PRTR Funds Without Deadline: What Changes for Executing Entities of the Recovery Plan

Key data

Executing entities of the Recovery, Transformation and Resilience Plan (PRTR) that still have pending expenses to allocate have a new opportunity: the Government has eliminated the deadline for executing those expenses, provided they are linked to actions that have contributed to the value declared to the European Commission in certified milestones or objectives on time.

The measure is articulated through the Agreement of the Council of Ministers of September 1, 2026, published by Resolution of the Under-Secretariat on September 12, 2026, and develops the third additional provision of Royal Decree-Law 18/2026, of June 29. It enters into force on the same day of its publication in the BOE.

What does this regulation establish?

The Recovery and Resilience Mechanism (MRR) program technically closed on August 31, 2026. Facing that closure, many executing entities found themselves with expenses already incurred or committed that had not been able to be formally allocated within the ordinary deadline.

This resolution establishes a special regime with the following specific rules:

The central mechanism is the certification of link: each executing entity must issue a document that proves that the expense in question is linked to an action that contributed to the value declared to the European Commission in milestones or objectives included in payment requests submitted or to be submitted on time.

Economic and operational impact

The impact of this measure is twofold: it avoids the loss of already certified European funds and reduces the risk of reimbursement for entities that had expenses in irregular situation due to the technical closure of the program.

From an operational perspective, the most relevant changes are:

• Comptrollers: can no longer reject an expense solely because it occurred outside the ordinary MRR deadline, provided the entity provides certification of link to certified milestones.
• Executing entities: must prepare and keep certification documentation for each expense they want to cover under this regime.
• Remainders: unjustified funds are not automatically lost; they may be redirected to new actions within the same policy areas of the PRTR, which opens an additional planning window.
• Service 50 PGE item: expenses allocated to this item are those most likely to benefit from this flexibility, as it is the usual channel for MRR funds in the General State Administration.

Who does it affect?

• Public administrations (state, regional and local) acting as executing entities of the PRTR.
• Public bodies and public sector entities managing projects financed with MRR funds.
• Comptrollers and internal control bodies that oversee expenses allocated to service 50 of the PGE or other items linked to the PRTR.
• Project managers and financial officers of entities with actions linked to milestones or objectives of the PRTR certified before the European Commission.
• Advisors and consultants accompanying public entities in the justification and closure of PRTR projects.

Practical example

An autonomous community executing a public services digitalization project included in the PRTR incurred consulting expenses in July 2026, but was unable to formally allocate them before the technical closure of the program on August 31, 2026.

Under the new regime, the autonomous community can continue allocating those expenses if:

1. It proves that the digitalization action contributed to the value declared to the European Commission in a milestone or objective included in a payment request submitted or to be submitted on time.
2. It issues the corresponding certification of link for each expense.
3. It presents that certification to the comptroller, who must consider the expense valid without being able to reject it on grounds of deadline.

If the autonomous community also has remainders of unjustified MRR funds in that project, it may redirect them to other actions within the same policy area of the PRTR (for example, other digitalization initiatives), thus avoiding the return of funds to the European Commission.

What should entities do now?

1. Identify all pending expenses to be allocated linked to PRTR actions, especially those allocated or allocable to service 50 of the PGE, that could not be formalized before August 31, 2026.
2. Verify the link of each expense to milestones or objectives certified before the European Commission in payment requests submitted or to be submitted on time. Without this link, the expense cannot be covered by the new regime.
3. Issue the certification of link for each expense to be allocated under this special regime. This document is the enabling requirement before the comptroller.
4. Inform comptrollers of the new regime and available documentation, to avoid rejections on grounds of deadline that are no longer appropriate.
5. Analyze unjustified remainders and evaluate whether they can be redirected to actions in the same policy areas of the PRTR, before the obligation to return becomes consolidated.
6. Document and file all traceability between expenses, actions, certified milestones and payment requests, given that this documentation will be key in any subsequent audit by the European Commission or the Court of Auditors.

Official source

Consult complete regulation in official source

Notice: This article is merely informative in nature and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-19104