The deadline for implementing reforms and investments under the European Recovery and Resilience Mechanism has expired, but the money is not lost at the same time. The dividing line is between the implementation of the milestones, the submission of the last request and the payment itself. By August 31, 2026, countries should have completed all agreed milestones and targets. They could send their last requests by September 30, and the European Commission has until December 31 to make the payments. In 2027, there will be no payments under this mechanism.
This means that after the August deadline, a new law, completed project or administrative action can no longer be used to remedy an unfulfilled commitment. The European Commission explicitly states that actions taken after 31 August cannot be taken into account in the assessment. If a gap is identified after this date, the procedure is no longer a temporary suspension with the possibility of subsequent implementation, but a reduction of the financial contribution or the loan related to the specific commitment.
Bulgaria sends its last request
For Bulgaria, the next important stage is the assessment of the fifth and final request for payment. The Council of Ministers announced that the document was sent on 30 September and is worth 1.823 billion euros. It takes into account the last 59 stages and objectives, including reforms in the anti-corruption system, public procurement and water supply and sanitation.
However, this is the position of the Bulgarian government, not a final decision on payment. The Commission must verify whether the declared results meet the agreed requirements. Only after this assessment will it become clear what part of the amount will be paid, whether there will be reductions and which commitments will remain financially unsupported.
By the fourth payment, Bulgaria has received over EUR 4.169 billion, or about 68% of the total resources under its plan. The fourth payment was for EUR 896 million, after the Commission adopted 23 out of 26 stages and objectives. This is precisely the example that shows how the mechanism works after the deadlines have expired: the fulfilled part can be paid, but the funds related to the unfulfilled conditions remain in question.
What does this mean for the remaining funds
The money under the mechanism is not a refund of a specific invoice, but a financial contribution tied to the results of agreed reforms and investments. Therefore, a country may have spent funds on a given measure, but still not receive the full payment if the required stage has not been satisfactorily completed. The European Commission may approve the part for which the conditions are met and reduce the remaining amount.
Unreceived funding is not automatically transferred to another Bulgarian program and cannot be kept for a new period. The reason is that the mechanism is temporary and its funds are tied to specific plans, deadlines and objectives. After the end of 2026, reporting, control, audits and checks can continue, but not the new absorption of funds under the same instrument.
Thus, the question is no longer just how much money has been agreed, but how much of it will be recognized as earned by the last possible stage. For Bulgaria, the answer will depend on the assessment of the 59 reported objectives and the Commission's decisions on the amount of EUR 1.823 billion. There will be payments by the end of the year, but only for the part that will be confirmed as implemented.
Sources: reforms-investments.ec.europa.eu, eur-lex.europa.eu, gov.bg, ec.europa.eu, luxembourg.representation.ec.europa.eu