As the EU negotiates its 2028–2034 Multiannual Financial Framework, Aqua Publica Europea is calling on the European Commission, the Parliament, and the Council, to go beyond just mentioning water resilience in the MFF to actually invest in it. Our position paper sets out seven targeted, realistic changes to the MFF's legal texts that would close the gap between the EU's water policy ambitions and its investment reality.
1. Water resilience must be embedded in the MFF's allocation architecture and adequately prioritised.
Water resilience to be identified as a clear investment priority for less developed regions under Art. 22(2)(a) of the NRP Fund regulation.
Water vulnerability indices (WEI+ and Water Availability Index) to be added as allocation criteria under Annex VII of the NRP Fund regulation.
Water resilience and the circular water economy to be explicitly included in Art. 3(1) of the ECF, with dedicated funding calls in work programmes under Art. 33.
2. The MFF's tracking methodology must recognise water infrastructure for what it is: a climate adaptation and social investment.
The 100% climate coefficient for water resilience infrastructure in the delegated act under Art. 4(4) of the Performance Framework Regulation.
100% social objective recognition for investments in access to water and sanitation services, consistent with the European Pillar of Social Rights and the human right to water, on equal terms with the 14% social spending floor under Art. 10 of the NRP Fund regulation.
3. River basin is the most appropriate scale for water resource management: Public water operators and public authorities must be integrated in investment planning under the different MFF funds.
Public water operators are explicitly named as partners in NRP Plan preparation under Art. 6 of the NRP Fund regulation.
A dedicated water operator seat in the ECF Strategic Stakeholders Board (Art. 14) and Clean Transition window consultation platforms.
4. The MFF's performance framework must be designed around how water infrastructure actually works.
Water-specific milestone definitions and force majeure provisions must be built into NRP Plan design in implementing rules.
Harmonised water indicators aligned with UWWTD and WFD reporting frameworks, incorporated into the Performance Framework Regulation's single intervention field system under Articles 8 and 14.
5. Funding priorities of the MFF should be aligned with legal requirements and environmental targets under recently revised water legislation.
ECF work programmes under Art. 33 to include dedicated calls for micropollutant treatment technology, nature-based solutions for water management, and research on climate-hydrological cycle impacts.
A formal inter-DG coordination mechanism between DG ENV and DG GROW/RTD to align ECF work programme timing with UWWTD compliance deadlines.
6. Water infrastructure must be treated as the critical infrastructure it already is under EU law.
Water infrastructure explicitly named alongside energy and transport in the NRP Fund's security provisions, with CER Directive obligations (Art. 12–15) recognised as an investment driver eligible for EU co-financing, and water infrastructure protection included in the ECF's Resilience and Security window.
7. The MFF must provide a dedicated financial vehicle to mobilise investment in water resilience at the scale the sector requires.
A dedicated water resilience compartment within the ECF InvestEU Instrument, explicitly covering UWWTD-driven capital investments, with the Water Resilience Investment Accelerator anchored to this instrument.
