absence of conflict of interest (DACI) by those involved in the procedures, art. 6.
- Prohibition of double funding: the same expenditure cannot be financed twice, art. 7.
- Identification of the recipient (tax identification number, tax address) and acceptance of data sharing between public authorities, art. 8.
- Communication: use of the official logo and reference to EU funding, art. 9.
In addition, art. 22.2 of the Regulation requires data to be collected on the final recipient, its contractors and subcontractors and their beneficial owners, and empowers the Commission, OLAF, the European Court of Auditors and the European Public Prosecutor’s Office to exercise their rights of control.
Justification: grant expenditure statement and auditor’s report
Many PRTR grants are justified by means of a grant expenditure statement with an auditor’s report (cuenta justificativa con informe de auditor, art. 74 of Royal Decree 887/2006), which the auditor issues in accordance with Order EHA/1434/2007. Some programmes, such as several PERTEs (strategic projects for economic recovery and transformation), publish their own instructions for that report. Before the review, it is advisable to have the following ready:
- Report on activities demonstrating fulfilment of the purpose and of the milestones assigned.
- Classified list of expenditure with invoices, proof of payment and separate recording in the accounts.
- Procurement files, or the three quotes where required by law.
- Supporting evidence for DNSH, DACI, publicity and absence of double funding.
If your entity receives more than €600,000.00 in grants in a financial year, remember that the Second Additional Provision of the Regulation implementing the Spanish Audit Act (Royal Decree 2/2021) requires that financial year, and those in which the operations are carried out, to be subject to an audit of annual accounts.
Document retention and subsequent checks
The end of the Facility does not close the files. Art. 22.2.f of the Regulation requires documents to be kept in accordance with art. 132 of the EU Financial Regulation, and the Spanish General Grants Act (Law 38/2003) requires them to be kept for as long as they may be subject to verification and control (art. 14.1.g). The right to demand repayment is generally time-barred after four years (art. 39), subject to grounds for interruption. Keep a complete archive that can be located by project.
Frequently asked questions
Does my justification deadline end on 31/08/2026?
Not necessarily. That date refers to the milestones of the national plan. Your deadline is the one set by the grant rules and the award decision, including any extensions.
What happens if I do not meet a PRTR condition?
It may lead to full or partial repayment with late-payment interest, according to the grading criteria in the grant rules. That is why it is advisable to review the documentation before submitting it.
Can I destroy the documentation once the aid has been received?
No. You must keep it for as long as it may be subject to national or EU checks, and for the applicable limitation periods.
Official sources
- Regulation (EU) 2021/241 establishing the Recovery and Resilience Facility (EUR-Lex)
- OJ L 57 of 18/02/2021, published text of the Regulation (copy on the BOE website)
- Order HFP/1030/2021, PRTR management system (BOE)
- Law 38/2003, General Grants Act (BOE)
- Royal Decree 887/2006, Regulation implementing the General Grants Act (BOE)
- Order EHA/1434/2007, rules of procedure for auditors reviewing grant expenditure statements (BOE)
- Recovery, Transformation and Resilience Plan (Government of Spain)
If your entity manages NextGenerationEU aid, our grant audit team can review your grant expenditure statement and issue the required auditor’s report. We are a ROAC-registered firm based in Alicante; meet our auditors in Alicante or contact us to plan your justification before your deadline expires.
Article prepared by Controlaudit’s technical team. Published on 14/07/2026. Reviewed on 08/10/2026. Content for information only that is no substitute for professional advice on your specific case.