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    <titel>Unterrichtung durch das Bundesministerium der Finanzen gemäß § 9a des Gesetzes über die Zusammenarbeit von Bundesregierung und Deutschem Bundestag in Angelegenheiten der Europäischen Union&#xd;
Beitritt Kroatien zum Euroraum</titel>
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  <text>[Deutscher Bundestag Drucksache 20/2296 
20. Wahlperiode 17.06.2022 
Unterrichtung 
durch das Bundesministerium der Finanzen 
gemäß § 9a des Gesetzes über die Zusammenarbeit von Bundesregierung 
und Deutschem Bundestag in Angelegenheiten der Europäischen Union 
Beitritt Kroatien zum Euroraum* 
Schreiben des Bundesministerium der Finanzen – E B 3 – Vw 9536/13/10001 :009 – vom 
15. Juni 2022
Anlage 1 Wesentliche Ergebnisse der Konvergenzberichte der Europäischen 
Kommission und der Europäischen Zentralbank (EZB) 
Anlage 2 Konvergenzbericht der Europäischen Kommission (englisch) 
Anlage 3 Konvergenzbericht der EZB (englisch) 
Anlage 4 Vorschlag der Europäischen Kommission für einen Beschluss des 
Rates über die Einführung des Euros in Kroatien am 1. Januar 2023 
(englisch) 
Anlage 5 Vorschlag der Europäischen Kommission für eine Verordnung des 
Rates zur Änderung der Verordnung (EG) Nr. 974/98 des Rates im 
Hinblick auf die Einführung des Euros in Kroatien (englisch) 
Kroatien beabsichtigt, der dritten Stufe der Wirtschafts- und Währungsunion zum 
1. Januar 2023 beizutreten. Die am 1. Juni 2022 veröffentlichten
Konvergenzberichte der Europäischen Kommission und der Europäischen Zentralbank (EZB)
kommen zu dem Ergebnis, dass Kroatien die Voraussetzungen für den Beitritt
zum Euroraum, die sogenannten Konvergenzkriterien, erfüllt. Ebenfalls am
1. Juni 2022 hat die Europäische Kommission einen Vorschlag für einen
Beschluss des Rates vorgelegt, der das kroatische Beitrittsersuchen befürwortet und
die Ausnahmeregelung des Artikels 139 des Vertrages über die Arbeitsweise der
Europäischen Union (AEUV) für Kroatien aufhebt sowie – darauf aufbauend –
einen Vorschlag zur rechtlichen Umsetzung der Einführung des Euros in Kroatien.
* 
Die an den Deutschen Bundestag übermittelten Ursprungsdateien ermöglichten keine Weiterverarbeitung 
zu einer barrierefreien Bundestagsdrucksache.
Die Berichte der Europäischen Kommission und der EZB würdigen die
Anstrengungen Kroatiens, die Konvergenzkriterien für den Eurobeitritt zu erfüllen. Im 
Einzelnen attestieren die Berichte, dass die rechtliche Konvergenz gegeben ist, 
die Inflationsrate sowie der langfristige Zinssatz in der Referenzperiode unterhalb 
der Referenzwerte liegen, die Tragfähigkeit der öffentlichen Finanzen erreicht 
wird, die Wechselkursstabilität gegenüber dem Euro besteht und sich die
realwirtschaftliche Konvergenz als hinreichend darstellt.  
Die Bundesregierung teilt die Gesamteinschätzung der Konvergenzberichte und 
beabsichtigt, dem Beschlussvorschlag der Europäischen Kommission zum Beitritt 
Kroatiens zum Euroraum zuzustimmen. 
Auf europäischer Ebene ist für das weitere Verfahren ein enger Zeitplan
vorgesehen: Nach der politischen Beratung des Rates Wirtschaft und Finanzen am 
16./17. Juni 2022 zum Euroraumbeitritt Kroatiens sind entsprechend Artikel 140 
Absatz 2 AEUV als weitere Schritte vorgesehen – die Aussprache im
Europäischen Rat am 23./24. Juni 2022, die Anhörung des Europäischen Parlaments vom 
4. bis 7. Juli 2022 und die abschließende Entscheidung des Rates Wirtschaft und 
Finanzen am 12. Juli 2022.  
Das Gesetz über die Zusammenarbeit von Bundesregierung und Deutschem
Bundestag in Angelegenheiten der Europäischen Union (EUZBBG) sieht in § 9a ein 
besonderes parlamentarisches Beteiligungsverfahren für Fälle der Einführung des 
Euro in einem Mitgliedstaat vor. Vor der abschließenden Entscheidung im Rat 
sollen der Deutsche Bundestag und die Bundesregierung das Einvernehmen
herstellen. Ich weise den Deutschen Bundestag in diesem Zusammenhang
vorsorglich ausdrücklich auf sein verfassungsrechtliches Recht zur Stellungnahme hin. 
Im Hinblick auf den dargestellten, engen zeitlichen Beratungsverlauf auf
europäischer Ebene bitte ich den Deutschen Bundestag, von seinem Recht zur
Stellungnahme so frühzeitig wie möglich Gebrauch zu machen, damit die
Bundesregierung rechtzeitig – wenn möglich bereits in der Aussprache im Europäischen Rat 
am 23./24. Juni 2022 – diese Haltung zum Beitrittsgesuch Kroatiens
berücksichtigen kann. Die klare Positionierung Deutschlands zur Erweiterung der Eurozone, 
wenn alle Voraussetzungen für den Beitritt erfüllt sind, ist ein wichtiges Signal 
sowohl gegenüber Kroatien als auch für die Eurozone insgesamt.  
Mit Blick auf das Ziel, Einvernehmen mit dem Deutschen Bundestag herzustellen, 
stehe ich jederzeit für eine weitergehende Unterrichtung und Aussprache zur
Verfügung. Zur besseren Übersicht übersende ich Ihnen mit diesem Schreiben fünf 
Anlagen und verweise insbesondere auf Anlage 1 mit einer Darstellung der
wesentlichen Inhalte der Konvergenzberichte der Europäischen Kommission und der 
Europäischen Zentralbank.  
Die Bundesregierung wird im Rahmen ihrer fortlaufenden Unterrichtung über den 
Rat Wirtschaft und Finanzen kontinuierlich über die weitere Entwicklung der 
Vorgänge informieren.
Anlage 1 
Wesentliche Ergebnisse der Konvergenzberichte der Europäischen Union und der 
Europäischen Zentralbank für Kroatien (HRV) 
I. Wesentliche Ergebnisse der Konvergenzberichte 
Am 1. Juni 2022 veröffentlichten EZB und Europäische Kommission (KOM) ihre turnusmäßigen
Konvergenzberichte, die darlegen, inwieweit die EU Mitgliedstaaten außerhalb des Euroraums die Bedingungen für den
Beitritt zum Euroraum erfüllen und welche Fortschritte sie beim Konvergenzprozess erreicht haben. In den Berichten 
prüften die Organe, u.a. auch ob Kroatien einen hohen Grad an dauerhafter Konvergenz erreicht hat. Kroatien 
erfüllt nach Einschätzung der Europäischen Kommission und der EZB sämtliche Konvergenzkriterien, bestehend 
aus rechtlicher Konvergenz und vier wirtschaftlichen Kriterien (Preisstabilität, tragfähige öffentliche Finanzlage, 
Wechselkursstabilität gegenüber dem Euro und langfristiger Zinssatz). 
Rechtliche Konvergenz: KOM und EZB stimmen überein, dass die kroatischen Rechtsvorschriften im monetären 
Bereich mit EU-Recht konform sind, dazu zählen vor allem die Unabhängigkeit der Zentralbank, das Verbot 
monetärer Staatsfinanzierung und die rechtliche Integration der kroatischen Nationalbank (CNB) in das
Europäische System der Zentralbanken und der EZB. Die Satzung und das Gesetz über die CNB sind vollständig mit den 
Artikeln 130 und 131 des AEUV vereinbar. 
Preisstabilität: Für den zwölfmonatigen Referenzzeitraum von Mai 2021 bis April 2022 weist HRV eine
durchschnittliche Inflationsrate von 4,7 % aus. Sie liegt damit leicht unter dem Referenzwert von 4,9 %. KOM und 
EZB erwarten, dass die kroatische Inflationsrate 2022 mit 6,1% deutlich über den Referenzwert steigen wird. 
KOM prognostiziert, dass dieser Anstieg mit der Inflation im Euroraum, die sie in ihrer Frühjahrsprognose
ebenfalls auf 6,1% schätzt, übereinstimmen wird. Die Inflationszyklen HRVs seien bereits in hohem Maße mit dem 
Inflationszyklus des Euroraums synchronisiert. Der Referenzwert wurde berechnet, indem zum ungewichteten 
arithmetischen Mittel der im Referenzzeitraum gemessenen Inflationsraten von Frankreich (3,2 %), Finnland 
(3,3 %) und Griechenland (3,6 %) 1,5 Prozentpunkte addiert wurden. Die EZB äußert jedoch Bedenken
hinsichtlich der Nachhaltigkeit der Preisstabilität. Der weitere wirtschaftliche Aufholprozess dürfte zu erhöhten
Inflationsraten gegenüber dem Euroraum führen, da das BIP-pro-Kopf und das Preisniveau in HRV immer noch
niedriger sind als im Euroraum. Um den Aufbau eines übermäßigen Preisdrucks und makroökonomischer
Ungleichgewichte zu verhindern, muss der Aufholprozess durch geeignete strukturelle Maßnahmen unterstützt werden. 
KOM sieht dieses Risiko nicht und verweist darauf, dass HRV im Vergleich zu allen anderen Mitgliedstaaten 
zum Zeitpunkt des Euro-Beitritts den höchsten Grad an Preiskonvergenz mit dem Euroraum erreicht hat. 
Tragfähige öffentliche Finanzlage: 2021 lag das öffentliche Defizit bei 2,9 % des BIP, also knapp unterhalb des 
Maastricht-Referenzwertes von 3 %. Für 2022 erwartet die KOM ein öffentliches Defizit von 2,3 % des BIP. Vor 
der Pandemie hatte HRV einen ausgeglichenen Haushalt. Nachdem der öffentliche Schuldenstand in 2020 um 
16 Prozentpunkte auf 87 % des BIPs gestiegen war, sank er in 2021 auf 79,8 %. Er lag über dem Grenzwert von 
60 %. Laut EZB und KOM hat HRV seinen finanzpolitischen Rahmen verbessert, gleichzeitig sind noch weitere 
Fortschritte, inklusive der Umsetzung der Maßnahmen im Rahmen der Aufbau- und Resilienzfazilität
erforderlich, um die Schuldenquote auf einen dauerhaften Abwärtspfad zu bringen. Insgesamt erfüllt HRV laut KOM und 
EZB das Kriterium der tragfähigen öffentlichen Finanzen. 
Wechselkursstabilität gegenüber dem Euro: HRV nimmt seit dem 10. Juli 2020 und somit für den größten Teil 
des zweijährigen Referenzzeitraums vom 26. Mai 2020 bis zum 25. Mai 2022 am WKM II teil. Die kroatische 
Kuna wurde in den WKM II zu einem Leitkurs von 7,53450 Kuna pro Euro mit einer Standardschwankungsbreite 
von ±15 % aufgenommen. Im Referenzzeitraum wies der Wechselkurs der kroatischen Kuna gegenüber dem Euro 
ein geringes Maß an Schwankungsbreite auf und bewegte sich in der Nähe seines Leitkurses. Seit der Aufnahme 
der Kuna in den WKM II sowie während des gesamten Referenzzeitraums betrug die maximale Abweichung vom 
Leitkurs nach oben 1,0 %, während die maximale Abweichung nach unten 0,8 % betrug. 
Langfristiger Zinssatz: Der langfristige Zinssatz lag im Verlauf des Referenzzeitraums von Mai 2021 bis April 
2022 mit durchschnittlich 0,8 % unterhalb des Referenzwertes von 2,6 %. Der Referenzwert wurde berechnet, 
indem zum Zwölfmonatsdurchschnitt der langfristigen Zinssätze Frankreichs (0,3 %), Finnlands (0,2 %) und 
Griechenlands (1,4 %), die drei Länder, die auch in die Berechnung des Referenzwerts für das
Preisstabilitätskriterium einbezogen wurden, 2 Prozentpunkte addiert wurden.
Zusätzliche Punkte: HRV würde von Strukturreformen profitieren, die darauf abzielen, das institutionelle und 
unternehmerische Umfeld zu verbessern, den Wettbewerb auf den Gütermärkten anzukurbeln, Ungleichgewichte 
auf dem Arbeitsmarkt und Engpässe beim Arbeitskräfteangebot abzubauen und die Effizienz der öffentlichen 
Verwaltung und des Justizsystems zu steigern. Unter dem Punkt weitere Faktoren führt die KOM aus, dass HRV 
bei den Rahmenbedingungen für Unternehmen nach gängigen Indikatoren schlechter abschneidet, als die meisten 
MS des Euroraums. Die Reformen und Investitionen, die im kroatischen Aufbau- und Resilienzplan enthalten 
sind, adressieren einige der strukturellen Schwächen der HRV Wirtschaft. Dieser dürfte dazu beitragen, dass HRV 
mittelfristig auf einem nachhaltigen Konvergenzpfad bleibt. 
II. HRV Wirtschaftslage 
 2018 2019 2020 2021 2022 2023 
Reales BIP-Wachstum (in % ggü. Vorjahr)  2,9 3,5 -8,1 10,2 3,4 3,0 
Inflation (jahresdurchschnittlich in %)  1,6 0,8 0,0 2,7 6,1 2,8 
Haushaltssaldo (in % des BIP) 0,0 0,2 -7,3 -2,9 -2,3 -1,8 
Staatsverschuldung (in % des BIP) 73,3 71,1 87,3 79,8 75,3 73,1 
Struktureller Saldo (in % des BIP) -1,2 -1,4 -4,4 -3,1 -2,7 -2,3 
Leistungsbilanzsaldo (in % des BIP) 1,9 2,8 -0,9 3,3 1,7 0,3 
Arbeitslosenquote 8,5 6,6 7,5 7,6 6,3 6,0 
Quelle: KOM-Frühjahrsprognose 2022 (Mai 2022) 
Vor Beginn des Kriegs in der Ukraine, zeigten die Prognosen für HRV optimistische Entwicklungspfade im
Hinblick auf die zukünftige Wirtschaftsentwicklung sowie die Entwicklung von Defizit und Schuldenstand. Letztere 
sind während der Pandemie und auch als Folge zweier schwerer Erdbeben im Jahr 2020 deutlich angestiegen. Die 
wirtschaftlichen Entwicklungen im Jahr 2021 deuten auf eine vollständige V-förmige Erholung der kroatischen 
Wirtschaft hin, mit einer Reduktion des Defizits auf 2.9 % und des Schuldenstands auf 79,8 %.  
Auswirkungen des Kriegs in der Ukraine auf die HRV Wirtschaft sind spürbar (reflektiert in einer nach unten 
korrigierten Wachstumsprognose), halten sich aber im Rahmen. KOM geht für 2022 von einem nach wie vor 
soliden Wachstum von 3,4 % aus. Während Unsicherheit und Inflation zu einem Rückgang des privaten Konsums 
führen, wird angenommen, dass die Umsetzung des nationalen Aufbau- und Resilienzplans sowie der
beschleunigte Wiederaufbau nach den Erdbeben, die Wirtschaftsleistung durch steigende Investitionen positiv
beeinflussen werden. 
KOM prognostiziert für 2022 eine Inflationsrate von 6,1 %, die auf stark ansteigende Energie- und
Lebensmittelpreise zurückzuführen ist. Maßnahmen der HRV Regierung (u.a. Reduzierung von Energiesteuern) zielen darauf 
ab, die Haushalte zu entlasten. Es wird von einem bremsenden Effekt auf die Inflation ausgegangen. 
 
Convergence 
Report 
Economic and 
Financial Affairs
ISSN 2443-8014 (online)
2022
INSTITUTIONAL PAPER 179 | JUNE 2022
EUROPEAN ECONOMY
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 5 –
Anlage 2
European Economy Institutional Papers are important reports analysing the economic situation and 
economic developments prepared by the European Commission's Directorate-General for Economic and 
Financial Affairs, which serve to underpin economic policy-making by the European Commission, the Council 
of the European Union and the European Parliament.   
Views expressed in unofficial documents do not necessarily represent the views of the European Commission. 
LEGAL NOTICE 
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for the use that might be made of the information contained in this publication. 
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https://ec.europa.eu/info/publications/economic-and-financial-affairs-publications_en. 
Luxembourg: Publications Office of the European Union, 2022 
PDF       ISBN 978-92-76-43947-9       ISSN 2443-8014        doi:10.2765/804537    KC-BC-22-016-EN-N  
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CREDIT 
Cover photography: © iStock.com/Chepko 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 6 –
European Commission 
Directorate-General for Economic and Financial Affairs 
Convergence Report 
2022 
EUROPEAN ECONOMY    Institutional Paper 179
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 7 –
ABBREVIATIONS 
ii 
Member States 
BG Bulgaria 
CZ Czechia 
HR Croatia 
HU Hungary 
PL Poland 
RO Romania 
SE Sweden 
EA Euro area 
EA-19  Euro area, 19 Member States 
EA-18 Euro area, 18 Member States before 2015 
EA-17   Euro area, 17 Member States before 2014 
EU-28 European Union, 28 Member States 
EU-27 European Union, 27 Member States before July 2013 (i.e. EU-28 excl. HR) and from February 
2020 (i.e. EU-28 excl. UK) 
EU-25 European Union, 25 Member States before 2007 (i.e. EU-28 excl. BG, RO and HR) 
EU-15 European Union, 15 Member States before 2004 
Currencies 
EUR Euro 
BGN Bulgarian lev 
CZK Czech koruna 
HRK Croatian kuna 
HUF Hungarian forint 
PLN Polish zloty 
RON Romanian leu (ROL until 30 June 2005) 
SEK Swedish krona 
USD United States dollar 
Central Banks 
BNB Bulgarska narodna banka (Bulgarian National Bank – central bank of Bulgaria) 
ČNB Česká národní banka (Czech National Bank – central bank of Czechia) 
HNB Hrvatska narodna banka (Croatian National Bank – central bank of Croatia) 
MNB Magyar Nemzeti Bank (Hungarian National Bank – central bank of Hungary) 
NBP Narodowy Bank Polski (National Bank of Poland – central bank of Poland) 
BNR Banca Naţională a României (National Bank of Romania – central bank of Romania) 
Other abbreviations 
AMR Alert Mechanism Report 
BoP Balance of Payments 
CAR Capital adequacy ratio 
CBA Currency board arrangement 
CEE Central and Eastern Europe 
CIT Corporate Income Tax 
CPI Consumer price index 
CR5 Concentration ratio (aggregated market share of five banks with the largest market share) 
EC European Community 
ECB European Central Bank 
EDP Excessive Deficit Procedure 
EMU Economic and monetary union 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 8 –
iii 
ERM II Exchange rate mechanism II 
ESA European System of Accounts 
ESCB European System of Central Banks 
EU European Union 
Eurostat Statistical Office of the European Union 
FDI Foreign direct investment 
FGS Funding for Growth Scheme 
FSA Financial Supervisory Authority 
GDP Gross domestic product 
HICP Harmonised index of consumer prices 
HFSA Hungarian Financial Supervisory Authority 
IDR In-Depth Review 
MFI Monetary Financial Institution 
MIP Macroeconomic Imbalance Procedure 
NCBs National central banks 
NEER Nominal effective exchange rate 
NIK Najwyższa Izba Kontroli (Poland's Supreme Chamber of Control) 
NPL Non-performing loans 
OJ Official Journal 
OJL Official Journal Lex 
PIT Personal Income Tax 
PPS Purchasing Power Standard 
REER Real effective exchange rate 
RRF Recovery and Resilience Facility 
RRP Recovery and Resilience Plan 
SGP Stability and Growth Pact 
TFEU Treaty on the Functioning of the European Union 
ULC Unit labour costs 
VAT Value added tax 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 9 –
ACKNOWLEDGEMENTS 
iv 
The Convergence Report and its Technical Annex were prepared in the Directorate-General for Economic 
and Financial Affairs. The main contributors were Lucian Briciu, Staffan Linden, Adriana Reut, Virgilijus 
Rutkauskas, Matteo Salto and Vaclav Zdarek. 
Other contributors were Ronald Albers, Pedro Arevalo, Lucian Albulescu, Martin Åström, Cristiana Belu 
Manescu, Adrian Bodea, Alessandra Cepparulo, Stefan Ciobanu, Angela D’Elia, Lukas Demoen, Patrick 
D’Souza, Ben Deboeck, Milan Deskar-Skrbic, Dorel-Adrian Dumitrescu-Pasecinic, Hugo Ferradans 
Ramonde, Carmine Gabriele, Nicola Gagliardi, Gabriele Giudice, Oskar Grevesmuhl, Valeska Gronert, 
James Hinton, Martjin Hoogeland, Szabolcs Klubuk, Willem Kooi, Daniel Kosicki, Ingo Kuhnert, Ivan 
Lozev, Robert Markiewicz, Philipp Mohl, Allen Monks, Markus Münch, Eloise Orseau, Stéphanie 
Pamies, Anda Patarau, Gábor Pellényi, Arian Perić, Lucia Piana, Simona Pojar, Diana Radu, Ernesto 
Reitano, Vincent Rietvink, Maja Šamanović, Martina von Terzi, Daniel Vâlcu, Bartlomiej Wiczewski, 
Rafał Wielądek and Christos Zavos.    
Statistical assistance was provided by Luisa Boa and Puck Boom, administrative assistance by Erdemia 
Malagrida and Sien Vangompel. 
The report benefitted from comments and suggestions by Isabel Grilo, Charlotte van Hooydonk, Michael 
Stierle, Massimo Suardi, Septimiu Szabo and Luc Tholoniat.  
The report was coordinated by Adriana Reut under the supervision of Eric Ruscher, Head of Unit and 
approved by Lucio Pench, Director, Declan Costello, Deputy Director General, and Maarten Verwey, 
Director General. 
Questions and comments may be referred to Adriana Reut (adriana.reut@ec.europa.eu). 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 10 –
CONTENTS 
v 
Convergence Report 2022 1 
Convergence Report 2022 - Technical annex 33 
1. Introduction 35 
1.1. ROLE OF THE REPORT 35 
1.2. APPLICATION OF THE CRITERIA 38 
1.2.1. Compatibility of legislation 38 
1.2.2. Price stability 38 
1.2.3. Public finances 42 
1.2.4. Exchange rate stability 46 
1.2.5. Long-term interest rates 48 
1.2.6. Additional factors 49 
2. Bulgaria 53 
2.1. LEGAL COMPATIBILITY 53 
2.1.1. Introduction 53 
2.1.2. Central Bank independence 53 
2.1.3. Prohibition of monetary financing and privileged access 54 
2.1.4. Integration in the ESCB 54 
2.1.5. Assessment of compatibility 55 
2.2. PRICE STABILITY 55 
2.2.1. Respect of the reference value 55 
2.2.2. Recent inflation developments 55 
2.2.3. Underlying factors and sustainability of inflation 56 
2.3. PUBLIC FINANCES 59 
2.3.1. Recent fiscal developments 59 
2.3.2. Medium-term prospects 60 
2.4. EXCHANGE RATE STABILITY 62 
2.5. LONG-TERM INTEREST RATES 63 
2.6. ADDITIONAL FACTORS 63 
2.6.1. Developments of the balance of payments 64 
2.6.2. Market integration 66 
3. Czechia 71 
3.1. LEGAL COMPATIBILITY 71 
3.1.1. Introduction 71 
3.1.2. Central Bank independence 71 
3.1.3. Prohibition of monetary financing and privileged access 72 
3.1.4. Integration in the ESCB 72 
3.1.5. Assessment of compatibility 73 
3.2. PRICE STABILITY 73 
3.2.1. Respect of the reference value 73 
3.2.2. Recent inflation developments 73 
3.2.3. Underlying factors and sustainability of inflation 74 
3.3. PUBLIC FINANCES 77 
3.3.1. Recent fiscal developments 77 
3.3.2. Medium-term prospects 78 
3.4. EXCHANGE RATE STABILITY 79 
3.5. LONG-TERM INTEREST RATES 80 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 11 – 
vi 
3.6. ADDITIONAL FACTORS 81 
3.6.1. Developments of the balance of payments 82 
3.6.2. Market integration 83 
4. Croatia 87 
4.1. LEGAL COMPATIBILITY 87 
4.1.1. Introduction 87 
4.1.2. Central Bank independence 87 
4.1.3. Prohibition of monetary financing and privileged access 87 
4.1.4. Integration in the ESCB 87 
4.1.5. Assessment of compatibility 87 
4.2. PRICE STABILITY 87 
4.2.1. Respect of the reference value 87 
4.2.2. Recent inflation developments 88 
4.2.3. Underlying factors and sustainability of inflation 88 
4.3. PUBLIC FINANCES 91 
4.3.1. Recent fiscal developments 91 
4.3.2. Medium-term prospects 92 
4.4. EXCHANGE RATE STABILITY 94 
4.5. LONG-TERM INTEREST RATES 95 
4.6. ADDITIONAL FACTORS 96 
4.6.1. Developments of the balance of payments 97 
4.6.2. Market integration 98 
4.7. SUSTAINABILITY OF CONVERGENCE 101 
5. Hungary 109 
5.1. LEGAL COMPATIBILITY 109 
5.1.1. Introduction 109 
5.1.2. Central Bank independence 109 
5.1.3. Prohibition of monetary financing and privileged access 110 
5.1.4. Integration in the ESCB 111 
5.1.5. Assessment of compatibility 112 
5.2. PRICE STABILITY 112 
5.2.1. Respect of the reference value 112 
5.2.2. Recent inflation developments 112 
5.2.3. Underlying factors and sustainability of inflation 113 
5.3. PUBLIC FINANCES 116 
5.3.1. Recent fiscal developments 116 
5.3.2. Medium-term prospects 117 
5.4. EXCHANGE RATE STABILITY 119 
5.5. LONG-TERM INTEREST RATES 120 
5.6. ADDITIONAL FACTORS 121 
5.6.1. Developments of the balance of payments 122 
5.6.2. Market integration 123 
6. Poland 127 
6.1. LEGAL COMPATIBILITY 127 
6.1.1. Introduction 127 
6.1.2. Central Bank independence 127 
6.1.3. Prohibition of monetary financing and privileged access 128 
6.1.4. Integration in the ESCB 129 
6.1.5. Assessment of compatibility 130 
6.2. PRICE STABILITY 130 
6.2.1. Respect of the reference value 130 
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vii 
6.2.2. Recent inflation developments 130 
6.2.3. Underlying factors and sustainability of inflation 131 
6.3. PUBLIC FINANCES 133 
6.3.1. Recent fiscal developments 133 
6.3.2. Medium-term prospects 134 
6.4. EXCHANGE RATE STABILITY 136 
6.5. LONG-TERM INTEREST RATES 136 
6.6. ADDITIONAL FACTORS 137 
6.6.1. Developments of the balance of payments 138 
6.6.2. Market integration 139 
7. Romania 143 
7.1. LEGAL COMPATIBILITY 143 
7.1.1. Introduction 143 
7.1.2. Central Bank independence 143 
7.1.3. Prohibition of monetary financing and privileged access 144 
7.1.4. Integration in the ESCB 145 
7.1.5. Assessment of compatibility 145 
7.2. PRICE STABILITY 145 
7.2.1. Respect of the reference value 145 
7.2.2. Recent inflation developments 146 
7.2.3. Underlying factors and sustainability of inflation 147 
7.3. PUBLIC FINANCES 150 
7.3.1. Recent fiscal developments 150 
7.3.2. Medium-term prospects 151 
7.4. EXCHANGE RATE STABILITY 152 
7.5. LONG-TERM INTEREST RATES 153 
7.6. ADDITIONAL FACTORS 154 
7.6.1. Developments of the balance of payments 156 
7.6.2. Market integration 157 
8. Sweden 161 
8.1. LEGAL COMPATIBILITY 161 
8.1.1. Introduction 161 
8.1.2. Central Bank independence 161 
8.1.3. Prohibition of monetary financing and privileged access 162 
8.1.4. Integration in the ESCB 162 
8.1.5. Assessment of compatibility 163 
8.2. PRICE STABILITY 163 
8.2.1. Respect of the reference value 163 
8.2.2. Recent inflation developments 163 
8.2.3. Underlying factors and sustainability of inflation 164 
8.3. PUBLIC FINANCES 168 
8.3.1. Recent fiscal developments 168 
8.3.2. Medium-term prospects 168 
8.4. EXCHANGE RATE STABILITY 170 
8.5. LONG-TERM INTEREST RATES 171 
8.6. ADDITIONAL FACTORS 172 
8.6.1. Developments of the balance of payments 173 
8.6.2. Market integration 174 
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LIST OF TABLES 
2.1. Bulgaria - Components of inflation 55
2.2. Bulgaria - Other inflation and cost indicators 55
2.3. Bulgaria - Budgetary developments and projections (as % of GDP unless indicated 
otherwise) 59
2.4. Bulgaria - Balance of payments 65
2.5. Bulgaria - Market integration 68
2.6. Bulgaria - Allocation of assets by financial sub-sector 68
2.7. Bulgaria - Financing of the economy1) 68
3.1. Czechia - Components of inflation 73
3.2. Czechia - Other inflation and cost indicators 74
3.3. Czechia - Budgetary developments and projections (as % of GDP unless indicated 
otherwise) 76
3.4. Czechia - Balance of payments 81
3.5. Czechia - Market integration 84
3.6. Czechia - Allocation of assets by financial sub-sector 85
3.7. Czechia - Financing of the economy1) 85
4.1. Croatia - Components of inflation 88
4.2. Croatia - Other inflation and cost indicators 89
4.3. Croatia - Budgetary developments and projections (as % of GDP unless indicated 
otherwise) 91
4.4. Croatia - Balance of payments 97
4.5. Croatia - Market integration 100
4.6. Croatia - Allocation of assets by financial sub-sector 100
4.7. Croatia - Financing of the economy1) 101
5.1. Hungary - Components of inflation 112
5.2. Hungary - Other inflation and cost indicators 115
5.3. Hungary - Budgetary developments and projections (as % of GDP unless indicated 
otherwise) 116
5.4. Hungary - Balance of payments 122
5.5. Hungary - Market integration 123
5.6. Hungary - Allocation of assets by financial sub-sector 124
5.7. Hungary - Financing of the economy1) 125
6.1. Poland - Components of inflation 130
6.2. Poland - Other inflation and cost indicators 131
6.3. Poland - Budgetary developments and projections (as % of GDP unless indicated otherwise) 133
6.4. Poland - Balance of payments 138
6.5. Poland - Market integration 139
6.6. Poland - Allocation of assets by financial sub-sector 140
6.7. Poland - Financing of the economy1) 141
7.1. Romania - Components of inflation 146
7.2. Romania - Other inflation and cost indicators 146
7.3. Romania - Budgetary developments and projections (as % of GDP unless indicated 
otherwise) 149
7.4. Romania - Balance of payments 155
7.5. Romania - Market integration 158
7.6. Romania - Allocation of assets by financial sub-sector 159
7.7. Romania - Financing of the economy1) 159
8.1. Sweden - Components of inflation 163
8.2. Sweden - Other inflation and cost indicators 164
8.3. Sweden - Budgetary developments and projections (as % of GDP unless indicated 
otherwise) 167
8.4. Sweden - Balance of payments 173
8.5. Sweden - Market integration 175
8.6. Sweden - Allocation of assets by financial sub-sector 176
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ix 
8.7. Sweden - Financing of the economy1) 176
LIST OF GRAPHS 
2.1. Bulgaria - Inflation criterion 55
2.2. Bulgaria - HICP inflation 56
2.3. Bulgaria - Inflation, productivity and wage trends 58
2.4. Bulgaria - Fiscal stance and its components 61
2.5. Bulgaria - BGN/EUR exchange rate 62
2.6. Bulgaria - Annual effective interest rate spread to 1-M Euribor 63
2.7. Bulgaria - Long-term interest rate criterion 63
2.8. Bulgaria - Long-term interest rates 63
2.9. Bulgaria - Effective exchange rates 66
2.10. Bulgaria - 2020 World Bank's Worldwide Governance Indicators 67
2.11. Bulgaria - Foreign ownership and concentration in the banking sector 69
2.12. Bulgaria - Intra-EU integration in equity and debt portfolio investment 69
3.1. Czechia - Inflation criterion 73
3.2. Czechia - HICP inflation 74
3.3. Czechia - Inflation, productivity and wage trends 76
3.4. Czechia - Fiscal stance and its components 78
3.5. Czechia - CZK/EUR exchange rate 80
3.6. Czechia - 3-M Pribor spread to 3-M Euribor 80
3.7. Czechia - Long-term interest rate criterion 80
3.8. Czechia- Long-term interest rates 81
3.9. Czechia - Effective exchange rates 83
3.10. Czechia - 2020 World Bank's Worldwide Governance Indicators 84
3.11. Czechia - Foreign ownership and concentration in the banking sector 86
3.12. Czechia - Intra-EU integration in equity and debt portfolio investment 86
4.1. Croatia - Inflation criterion 88
4.2. Croatia - HICP inflation 88
4.3. Croatia - Inflation, productivity and wage trends 90
4.4. Croatia - Fiscal stance and its components 94
4.5. Croatia - HRK/EUR exchange rate 94
4.6. Croatia - 3-M Zibor(1) and 3-M NRR(2) spread to 3-M Euribor 95
4.7. Croatia - Long-term interest rate criterion 95
4.8. Croatia - Long-term interest rates 96
4.9. Croatia - Effective exchange rates 98
4.10. Croatia - 2020 World Bank's Worldwide Governance Indicators 99
4.11. Croatia - Foreign ownership and concentration in the banking sector 101
4.12. Croatia - Intra-EU integration in equity and debt portfolio investment 101
5.1. Hungary - Inflation criterion 112
5.2. Hungary - HICP inflation 113
5.3. Hungary - Inflation, productivity and wage trends 115
5.4. Hungary - Fiscal stance and its components 118
5.5. Hungary - HUF/EUR exchange rate 119
5.6. Hungary - 3-M Bubor spread to 3-M Euribor 120
5.7. Hungary - Long-term interest rate criterion 120
5.8. Hungary - Long-term interest rates 121
5.9. Hungary - Effective exchange rates 122
5.10. Hungary - 2020 World Bank's Worldwide Governance Indicators 123
5.11. Hungary - Foreign ownership and concentration in the banking sector 125
5.12. Hungary - Intra-EU integration in equity and debt portfolio investment 126
6.1. Poland - Inflation criterion 130
6.2. Poland - HICP inflation 131
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6.3. Poland - Inflation, productivity and wage trends 132
6.4. Poland - Fiscal stance and its components 135
6.5. Poland - PLN/EUR exchange rate 136
6.6. Poland - 3-M Wibor spread to 3-M Euribor 136
6.7. Poland - Long-term interest rate criterion 137
6.8. Poland - Long-term interest rates 137
6.9. Poland - Effective exchange rates 139
6.10. Poland - 2020 World Bank's Worldwide Governance Indicators 140
6.11. Poland - Foreign ownership and concentration in the banking sector 141
6.12. Poland - Intra-EU integration in equity and debt portfolio investment 141
7.1. Romania - Inflation criterion 146
7.2. Romania - HICP inflation 146
7.3. Romania - Inflation, productivity and wage trends 149
7.4. Romania - Fiscal stance and its components 152
7.5. Romania - RON/EUR exchange rate 153
7.6. Romania - 3-M Robor spread to 3-M Euribor 153
7.7. Romania - Long-term interest rate criterion 153
7.8. Romania - Long-term interest rates 154
7.9. Romania - Effective exchange rates 156
7.10. Romania - 2020 World Bank's Worldwide Governance Indicators 158
7.11. Romania - Foreign ownership and concentration in the banking sector 160
7.12. Romania - Intra-EU integration in equity and debt portfolio investment 160
8.1. Sweden - Inflation criterion 163
8.2. Sweden - HICP inflation 164
8.3. Sweden - Inflation, productivity and wage trends 166
8.4. Sweden - Fiscal stance and its components 169
8.5. Sweden - SEK/EUR exchange rate 170
8.6. Sweden - 3-M Stibor spread to 3-M Euribor 171
8.7. Sweden - Long-term interest rate criterion 171
8.8. Sweden - Long-term interest rates 172
8.9. Sweden - Effective exchange rates 174
8.10. Sweden - 2020 World Bank's Worldwide Governance Indicators 175
8.11. Sweden - Foreign ownership and concentration in the banking sector 177
8.12. Sweden - Intra-EU integration in equity and debt portfolio investment 177
LIST OF BOXES 
1.1. Article 140 of the Treaty 37
1.2. Assessment of price stability and the reference value 39
1.3. Excessive deficit procedure 43
1.4. Fiscal policy in the EU since COVID-19 crisis 45
1.5. A reinforced approach to ERM II participation by means of upfront policy commitments by 
the applicant Member States 47
1.6. Data for the interest rate convergence 49
1.7. The Macroeconomic Imbalance Procedure (MIP) 50
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 16 – 
Convergence Report 2022 
(prepared in accordance with Article 140(1) of the Treaty) 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 17 –
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Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 18 – 
3 
1. PURPOSE OF THE REPORT
The euro is meant to be the single currency of the European Union as a whole. It is
now used every day by around 343 million people in 19 Member States in the euro
area. The practical benefits include stable prices, lower transaction costs for people
and businesses, more transparent and competitive markets and increased intra-EU
and international trade. The euro is also the second most used currency worldwide.
Article 140(1) of the Treaty on the Functioning of the European Union (TFEU)
requires the Commission and the European Central Bank (ECB) to report to the
Council, at least once every 2 years, or at the request of a Member State with a
derogation1, on the progress made by Member States in fulfilling their obligations on
the achievement of economic and monetary union. The latest Commission and ECB
Convergence Reports were adopted in June 2020.
The 2022 Convergence Report covers the following seven Member States with a
derogation: Bulgaria, Czechia, Croatia, Hungary, Poland, Romania and Sweden2.
The staff working document accompanying this report provides a more detailed
assessment of the state of convergence in these Member States3.
Article 140(1) TFEU requires the reports to include an examination of the
compatibility of national legislation, including the statutes of the national central
bank, with Articles 130 and 131 TFEU and the Statute of the European System of
Central Banks and of the European Central Bank (‘the ESCB/ECB Statute’). The
reports must also examine whether a high degree of sustainable convergence has
been achieved in the Member State concerned by reference to the fulfilment of the
convergence criteria (price stability, public finances, exchange rate stability,
longterm interest rates), and by taking account of other factors relevant to economic
integration and convergence mentioned in the final sub-paragraph of Article 140(1)
TFEU. The four convergence criteria are developed further in a protocol annexed to
the Treaties (Protocol No 13 on the convergence criteria).
The outbreak of the COVID-19 pandemic in March 2020 led to a severe economic
downturn for the EU as a whole and in all Member States. Unprecedented action
taken at EU level and by the individual Member States cushioned the impact of the
crisis and led to a robust recovery in 2021. In particular, swift activation of the
general escape clause of the Stability and Growth Pact, coupled with the temporary
framework on State aid, enabled large-scale fiscal support in all Member States. The
ECB also took a broad set of monetary policy measures to preserve favourable
financing conditions for all sectors of the economy in order to support economic
activity and safeguard medium-term price stability. The roll-out of the Recovery and
Resilience Facility, which is the centrepiece of NextGenerationEU, is further
bolstering the EU’s resilience. At the same time, the strong recovery in 2021, supply
chain bottlenecks and a surge in energy prices contributed to a sharp rise in inflation
throughout 2021 and into 2022.
1  The Member States that have not yet fulfilled the necessary conditions for the adoption of the euro are referred to as ’Member States 
with a derogation’. Denmark negotiated an opt-out before the adoption of the Maastricht Treaty and does not participate in the third 
stage of economic and monetary union. 
2  Denmark has not expressed an intention to adopt the euro and is therefore not covered in the assessment. 
3  The cut-off date for the data used in this report is 18 May 2022. The convergence assessment is based on a range of monthly 
convergence indicators that are calculated up to April 2022.  
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 19 –
4 
Russia’s invasion of Ukraine on 24 February 2022 forced a re-assessment of the 
outlook for the EU economy, which had been expected to expand strongly in 2022 
and 2023. The crisis has mainly dealt a new supply-side shock to an economy that 
was already facing inflationary pressures. It has weakened recovery prospects and 
reinforced upward price pressures, while further underlining the need for greater 
private and public investment to diversify Europe’s energy supplies and improve 
energy security. Several of the Member States with a derogation assessed in this 
report are among the most heavily exposed to the crisis triggered by Russia’s 
invasion of Ukraine. To varying degrees, this exposure reflects the relatively high 
energy intensity of their economies, strong dependency by some on Russian gas and 
oil supplies, trade linkages with Russia and the provision of frontline assistance to 
people fleeing Ukraine. The Commission proposed a REPowerEU plan on 18 May 
2022, for which the Recovery and Resilience Facility will be a key tool. It aims to 
phase out dependence on fossil fuels from Russia well before 2030 by diversifying 
the EU’s gas supplies and speeding up the green transition.  
On 23 May 2022, the Commission presented its European Semester spring 2022 
package. Member States should primarily focus on the timely implementation of the 
recovery and resilience plans (RRPs). Therefore, the Commission proposes to the 
Council to address to all Member States with an approved RRP: a recommendation 
on fiscal policy, including fiscal-structural reforms where relevant; a 
recommendation on the implementation of the RRP and the cohesion policy 
programmes; a recommendation on energy policy in line with the objectives of 
REPowerEU; where relevant, an additional recommendation on outstanding and/or 
newly emerging structural challenges. The scope of the recommendations is larger 
for Member States that do not have approved RRPs.  
The outbreak of the COVID-19 pandemic, the measures taken in response to that 
crisis, the surge in commodity prices, the supply bottlenecks and the robust recovery 
in 2021 have had a significant impact on some of the economic convergence 
indicators used in this report. This is especially the case for the assessment of the 
price stability criterion. Differences in inflation performance across the EU have 
increased mainly due to the heterogeneous impact of the recovery on Member States’ 
inflation rates and the differences in energy price inflation. In addition, the various 
fiscal measures taken by national authorities to cushion the impact of higher energy 
prices play a role. While some of these measures, such as social transfers to most 
vulnerable households, do not have a direct impact on consumer prices, others have a 
more direct impact on the inflation convergence assessment. In addition, long-term 
interest rates were influenced, initially, by the policy measures taken to stabilise 
financial markets and preserve favourable financing conditions and, later, by higher 
inflation expectations and the differing paths of monetary tightening.  
The 2020 economic recession and fiscal response to the COVID-19 pandemic led to 
a sharp increase in general government deficits and debt. In 2020, the deficit was 
above the 3% of GDP Treaty reference value in 25 Member States, with an EU 
aggregate deficit of 6.8% of GDP. In 2021, the strong economic recovery contributed 
to an improvement in government deficits and debt improved, with fifteen Member 
States recording deficits higher than 3% of GDP and the EU aggregate deficit 
declining to 4.7% of GDP. In March 2020, the European Commission, with the 
agreement of the EU Ministers of Finance, activated the general escape clause of the 
Stability and Growth Pact. On 23 May 2022, in its Communication on the 2022 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 20 –
5 
European Semester spring package, the Commission considered that the Union was 
not yet out of a period of severe economic downturn and that the conditions to 
maintain the general escape clause in 2023 and to deactivate it as of 2024 were met. 
The Commission invited the Council to endorse this conclusion to provide clarity to 
Member States. In spring 2020, 2021 and 2022, the Commission considered that a 
decision on whether to place Member States under the excessive deficit procedure 
should not be taken, taking into account the extraordinary macroeconomic and fiscal 
impact of the COVID-19 pandemic that, together with the geopolitical situation in 
spring 2022, create exceptional uncertainty, including for designing a detailed path 
for fiscal policy4. These conclusions have straightforward implications for the 
assessment of the criterion on the government budgetary position presented in this 
report. 
The impact of Russia’s invasion of Ukraine on the historical data used in the 2022 
Convergence Report is limited. This is a consequence of the report’s cut-off date (18 
May), which together with the Treaty-defined calculation methods of the price 
stability and long-term interest rate criteria (i.e. one year averages), mean that the 
corresponding data largely reflect the situation prior to Russia’s invasion. Instead, the 
extent to which the economic convergence indicators are affected by the crisis 
triggered by Russia’s invasion as well as by other ongoing economic developments is 
fully captured in the economic projections for 2022 and 2023, which the Commission 
published on 16 May 2022 (Commission’s Spring 2022 Economic Forecast) and 
which are used to assess the sustainability of convergence. This forecast is the first 
comprehensive Commission assessment of the likely economic effects in 2022 and 
2023 of the crisis triggered by Russia’s invasion of Ukraine, and as such, is 
surrounded by higher than usual uncertainty. 
Convergence criteria 
The examination of the compatibility of national legislation, including the statutes 
of national central banks of Member States with a derogation, together with Article 
130 TFEU and the compliance duty under Article 131 TFEU, encompasses an 
assessment of observance of the prohibition of monetary financing (Article 123 
TFEU) and the prohibition of privileged access to financial institutions (Article 124 
TFEU); consistency with the ESCB's objectives (Article 127(1) TFEU) and tasks 
(Article 127(2) TFEU), and other aspects relating to the integration of national 
central banks into the ESCB. 
The price stability criterion is defined in the first indent of Article 140(1) TFEU: 
‘’the achievement of a high degree of price stability; this will be apparent from a 
rate of inflation which is close to that of, at most, the three best performing Member 
States in terms of price stability’’. 
Article 1 of the Protocol on the convergence criteria further provides that ‘the 
criterion on price stability […] shall mean that a Member State has a price 
performance that is sustainable and an average rate of inflation, observed over a 
period of one year before the examination, that does not exceed by more than 1.5 
percentage points that of, at most, the three best-performing Member States in terms 
4  On 3 April 2020, the Council decided that an excessive deficit exists in Romania based on the planned excessive deficit in 2019. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 21 –
 
6 
of price stability. Inflation shall be measured by means of the consumer price index 
on a comparable basis, taking into account differences in national definitions’5.  
The requirement of sustainability implies that the satisfactory inflation performance 
must be attributable to the behaviour of input costs and other factors influencing 
price developments in a structural manner, rather than the influence of temporary 
factors. The convergence examination therefore includes an assessment of the factors 
that have an impact on the inflation outlook and is complemented by a reference to 
the most recent Commission forecast of inflation6. Related to this, the report also 
assesses whether the country is likely to meet the reference value in the months 
ahead. 
The inflation reference value was calculated to be 4.9% in April 2022, with France, 
Finland and Greece as the three ‘best-performing Member States’7. 
Malta and Portugal have been identified as outliers, as their inflation rates deviated 
by a wide margin from the euro area average and were driven by country-specific 
factors that limit their scope to act as meaningful benchmarks for other Member 
States8. This is consistent with past practice as outliers were identified in the 
Convergence Reports of 2004, 2010, 2013, 2014 and 2016. Outliers are identified on 
the basis of two criteria taken in combination: i) an inflation rate substantially below 
the euro area average and ii) an inflation rate driven by country-specific factors that 
cannot be seen as representative of the process driving inflation in the euro area. In 
past Convergence Reports, Member States that had an inflation rate 1.5 percentage 
points or more below the euro area were generally considered as outliers. In April 
2022, the 12-month average inflation rates of Malta and Portugal were respectively 
2.2 percentage points and 1.7 percentage points below the euro area average of 4.4%.  
In addition, the inflation performances of Malta and Portugal were driven by 
country-specific factors. In the case of Malta, country-specific factors that are 
reflected in the comparatively low average inflation rate include broadly stable 
energy prices in a context of surging international oil and gas prices and larger 
changes in the weights used to calculate the HICP than in most other EU countries in 
2021. The absence of energy price inflation in Malta was notably enabled by 
government measures, including through financial support to the energy sector. A 
fixed price contract for the supply of liquefied natural gas also contributed.  
In the case of Portugal, country-specific factors that are reflected in the 
comparatively very low average inflation rate include comparatively low energy 
inflation and the weaker cyclical position of the country compared with most other 
EU Member States. A combination of factors weighed on energy inflation, including 
a broad range of regulatory measures that kept the growth in retail prices of 
electricity and natural gas well below the EU average. In addition, the COVID-19 
crisis had a prolonged negative impact on Portuguese activity and inflation. The 
country’s activity was more severely hit than in most other EU Member States in the 
                                                          
5 For the purpose of the criterion on price stability, inflation is measured by the Harmonised Index of Consumer Prices (HICP) defined in 
Regulation (EU) 2016/792 of the European Parliament and of the Council. 
6  All forecasts for inflation and other variables in the current report are from the Commission’s Spring 2022 Economic Forecast. The 
forecasts are based on a set of common assumptions for external variables and on a ‘no policy change’ assumption while taking into 
consideration measures that are known in sufficient detail. 
7  The respective twelve-month average inflation rates were 3.2%, 3.3% and 3.6%. 
8  In April 2022, the twelve-month average inflation rates of Malta and Portugal were 2.1% and 2.6% respectively and that of the euro area 
4.4%. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 22 – 
7 
early stages of the pandemic and its recovery has since been comparatively slow. In 
the fourth quarter of 2021, Portugal’s GDP was still significantly below its pre-crisis 
peak and the gap was the second largest in the EU. This reflects mainly Portugal’s 
large exposure to tourism and particularly aviation-based tourism, which has been 
heavily and durably hit by the pandemic. The relative weakness in Portugal’s 
recovery has had a lasting dampening effect on inflation in services, particularly in 
sectors related to tourism.  
The convergence criterion dealing with public finances is defined in the second 
indent of Article 140(1) TFEU as ‘’the sustainability of the government financial 
position; this will be apparent from having achieved a government budgetary 
position without a deficit that is excessive as determined in accordance with Article 
126(6)’’.  
Furthermore, Article 2 of the Protocol on the convergence criteria states that this 
criterion means that ‘’at the time of the examination the Member State is not the 
subject of a Council decision under Article 126(6) of the said Treaty that an 
excessive deficit exists’’. 
The TFEU refers to the exchange rate criterion in the third indent of Article 140(1) 
as ‘‘the observance of the normal fluctuation margins provided for by the
exchangerate mechanism of the European Monetary System, for at least two years, without 
devaluing against the euro’’. 
Article 3 of the Protocol on the convergence criteria provides that: ‘‘The criterion on 
participation in the exchange rate mechanism of the European Monetary System […] 
shall mean that a Member State has respected the normal fluctuation margins 
provided for by the exchange-rate mechanism of the European Monetary System 
without severe tensions for at least the last two years before the examination. In 
particular, the Member State shall not have devalued its currency’s bilateral central 
rate against the euro on its own initiative for the same period’’9. 
The relevant two-year period for assessing exchange rate stability in this report is 19 
May 2020 to 18 May 2022. In its assessment of the exchange rate stability criterion, 
the Commission takes into account developments in auxiliary indicators such as 
foreign reserve developments and short-term interest rates. It also takes into account 
the role of policy measures, including foreign exchange interventions, and 
international financial assistance wherever relevant, in maintaining exchange rate 
stability. Two of the Member States with a derogation assessed in this report 
currently participate in the European exchange rate mechanism (ERM II) – Bulgaria 
and Croatia. Entry into ERM II is decided upon request of a Member State by mutual 
agreement of all ERM II participants10. This report is not related to the ERM II entry 
process and it does not provide an assessment of a Member State’s capacity to join 
ERM II. 
The fourth indent of Article 140(1) TFEU requires that ‘the durability of 
convergence achieved by the Member State with a derogation and of its participation 
in the exchange rate mechanism’ is ‘reflected in the long-term interest rate levels’. 
9 In assessing compliance with the exchange rate criterion, the Commission examines whether the exchange rate has remained close to the 
ERM II central rate, while reasons for an appreciation may be taken into account, in accordance with the Common Statement on 
Acceding Countries and ERM2 by the Informal ECOFIN Council, Athens, 5 April 2003. 
10  ERM II participants are the euro-area finance ministries, the ECB, non-euro area ERM II finance ministries and central banks. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 23 –
 
8 
Article 4 of the Protocol on the convergence criteria further states that ‘the criterion 
on the convergence of interest rates […] shall mean that, observed over a period of 
one year before the examination, a Member State has had an average nominal
longterm interest rate that does not exceed by more than 2 percentage points that of, at 
most, the three best-performing Member States in terms of price stability. Interest 
rates shall be measured on the basis of long-term government bonds or comparable 
securities, taking into account differences in national definitions’. 
The interest rate reference value was calculated to be 2.6% in April 202211. 
Article 140(1) TFEU also requires the reports to take account of other factors 
relevant to economic integration and convergence. These include the integration of 
markets, the development of the balance of payments on current account and of unit 
labour costs and other price indices12. The latter are covered within the assessment of 
price stability. The additional factors to be considered are important indicators on 
whether a Member State would integrate into the euro area without difficulties and 
they broaden the view on the sustainability of convergence. 
The assessment of the degree of sustainable convergence for the Member States with 
a derogation presented in this report draws on the Commission’s Spring 2022 
Economic Forecast and the policy guidance provided under the European Semester. 
It is informed in particular by the fiscal surveillance carried out under the Stability 
and Growth Pact and the Macroeconomic Imbalance Procedure. It also reflects the 
Commission’s assessments of fiscal sustainability risks and of the national fiscal 
frameworks, as well as the implementation of the recovery and resilience plans. 
 
2. BULGARIA 
In the light of its assessment on legal compatibility and on the fulfilment of the 
convergence criteria, and taking into account the additional relevant factors, the 
Commission considers that Bulgaria does not fulfil the conditions for the 
adoption of the euro. 
Legislation in Bulgaria — in particular the Law on the Bulgarian National Bank — 
is not fully compatible with the compliance duty under Article 131 TFEU. 
Incompatibilities and imperfections exist in the fields of central bank independence, 
the prohibition of monetary financing and central bank integration into the ESCB at 
the time of euro adoption with regard to the tasks laid down in Article 127(2) TFEU 
and Article 3 of the ESCB/ECB Statute. 
Bulgaria does not fulfil the criterion on price stability. The average inflation rate 
in Bulgaria during the 12 months to April 2022 was 5.9%, above the reference value 
of 4.9%. The Commission projects it to remain above the reference value in the 
months ahead. 
                                                          
11 The reference value for April 2022 is calculated as the simple average of the 12-month average of long-term interest rates of France 
(0.3%), Finland (0.2%) and Greece (1.4%), plus two percentage points.  
12  It is, however, important to bear in mind that unit labour costs data may have been impacted by the labour retention schemes put in place 
in some Member States following the outbreak of the pandemic. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 24 – 
9 
Bulgaria’s annual HICP inflation rate averaged 1.2% in 2020, and accelerated to 
2.8% in 2021. Annual HICP inflation decreased from 1.3% in April 2020 to -0.3% in 
January 2021. Headline inflation then increased during the course of 2021, before 
accelerating sharply in the first months of 2022, reaching 12.1% in April 2022. 
Deflation in unprocessed food prices and low inflation rates in processed food prices 
drove inflation down in April 2020 to January 2021. The subsequent acceleration of 
inflation in 2021 was due to strong contributions from all broad categories. In 
particular, fuel prices contributed 3.5 percentage points to the annual inflation rate in 
December 2021. In the first part of 2022, headline inflation continued to increase on 
the back of higher energy prices and other broad-based price increases. Annual HICP 
inflation rates in Bulgaria in 2020 and 2021 were on average higher than those of the 
euro area. 
In the Commission’s Spring 2022 Economic Forecast, inflation is projected to 
accelerate significantly from 2.8% in 2021 to 11.9% in 2022, gradually easing to 
5.0% in 2023. Headline inflation is expected to increase and remain elevated because 
of persistently higher costs of energy and other intermediate products, expected 
increases in regulated gas and heating prices, as well as higher international food 
prices and growing import deflators. The relatively low price level in Bulgaria (about 
52% of the euro area average in 2020) suggests significant potential for price level 
convergence in the long term. 
Bulgaria fulfils the criterion on public finances. Bulgaria is not the subject of a 
Council Decision on the existence of an excessive deficit. The general government 
balance remained broadly stable with a deficit of 4.0% of GDP in 2020 and a deficit 
of 4.1% of GDP in 2021. After a period of budget surpluses, these deficits are the 
result of the pandemic-induced shock and the measures taken by the Bulgarian 
government in response to it. The Commission’s Spring 2022 Economic Forecast 
expects the general government balance is projected to improve to -3.7% of GDP in 
2022. Fiscal costs associated with people fleeing the war in Ukraine as well as 
measures in light of higher energy prices weigh on the deficit’s recovery path. The 
deficit is expected to reach -2.4% of GDP in 2023 under a  ‘no policy change’ 
assumption. On 23 May 2022, the Commission adopted a report prepared in 
accordance with Article 126(3) of the TFEU for 18 Member States, including 
Bulgaria. Overall, taking into account all relevant factors as appropriate, the analysis 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 25 –
10 
in the report suggested that Bulgaria did not fulfil the deficit criterion. In line with its 
Communication of 2 March 202213, the Commission did not propose opening new 
excessive deficit procedures. It noted that the COVID-19 pandemic continues to have 
an extraordinary macroeconomic and fiscal impact that, together with Russia’s 
invasion of Ukraine, creates exceptional uncertainty, including for designing a 
detailed path for fiscal policy. On these grounds, the Commission considered that a 
decision on whether to place Member States under the excessive deficit procedure 
should not be taken in spring 2022. The public debt-to-GDP ratio increased from just 
below 25% in 2020 to 25.1% in 2021, and is expected to remain broadly the same in 
2022, before increasing slowly towards 26% in 2023. Despite the low projected debt 
level by 2032 (37% of GDP), debt sustainability risks for Bulgaria appear medium in 
the medium term. The projection is subject to considerable uncertainty. Bulgaria has 
developed a strong fiscal framework in recent years, and now has a better track 
record in compliance. The system of rules, however, appears complex, which 
increases the need to streamline the process. 
In line with its currency board arrangement, the exchange rate of the Bulgarian 
lev against the euro has been stable since the previous Convergence Report. The 
two-year period relevant for the assessment of exchange-rate stability extends from 
19 May 2020 to 18 May 2022. The Bulgarian lev joined ERM II on 10 July 2020 and 
observes a central rate of 1.95583 to the euro with a standard fluctuation band of 
±15%. The Bulgarian National Bank pursues its primary objective of price stability 
through an exchange rate anchor as part of a currency board arrangement. Bulgaria 
introduced its currency board arrangement in 1997, pegging the Bulgarian lev to the 
German mark and later to the euro. Bulgaria joined ERM II with its existing currency 
board arrangement in place, as a unilateral commitment, thereby placing no 
additional obligations on the ECB. The lev exchange rate has remained stable over 
the two-year assessment period without any signs of tensions or devaluation against 
the euro. Additional indicators, such as developments in foreign exchange reserves 
and short-term interest rates, suggest that investors' risk perception towards Bulgaria 
has remained favourable. A sizeable buffer of official reserves continues to 
underpincurrency board arrangement’s resilience. After joining ERM II, Bulgaria 
committed to implement a set of policy measures – the so-called post-entry 
commitments – to ensure that its participation in the mechanism is sustainable and 
13  For more information, see COM(2022) 85 final: https://ec.europa.eu/info/sites/default/files/economy-
finance/com_2022_85_1_en_act_en.pdf.  
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 26 –
11 
that the country achieves a high degree of economic convergence before adopting the 
euro. The measures cover four policy areas: the non-banking financial sector, the 
insolvency framework, the anti-money laundering framework, and governance of 
state-owned enterprises. Bulgaria is currently working towards completing these 
post-entry commitments, in cooperation with the Commission, which monitors its 
progress. 
The lev has remained at the ERM II central rate for the 2 years covered by this 
assessment. There has been no devaluation of the lev’s central parity inside ERM II. 
By the time of a possible Council Decision in July 2022, the lev will have 
participated in ERM II for 24 months. Bulgaria fulfils the exchange rate criterion. 
Bulgaria fulfils the criterion on the convergence of long-term interest rates. The 
average long-term interest rate in the year up to April 2022 was 0.5%, well below the 
reference value of 2.6%. Long-term interest rates in Bulgaria have been very low and 
fairly stable since the beginning of 2020 until the end of 2021, remaining within a 
band of 0.1-0.4%. There was only a brief peak in June-July 2020, when the 
benchmark interest rate increased to 0.7%. In the same period, the spread vis-à-vis 
the German benchmark bond has hovered mostly around 60 basis points, with a brief 
peak above 100 basis points in mid-2020. However, at the beginning of 2022, both 
the interest rate and the spread started to increase, and were 1.6% and 89 basis points 
respectively in April 2022. 
The Commission has also examined additional factors, including balance of 
payments developments and the integration of markets. Bulgaria’s external balance 
(the combined current and capital account) has remained in surplus, at 1.5% of GDP 
in 2020 and 0.3% in 2021. The Bulgarian economy is well integrated with the euro 
area through trade and investment linkages. Selected indicators related to the 
business environment show that Bulgaria performs worse than many euro area 
Member States. Challenges also relate to the institutional framework including 
corruption and government efficiency. However, in the context of successful 
participation in the ERM II and in accordance with the recovery and resilience plan 
(RRP), Bulgaria is taking measures to improve the business environment and 
maintain financial sector stability, in the four areas covered by the post-entry ERM II 
commitments mentioned above. The financial sector in Bulgaria is smaller and less 
developed than in the euro area, with an above average share of non-performing 
loans that has been declining only very gradually in the past several years. Banking 
dominates the Bulgarian financial sector, and its banking sector is well integrated 
with the euro area financial sector, in particular through a high level of foreign 
ownership. However, market based financing is less developed, which is reflected in 
the very small markets for equity and private sector debt. In the context of the 
Macroeconomic Imbalance Procedure, the Commission concluded in its Alert 
Mechanism Report for 2022 that it was not necessary to carry out further in-depth 
analysis for Bulgaria. 
The effective implementation of the reforms and investment set out in Bulgaria’s 
recovery and resilience plan will address key macro-economic challenges. These 
include social inclusion, education and skills, healthcare, decarbonisation, the digital 
transition, the business environment, and financing of small and medium-sized 
enterprises. Key investments are included in renewable energy production, electricity 
storage and interconnection capacities, and in the digitalisation of public 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 27 –
12 
administration and digital skills. Key reforms include the introduction of a 
framework for coal phase-out, the liberalisation of the electricity market, 
comprehensive educational reform, and strengthening the minimum income scheme, 
the anti-money laundering and the insolvency frameworks. The plan also contains 
measures to improve the efficiency of the public administration and justice system, to 
prevent, detect and correct corruption. 
3. CZECHIA
In the light of its assessment on legal compatibility and on the fulfilment of the
convergence criteria, and taking into account the additional relevant factors, the
Commission considers that Czechia does not fulfil the conditions for the
adoption of the euro.
Legislation in Czechia – in particular the Czech National Council Act No. 6/1993
Coll. on the Czech national bank(the ČNB Law) – is not fully compatible with the
compliance duty under Article 131 TFEU. Incompatibilities concern the
independence of the central bank and central bank integration in the ESCB at the
time of euro adoption with regard to the Česká národní banka’s (ČNB) objectives
and the ESCB tasks laid down in Article 127(2) TFEU and Article 3 of the
ESCB/ECB Statute. In addition, the ČNB Law also contains imperfections relating to
the prohibition of monetary financing and the ESCB tasks.
Czechia does not fulfil the criterion on price stability. The average inflation rate
in Czechia during the 12 months to April 2022 was 6.2%, well above the reference
value of 4.9%. It is projected to remain well above the reference value in the months
ahead.
The annual HICP inflation rate eased from 3.8% at the beginning of 2020 to 2.1% in 
February 2021 mostly due to falling energy and food inflation. Headline inflation 
then picked up during the course of 2021, before accelerating sharply in the first 
months of 2022 to reach 13.2% in April 2022. The increase in 2021 and early 2022 
was broad based, reflecting both a surge in energy prices and a strong acceleration of 
core inflation (driven by non-energy industrial goods and services). The annual HICP 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 28 –
13 
inflation rate averaged 3.3% in both 2020 and 2021. Annual HICP inflation rates in 
Czechia in 2020 and 2021 were on average higher than those of the euro area. 
The Commission’s Spring 2022 Economic Forecast expects inflation to accelerate 
significantly to 11.7% in 2022 and then moderate to 4.5% in 2023 . Headline 
inflation is expected to increase and remain elevated over both years because of 
persistently higher costs of energy and other intermediate products, expected 
increases in administered prices for energy and other utilities, and core inflation 
components, especially goods followed by services. The relatively low price level in 
Czechia (about 73% of the euro area average in 2020) suggests that there is potential 
for further price level convergence in the long term. 
Czechia fulfils the criterion on public finances. Czechia is not the subject of a 
Council Decision on the existence of an excessive deficit. The general government 
balance worsened somewhat from a deficit of 5.8% in 2020 to a deficit of 5.9% of 
GDP in 2021. The Commission’s Spring 2022 Economic Forecast expects the 
general government balance to improve to -4.3% of GDP in 2022, despite the 
negative impact of Russia’s invasion of Ukraine. This led to the implementation of 
emergency and integration measures to support those fleeing Ukraine as well as 
measures to ease energy costs. The general government balance is forecast to reach -
3.9% of GDP in 2023 under a ‘no policy change’ assumption. On 23 May 2022 the 
Commission adopted a report prepared in accordance with Article 126(3) of the 
TFEU for 18 Member States, including Czechia. Overall, taking into account all 
relevant factors as appropriate, the analysis in the report suggested that Czechia did 
not fulfil the deficit criterion. In line with its Communication of 2 March 202214, the 
Commission did not propose opening new excessive deficit procedures. It noted that 
the COVID-19 pandemic continues to have an extraordinary macroeconomic and 
fiscal impact that, together with Russia’s invasion of Ukraine, create exceptional 
uncertainty, including for designing a detailed path for fiscal policy. On these 
grounds, the Commission considered that a decision on whether to place Member 
States under the excessive deficit procedure should not be taken in spring 2022. The 
public debt-to-GDP ratio increased from around 38% in 2020 to 41.9% in 2021, and 
is expected to increase to 42.8% in 2022 and to 44.0% in 2023. Debt sustainability 
risks for Czechia appear medium in the medium term, particularly as government 
debt is projected to increase to around 61% of GDP in 2032. The projection is 
subject to significant sensitivity to adverse macro-financial developments. The Czech 
national fiscal framework is well developed. After the outbreak of the COVID-19 
pandemic, Parliament fast-tracked legislative amendments that allow a larger deficit 
over 2021–2027 and a longer adjustment path (0.5 percentage point correction per 
year, in structural terms). 
14  For more information, see COM(2022) 85 final: https://ec.europa.eu/info/sites/default/files/economy-
finance/com_2022_85_1_en_act_en.pdf.  
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 29 –
14 
Czechia does not fulfil the exchange rate criterion. The Czech koruna does not 
participate in ERM II. Czechia operates a de jure floating exchange rate regime, 
allowing the central bank to make foreign exchange market interventions . Following 
the lock-down measures taken in the early stages of the COVID-19 pandemic, the 
koruna depreciated significantly by about 6% in April 2020 (year-on-year). From 
June 2020 it fluctuated at slightly higher levels until December 2020, when it entered 
an appreciation phase that ended abruptly in early 2022. The appreciation was mostly 
driven by a sharp monetary tightening by the ČNB. However, in the wake of 
Russia’s invasion of Ukraine the Czech koruna experienced strong depreciation 
pressures, which triggered short-lasting stabilising interventions by the ČNB in the 
foreign exchange market in early March 2022. In April 2022, the Czech koruna was 
about 12% stronger against the euro than 2 years earlier. Short-term interest rate 
differentials vis-à-vis the euro area increased from around 90 basis points in May 
2021 to around 580 basis points by April 2022, following the strong tightening cycle 
that the ČNB started in August 2021. 
Czechia fulfils the criterion on the convergence of long-term interest rates. The 
average long-term interest rate in the year to April 2022 was 2.5%, below the 
reference value of 2.6%. The long-term interest rate of Czechia fell in the first few 
months of 2020 to bottom out at around 0.9% in summer 2020. It then increased 
slowly to about 1.9% in spring 2021 before picking up more strongly on the back of 
the ČNB’s sharp monetary tightening and a rapid increase in inflation. The long-term 
interest rate reached 4.0% in April 2022, with the spread vis-à-vis the German 
benchmark bond nearing 330 basis points. 
The Commission has also examined additional factors, including balance of 
payments developments and the integration of markets. Czechia’s external balance 
(the combined current and capital account) recorded an exceptionally high surplus of 
3.6% of GDP in 2020 due to the effect of the COVID-19 crisis on the trade and 
primary income balances. The Czech economy is highly integrated with the euro area 
through trade and investment linkages. Selected indicators related to the business 
environment show that Czechia performs around the average of euro area Member 
States. Challenges relate to the institutional framework including government 
efficiency and the anti-corruption framework, for instance in relation to avoiding 
conflicts of interest. The financial sector in Czechia is smaller and less developed 
than in the euro area. Market based financing is less developed, which is reflected in 
the very small markets for equity and private sector debt. The Czech financial sector 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 30 –
15 
is highly integrated into the euro area financial system, in particular through a high 
degree of foreign ownership of financial intermediaries.  
The effective implementation of the reforms and investment set out in Czechia’s 
recovery and resilience plan (RRP) will address key macro-economic challenges. 
These include technological changes, such as those posed by automation and the 
green transition, investment in research and development, new childcare facilities, 
and up-skilling and reskilling actions. Key investments are included on energy 
efficiency of buildings, digital skills and access to finance for companies. Key 
reforms are aimed at addressing the quality of public administration (including 
digitalisation), increasing the capacity of childcare facilities, improving access to and 
the resilience of the healthcare sector, improving education programmes, upgrading 
labour market services, supporting research activities and the introduction of 
innovation in firms. The business environment is being improved by several
egovernment measures, anti-corruption reforms, including strengthening the 
institutional and administrative framework linked to avoiding conflict of interest and 
a comprehensive reform of the procedure for granting building permits, which 
currently represent major obstacles to investment in Czechia.   
4. CROATIA
In the light of its assessment on legal compatibility and on the fulfilment of the
convergence criteria, and taking into account the additional relevant factors, the
Commission considers that Croatia fulfils the conditions for the adoption of the
euro.
Legislation in Croatia is fully compatible with the compliance duty under Article
131 TFEU.
Croatia fulfils the criterion on price stability. The average inflation rate in Croatia
during the 12 months to April 2022 was 4.7%, below the reference value of 4.9%. It
is projected to remain below the reference value in the months ahead.
In 2021, the annual HICP inflation rate averaged 2.7%, increasing significantly
compared to 2020, when it averaged 0%. Inflation was slightly negative in Croatia
between April 2020 and January 2021, mostly due very low and negative energy and
non-energy industrial goods inflation. It then accelerated sharply throughout 2021
and in the first months of 2022 to reach 9.6% in April. The increase in 2021 and
early 2022 was broad based, reflecting higher energy prices but also an acceleration
of core inflation. Annual HICP inflation rates in Croatia in 2020 and 2021 were on
average very close to those of the euro area.
The Commission’s Spring 2022 Economic Forecast expects annual HICP inflation to
accelerate to 6.1% in 2022 before decelerating to 2.8% in 2023, mostly supported by
an expected decline in international commodity prices. Headline inflation is therefore
projected to remain very close to the euro area headline inflation in 2022 and 2023.
Core inflation is expected to be higher than in the euro area in 2022 (i.e., 4.3% vs.
3.5%), reflecting stronger inflation in processed food and, more generally, a stronger
recovery from the COVID-19 crisis in Croatia. However, this is expected to be
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 31 –
16 
temporary and the gap is projected to narrow in 2023 (i.e., 3.3% vs. 3.1%). Unit 
labour costs are projected to remain subdued in both 2022 and 2023. 
The requirement of sustainability implies that respecting the reference value is the 
result of underlying fundamentals rather than temporary factors. The analysis of 
underlying fundamentals and the fact that the reference value will continue to be met 
in the months ahead support a positive assessment on the fulfilment of the price 
stability criterion. While RRP-related investments and reforms are expected to have a 
muted if not disinflationary effect in the long run, investments should also support 
aggregate demand in the short term (see the next paragraph). According to the 
Commission’s Spring 2022 Economic Forecast, inflation is projected to ease 
significantly over the forecast horizon, which suggests that any possible short-term 
inflationary effect of RRP-related investments should remain limited. 
In the longer-term, inflation prospects will hinge in particular on wages growing in 
line with productivity. Inflation cycles in Croatia are already highly synchronised 
with the inflation cycle of the euro area and wage developments are expected to 
continue to underpin this synchronisation. However, although the 2013 and 2014 
labour market reforms substantially increased the level of flexibility in the labour 
market, wage setting remains imperfectly aligned with productivity developments. 
This is partly linked to the public sector’s role as wage leader. The associated risks in 
terms of wage developments are not expected to increase with euro accession. 
Furthermore, RRP-related reforms (e.g., reduction of administrative burden and
parafiscal charges, deregulation of services etc.) should enhance competition on the 
market and reduce costs for companies, leading to downward pressure on the prices 
of final products in the long run. In particular, two reforms could contribute to better 
align productivity wages in the medium term. The first is the new wage and work 
model in civil and public service, which should introduce a fairer, more transparent 
and sustainable wage system in the state administration and public services. The 
second is the Amendment to the Labour Act, tackling unjustified temporary 
employment and incentivising workers to remain active, among others. Furthermore, 
although there is a potential for further price level convergence in the long term, it 
should be noted that at about 67% of the euro area average in 2020, the price level in 
Croatia has already achieved a higher level of price convergence with the euro area 
than other Member States when they joined the euro area. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 32 –
17 
Croatia fulfils the criterion on public finances. Croatia is not the subject of a 
Council Decision on the existence of an excessive deficit. After 3 years of broadly 
balanced budgets and surpluses, the general government balance turned into a deficit 
of 7.3% of GDP in 2020 due to the COVID-19 crisis. The general government deficit 
declined to 2.9% of GDP in 2021, thanks largely to the strong economic recovery 
and the gradual phasing out of COVID-19 support measures. The Commission’s 
Spring 2022 Economic Forecast projects the general government balance to improve 
further to -2.3% of GDP in 2022, notwithstanding the measures taken by the 
government to reduce the economic and social impact of the increase in energy 
prices and the costs of assistance to those fleeing Ukraine. In 2023, the government 
balance should reach -1.8% of GDP on a no policy change basis. The public debt-to-
GDP ratio decreased from around 87% in 2020 to 79.8% in 2021, and is expected to 
decline to 75.3% in 2022 and to 73.1% in 2023. Debt sustainability risks for Croatia 
appear medium in the medium term, with government debt projected to stay below 
its 2021 level until 2032. However, the projections are subject to significant 
sensitivity to adverse macro-financial developments.  The Croatian fiscal framework 
has been significantly strengthened recently, largely thanks to the transposition of 
some of the outstanding requirements of the Council Directive on Budgetary 
Frameworks (2011/85/EU). 
The exchange rate of the Croatian kuna against the euro has been broadly 
stable since the previous Convergence Report. The two-year period relevant for 
the assessment of exchange rate stability runs from 19 May 2020 to 18 May 2022. 
The Croatian kuna joined ERM II on 10 July 2020 and observes a central rate of 
7.53450 to the euro with a standard fluctuation band of ±15%. After having 
depreciated against the euro by up to 2% in the first 2 months of the pandemic in 
March and April 2020, the kuna-euro exchange rate in the 2 months before Croatia 
joined ERM II was stable with only minor deviations from the post-ERM II entry 
central rate. The kuna has fluctuated in a narrow band of less than +/-1% against its 
central rate to the euro since it joined ERM II, with the Croatian central bank having 
operated a de jure managed floating exchange rate before the ERM II entry. Over the 
last 2 years, the kuna's exchange rate against the euro has continued to exhibit a 
seasonal pattern of temporary modest appreciation in the summer thanks to foreign 
currency inflows related to the tourism sector. On 18 May 2022, the kuna stood at 
7.535 HRK/EUR, very close to its ERM II central rate to the euro and broadly stable 
compared to its level 2 years earlier. Additional indicators, such as developments in 
foreign exchange reserves and short-term interest rates, suggest that investors' risk 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 33 – 
18 
perception towards Croatia has remained favourable. International reserves held by 
the Croatian National Bank  stood at EUR 25 billion at the end of 2021, increasing 
from close to EUR 19 billion at the end of 2020. The spread of the Croatian 
benchmark short-term rate, i.e. the 3-month NRR rate, to the EURIBOR has been 
broadly stable and averaged about 60 basis points over the 2020-2021 period. Upon 
its ERM II entry, Croatia committed to implement a set of policy measures – the
socalled post-entry commitments – to ensure that its participation in the mechanism is 
sustainable and that the country achieves a high degree of economic convergence 
before adopting the euro. The measures cover four policy areas: the anti-money 
laundering, the business environment, state-owned enterprises and the insolvency 
framework. 
The kuna has remained very close to the ERM II central rate for the 2 years covered 
by this assessment. There has been no devaluation of the kuna's central parity inside 
ERM II. By the time of a possible Council Decision in July 2022, the kuna will have 
participated in ERM II for 24 months. Croatia fulfils the exchange rate criterion. 
Croatia fulfils the criterion on the convergence of long-term interest rates. The 
average long-term interest rate of Croatia was 0.8% in April 2022, well below the 
reference value of 2.6%. Having risen in the first 2 months of the pandemic by over 
60 basis points to 1.2% in April 2020, the long-term interest rate then declined very 
gradually, falling to as low as 0.3% by the end of 2021. The long-term interest rate 
picked up slightly in December 2021 and moved higher in the first few months of 
2022 amid increasing geopolitical risks at global level and a deterioration in the 
inflation outlook against the backdrop of an already high level of inflation in most 
advanced economies. The spread against the German long-term benchmark bond was 
slightly above 100 basis points in 2020 but declined gradually in 2021, falling to 
around 50 basis points by the end of 2021. It widened again to above 100 basis points 
at the beginning of 2021, rising to 168 basis points in April 2022 after having peaked 
by 180 basis points in the previous month. 
The Commission has also examined additional factors, including balance of 
payments developments and the integration of markets. Croatia's external balance 
(the combined current and capital account) decreased to 2.1% of GDP in 2020 from 
4.6% of GDP in 2019 due to the economic fallout of the COVID-19 pandemic. 
Benefiting from a high current account surplus as a result of a strong recovery of 
tourism export services, it rose substantially to 5.5% of GDP in 2021. The Croatian 
economy is well integrated with the euro area through trade and investment linkages. 
Selected indicators relating to the business environment show that Croatia performs 
worse than many euro area Member States. Challenges inter alia relate to the 
institutional framework including regulatory quality and corruption. However, there 
has been renewed effort as part of post-entry ERM II commitments to improve the 
business environment, in particular to reduce the administrative burden and 
regulatory restrictions (see also below the paragraph on the RRP-related measures). 
Croatia’s banking sector is highly integrated with the euro area financial system, in 
particular through a high share of foreign ownership of financial intermediaries. In 
July 2020, the ECB adopted a decision to establish close cooperation with the 
Croatian National Bank in the field of banking supervision. The ECB is now 
responsible for the supervision of Croatia’s major banking institutions and Croatia 
has effectively joined the Banking Union. The Croatian financial sector is smaller 
than that of the euro area in terms of GDP. It is dominated by the banking sector 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 34 –
19 
which is highly integrated into the euro area banking sector, in particular through 
foreign ownership. At the same time, the insurance and pension funds sector is also 
relatively large in Croatia. However, market-based financing is less developed, 
which is reflected in the very small markets for equity and private sector debt. In the 
context of the Macroeconomic Imbalance Procedure, the Commission concluded in 
its Alert Mechanism Report for 2022 that Croatia warranted an In-Depth Review 
(IDR). In the updated scoreboard including figures until 2020, the net international 
investment position (NIIP), unit labour cost (ULC) growth, house price growth and 
general government gross debt indicators were above their indicative thresholds. 
However, the findings of the Commission’s 2022 In-Depth Review (IDR) indicate 
that the unwinding of macroeconomic imbalances resumed in 2021, following a 
relatively contained deterioration in 2020. Based on this in-depth review, the 
Commission considered that Croatia is no longer experiencing macroeconomic 
imbalances. 
The effective implementation of the reforms and investment set out in Croatia’s 
recovery and resilience plan will address key macro-economic and institutional 
challenges. These include low employment and activity rates, skills gaps, a 
burdensome and complex business environment and the low quality of education. 
Key investments are included on energy efficiency and post-earthquake 
reconstruction of buildings, sustainable transport, the digital transition of the public 
administration and 5G infrastructure. Reforms are planned in areas such as early 
childhood education and care, the healthcare system, anti-money laundering and
anticorruption, judiciary, fiscal framework and the business environment, notably by 
reducing administrative barriers. 
5. HUNGARY
In the light of its assessment on legal compatibility and on the fulfilment of the
convergence criteria, and taking into account the additional relevant factors, the
Commission considers that Hungary does not fulfil the conditions for the
adoption of the euro.
Legislation in Hungary – in particular the Law on the Magyar Nemzeti Bank
(MNB) – is not fully compatible with the compliance duty under Article 131 TFEU.
Notable incompatibilities concern the independence of the MNB, the prohibition of
monetary financing and central bank integration into the ESCB at the time of the
euro adoption with regard to the ESCB’s tasks laid down in Article 127(2) TFEU and
Article 3 of the ESCB/ECB Statute. In addition, the Law on the MNB also contains
further imperfections relating to MNB integration into the ESCB.
Hungary does not fulfil the criterion on price stability. The average inflation rate
in Hungary during the 12 months to April 2022 was 6.8%, well above the reference
value of 4.9%. It is projected to remain well above the reference value in the months
ahead.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 35 –
20 
Annual HICP inflation in Hungary was on an upward path in 2020 and 2021, 
averaging 3.4% and 5.2% respectively. Annual HICP inflation rose from 2.5% in 
April 2020 to 5.2% in April 2021. It then accelerated further in the first few months 
of 2022, reaching 8.6% in March 2022. Inflation acceleration in 2021 was mostly 
driven by developments in energy and commodity prices. However, core inflation 
(measured as HICP inflation excluding energy and unprocessed food) increased 
sharply, after easing slightly between August 2020 and March 2021. Inflation stood 
at 9.6% in April 2022. Annual HICP inflation rates in Hungary in 2020 and 2021 
were on average higher than those of the euro area. 
Inflation is projected to increase to 9.0% in 2022 and to slow down to 4.1% in 2023 
according to the Commission’s Spring 2022 Economic Forecast. Inflation is expected 
to be mostly driven by energy and commodity prices but also relatively sizable wage 
increases. The relatively low price level in Hungary (about 63% of the euro area 
average in 2020) suggests that there is potential for further price level convergence in 
the long term. 
Hungary fulfils the criterion on public finances. Hungary is not the subject of a 
Council Decision on the existence of an excessive deficit. The general government 
deficit reached 7.8% of GDP in 2020, before declining to 6.8% of GDP in 2021. The 
Commission’s Spring 2022 Economic Forecast expects that, on the back of
betterthan-expected output growth, the general government deficit will decrease to 6.0% of 
GDP in 2022, notwithstanding the measures taken by the government to reduce the 
economic and social impact of the increase in energy prices and the costs of 
assistance to those fleeing Ukraine. It is forecast to further decrease to 4.9% of GDP 
in 2023, under a ‘no policy change’ assumption. On 23 May 2022, the Commission 
adopted a report prepared in accordance with Article 126(3) of the TFEU for 18 
Member States, including Hungary. Overall, taking into account all relevant factors 
as appropriate, the analysis in the report suggested that the Hungary did not fulfil the 
deficit and debt criteria. In line with its Communication of 2 March 202215, the 
Commission did not propose to open new excessive deficit procedures. The 
Commission considered, within its assessment of all relevant factors, that compliance 
15  For more information, see COM(2022) 85 final: https://ec.europa.eu/info/sites/default/files/economy-
finance/com_2022_85_1_en_act_en.pdf.  
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 36 – 
21 
with the debt reduction benchmark would imply a too demanding frontloaded fiscal 
effort that risks to jeopardise growth. Therefore, in the view of the Commission, 
compliance with the debt reduction benchmark is not warranted under the current 
exceptional economic conditions. The Commission noted that the COVID-19 
pandemic continues to have an extraordinary macroeconomic and fiscal impact that, 
together with Russia’s invasion of Ukraine, create exceptional uncertainty, including 
for designing a detailed path for fiscal policy. On these grounds, the Commission 
considered that a decision on whether to place Member States under the excessive 
deficit procedure should not be taken in spring 2022. The public debt-to-GDP ratio 
decreased from around 80% in 2020 to 76.8% in 2021 and is forecast to increase to 
76.4% in 2022 and decrease to 76.1 % in 2023. Debt sustainability risks for Hungary 
appear medium in the medium term. The projection is subject to particularly large 
uncertainty and is sensitive to adverse macro-financial developments.  The 
Hungarian fiscal framework has been improved through reforms that began in 2011, 
but there is still room for improvement. The Fiscal Council’s role in fiscal policy 
making could be strengthened and the volatility of the medium-term framework 
could still be reduced. 
Hungary does not fulfil the exchange rate criterion. The Hungarian forint does not 
participate in ERM II. Hungary operates a de jure floating exchange rate regime, 
allowing for foreign exchange market interventions by the central bank. Overall, the 
forint depreciated against the euro over the period covered by the report, resulting 
from oscillating depreciation and re-appreciation movements. In particular, there was 
a strong depreciation immediately after the Russia’s invasion of Ukraine, partially 
reduced thanks to restrictive monetary policy. In April 2022, the forint was about 5% 
weaker against the euro than 2 years earlier. Short-term interest rate differentials
visà-vis the euro area increased substantially since the beginning of the COVID-19 
crisis, when the previous upward movement in Hungarian rates was accentuated. The 
spread first increased in winter 2020 and early spring 2020, when monetary rates 
were raised to support the exchange rate at the height of the crisis.  After a 
stabilisation at around 130 basis point between January and June 2021, the spread 
started to increase steeply due to monetary policy tightening. The spread reached 705 
basis points in April 2022.  
Hungary does not fulfil the criterion on the convergence of long-term interest 
rates. The average long-term interest rate stood at 4.1% in April 2022, above the 
reference value of 2.6%. Hungary’s long-term interest rate, which stood at around 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 37 –
22 
2.5% in April 2020, decreased until the end of 2020, reflecting the monetary easing 
conducted by major central banks. Hungary’s long-term interest rate started to 
increase again in 2021, in particular from September 2021 onwards, reflecting the 
tightening of monetary policy, to surpass 4% in November 2021. The increase in 
long-term rates continued, and accelerated further in March 2022, on the back of 
Russia’s invasion of Ukraine. Despite the increase in rates on the German benchmark 
bond over the same period, the long-term spread vis-à-vis the German benchmark 
bond has increased over the last 2 years and reached 584 basis points in April 2022. 
The Commission has also examined additional factors have also been examined, 
including balance of payments developments and the integration of markets. The 
external balance (the combined current and capital account) deteriorated in 2020 and 
2021, mainly due to strong growth in imports that was not compensated by exports, 
which were affected by the COVID-19 disruptions. The external balance deteriorated 
from 1.0% of GDP in 2020 to -0.4% in 2021. The Hungarian economy is highly 
integrated with the euro area through trade and investment linkages. Selected 
indicators relating to the business environment, show that Hungary performs worse 
than many euro area Member States. Hungary inter alia faces challenges in areas 
such as controlling corruption, judicial independence and the quality of
decisionmaking. Hungary’s financial system is characterised by a large presence of foreign 
holdings that perform no financial intermediation in the domestic economy. 
Excluding these, Hungary’s financial system is less developed than those of the euro 
area. Hungary's banking sector shows a large and relatively stable weight in the 
financial sector and is well integrated into the euro area financial system due to a 
relatively large share of foreign ownership. The equity and debt markets are small 
and relatively less developed.  
Hungary submitted its recovery and resilience plan on 11 May 2021. The plan is 
currently being assessed by the Commission to make sure that all assessment criteria 
are being fulfilled. The plan proposes investments and reforms to strengthen primary 
care and hospitals, increase the capacity of suburban rail and increase renewable 
energy production at residential level.   
6. POLAND
In light of its assessment on legal compatibility and on the fulfilment of the
convergence criteria, and taking into account the additional relevant factors, the
Commission considers that Poland does not fulfil the conditions for the adoption
of the euro.
Legislation in Poland - in particular the Act on the Narodowy Bank Polski (NBP)
and the Constitution of the Republic of Poland - is not fully compatible with the
compliance duty under Article 131 TFEU. Incompatibilities relate to the
independence of the central bank, the prohibition of monetary financing and central
bank integration into the ESCB at the time of euro adoption. In addition, the Act on
the NBP also contains some imperfections relating to central bank independence and
the integration of the NBP into the ESCB at the time of euro adoption.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 38 – 
23 
Poland does not fulfil the criterion on price stability. The average inflation rate in 
Poland during the 12 months to April 2022 was 7.0%, well above the reference value 
of 4.9%. It is projected to remain well above the reference value in the months ahead. 
Annual HICP inflation in Poland was on a broad upward trend during most of 2020 
and 2021, averaging 3.7% in 2020 and 5.2% in 2021 mostly due to service and 
energy inflation. Annual HICP fell to 2.9% in April 2020 following the 
disinflationary effect of the first wave of the pandemic in Poland. It recovered to 
3.8% in June 2020 and remained broadly constant until February 2021. Annual 
inflation then increased sharply throughout 2021 and early 2022, driven by rising 
energy and food prices as well as accelerating core inflation (driven by non-energy 
industrial goods and services). It reached 7.0% in April 2022. Annual HICP inflation 
rates in Poland in 2020 and 2021 were on average higher than in the euro area. 
Inflation is projected to increase to 11.6% in 2022 and to 7.3% in 2023 according to 
the Commission’s Spring 2022 Economic Forecast. Energy prices are expected to 
increase strongly amid a hike in regulated energy prices at the beginning of 2022, 
although the increase will be somewhat counterbalanced by a policy package put in 
place by the government to reduce tax rates paid in energy and food products. The 
relatively low price level in Poland (about 56% of the euro area average in 2020) 
suggests significant potential for price level convergence in the long term. 
Poland fulfils the criterion on public finances. Poland is not the subject of a 
Council Decision on the existence of an excessive deficit. The general government 
deficit increased sharply to 6.9% of GDP in 2020 and fell to 1.9% in 2021. The 
Commission’s Spring 2022 Economic Forecast expects the deficit-to-GDP ratio to 
deteriorate to 4.0% in 2022, reflecting the measures taken by the government to 
reduce the economic and social impact of the increase in energy prices and the costs 
of assistance to those fleeing Ukraine. It is projected to reach 4.4% in 2023 under a 
‘no policy change’ assumption. On 23 May 2022, the Commission adopted a report 
prepared in accordance with Article 126(3) of the TFEU for 18 Member States, 
including Poland. Overall, taking into account all relevant factors as appropriate, the 
analysis in the report suggested that Poland did not fulfil the deficit criterion. In line 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 39 – 
24 
with its Communication of 2 March 202216, the Commission did not propose 
opening new excessive deficit procedures. It noted that the COVID-19 pandemic 
continues to have an extraordinary macroeconomic and fiscal impact that, together 
with Russia’s invasion of Ukraine, create exceptional uncertainty, including for 
designing a detailed path for fiscal policy. On these grounds, the Commission 
considered that a decision on whether to place Member States under the excessive 
deficit procedure should not be taken in spring 2022. The public debt-to-GDP ratio 
decreased from around 57.1% in 2020 to 53.8% in 2021 and is forecast to further 
decrease to 50.8% in 2022 and 49.8% in 2023. The debt sustainability analysis for 
Poland indicates low risk in the medium term, particularly as government debt is 
projected to stay below 60% of GDP until 2032. The fiscal framework in Poland is 
strong overall and the numerical fiscal rules are at the centre of the framework. The 
framework was recently relaxed slightly to take account of the pressures emerging 
from the COVID-19 pandemic.  
Poland does not fulfil the exchange rate criterion. The Polish zloty does not 
participate in ERM II. Poland operates a de jure floating exchange rate regime, 
allowing for foreign exchange market interventions by the central bank. The zloty 
depreciated sharply after the onset of the COVID-19 crisis in early 2020. Afterwards 
it went through a period of fluctuations but showed no clear trend up to February 
2022. The NBP intervened actively in the foreign exchange market to stabilise the 
zloty during this period. The outbreak of Russia’s invasion of Ukraine weakened the 
zloty. In April 2022, the zloty was about 2% weaker against the euro than 2 years 
earlier. The short-term interest rate differential vis-à-vis the euro area fluctuated 
strongly in 2020 and 2021, mirroring differences in the monetary policy stances in 
Poland and the euro area. It narrowed to historically low levels after the onset of the 
COVID-19 crisis on the back of an easing of the NBP’s monetary policy. From 
October 2021, the short-term interest rate differential widened rapidly as the NBP 
tightened its policy and the reference rate reached 5.25% in May 2022. International 
reserves held by the NBP increased and by the end of 2021 constituted EUR 147 
billion (around 26% of GDP).  
Poland does not fulfil the criterion on the convergence of long-term interest 
rates. The average long-term interest rate in the year to April 2022 was 3.0%, above 
the reference value of 2.6%. The easing of monetary policy after the onset of the 
16  For more information, see COM(2022) 85 final: https://ec.europa.eu/info/sites/default/files/economy-
finance/com_2022_85_1_en_act_en.pdf.  
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 40 – 
25 
pandemic in 2020 contributed to a significant decrease in the long-term interest rates, 
which remained at 1.3% until the end of 2020. In January 2021, the long-term 
interest rate reached its lowest level on record (1.2%) before starting to increase 
moderately until the summer. The tightening of monetary policy, which started in 
October 2021, then contributed to a considerable increase in the long-term interest 
rate reaching 3.0% in April 2022. The long-term interest rate spread vis-à-vis the 
German benchmark bond narrowed strongly during the early months of the COVID-
19 crisis and fluctuated around 180 basis points up-to April 2021. In mid-2021, it 
started to increase slightly and by October 2021 the spread had started to widen. By 
the end of 2021, the long-term interest rate spread reached around 373 basis points 
and continued to widen to 521 basis points in April 2022.  
The Commission has also examined additional factors, including balance of 
payments developments and the integration of markets. Poland’s external balance 
(the combined current and capital account) stayed in surplus in 2020 and 2021 but 
weakened in late 2021 and early 2022 due to the rising price of commodity imports. 
The Polish economy is well integrated with the euro area through trade and 
investment linkages. Selected indicators relating to the business environment show 
that Poland performs worse than many euro area Member States, in particular in 
relation to indicators on rule of law and government effectiveness. The financial 
sector in Poland is smaller and less developed than in the euro area. It is highly 
dominated by banks, which are well integrated into the euro area financial system. 
Market based financing is less developed, which is reflected in the very small 
markets for equity and private sector debt.  
Poland submitted its recovery and resilience plan (RRP) on 3 May 2021. The plan 
proposes investments and reforms to decarbonise the Polish economy, make the 
transport sector more sustainable, address challenges related to the investment 
climate, notably with regard to the Polish judicial system as well as decision- and 
law-making processes, improve IT connectivity and make the healthcare system 
more resilient. 
7. ROMANIA
In the light of its assessment on legal compatibility and on the fulfilment of the
convergence criteria, and taking into account the additional relevant factors, the
Commission considers that Romania does not fulfil the conditions for the
adoption of the euro.
Legislation in Romania – in particular Law No. 312 on the Statute of the Bank of
Romania (the BNR Law) – is not fully compatible with the compliance duty under
Article 131 TFEU. Incompatibilities relate to the independence of the central bank,
the prohibition of monetary financing and central bank integration into the ESCB at
the time of euro adoption. In addition, the BNR Law contains imperfections relating
to central bank independence and to central bank integration in the ESCB at the time
of euro adoption with regard to the BNR's objectives and the ESCB tasks laid down
in Article 127(2) TFEU and Article 3 of the ESCB/ECB Statute.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 41 – 
26 
Romania does not fulfil the criterion on price stability. The average inflation rate 
in Romania during the 12 months to April 2022 was 6.4%, above the reference value 
of 4.9%. It is projected to remain  above the reference value in the months ahead. 
Annual HICP inflation in Romania accelerated throughout 2021, from an average of 
2.3% in 2020 to 4.1% in 2021. The annual inflation rate fell from 3.9% in January 
2020 to 1.8% in May 2020, reflecting the reduced demand for goods and services at 
the outset of the COVID-19 pandemic, as well as the sharp drop in the international 
price of crude oil in the first 4 months of 2020. After a temporary rise to 2.5% in 
August 2020, reflecting strong food price inflation, it declined again and bottomed 
out at 1.7% in November 2020. Subsequently, inflation rose steadily, reaching 3.5% 
in June 2021 and 6.7% in December 2021. The increase was driven by higher energy 
prices throughout 2021 and, in the second half of 2021, was also sustained by higher 
core inflation. It continued to accelerate in the first 4 months of 2022, reaching 
11.7% in April 2022. Annual HICP inflation rates in Romania in 2020 and 2021 
were on average higher than those of the euro area.   
The Commission’s Spring 2022 Economic Forecast expects the annual average rate 
of inflation to increase to 8.9% in 2022, before falling to 5.1% in 2023. The 
significant increase in 2022 is mainly due to the hike in energy prices, while higher 
food prices also contribute. The relatively low price level in Romania (about 52% of 
the euro area average in 2020) suggests significant potential for price level 
convergence in the long term.  
Romania does not fulfil the criterion on public finances. Romania has been 
subject to an excessive deficit procedure since April 2020, based on the
prepandemic developments. On 18 June 2021, taking into account the continued 
application of the general escape clause of the Stability and Growth Pact, the Council 
adopted a revised recommendation under Article 126(7) of the Treaty (TFEU), with a 
view to bringing an end to the excessive government deficit in Romania by 2024 at 
the latest. On 23 May 2022, the Commission concluded that, taking into account the 
deficit outturn of 7.1% of GDP in 2021 and the fiscal effort in 2021, Romania was in 
line with the Council recommendation of 18 June 2021 and the excessive deficit 
procedure should be kept in abeyance. The improvement in the general government 
deficit in 2021, down from 9.3% of GDP in 2020, was mainly due to higher revenues 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 42 –
27 
as a result of the economic recovery, while the government also implemented some 
consolidation measures, including a freeze in public sector wages. The 
Commission’s Spring 2022 Economic Forecast projects that the general government 
deficit will decrease further to 7.5% of GDP in 2022, notwithstanding the measures 
taken by the government to reduce the economic and social impact of the increase in 
energy prices and the costs of assistance to those fleeing Ukraine. It is forecast to 
decrease to 6.3% of GDP in 2023 under the ‘no policy change’ assumption. 
However, for both 2022 and 2023, Romania is at risk of non-compliance with the 
fiscal targets established in the Council Recommendation of 18 June 2021. The 
public debt-to-GDP ratio increased from 47.2% in 2020 to 48.8% in 2021 and is 
expected to increase further to 50.9% in 2022 and 52.6% in 2023. Debt sustainability 
risks for Romania appear medium in the medium term, particularly as government 
debt is projected to increase to around 73% of GDP in 2032 and due to significant 
sensitivity of the projections to adverse macro-financial developments. Despite 
having the appropriate legislative setting, the implementation track record of the 
Romanian fiscal framework has been generally weak and has not improved since the 
last report. In particular, the annual budget laws have repeatedly contradicted 
national fiscal rules and have not been guided by  medium-term budgetary strategies. 
Romania does not fulfil the exchange rate criterion. The Romanian leu does not 
participate in ERM II. Romania operates a de jure floating exchange rate regime, 
allowing for foreign exchange market interventions by the central bank. The leu 
depreciated steadily against the euro in 2020 and 2021. In April 2022, the leu was 
about 2% weaker against the euro compared to 2 years earlier. The short-term 
interest rate spread vis-à-vis the euro area decreased by around 120 basis points 
between March 2020 and February 2021 from 330 basis points, mirroring the key 
policy rate cuts by the BNR over this period. Subsequently, it increased from its 
trough of slightly over 200 basis points in June 2021 to around 520basis points in 
April 2022, as monetary policy tightened between September 2021 and April 2022. 
Romania does not fulfil the criterion on the convergence of long-term interest 
rates. The average long-term interest rate in the year to April 2022 was 4.7%, above 
the reference value of 2.6%. At the outset of the COVID-19 crisis, the long-term 
interest rate in Romania increased sharply from 4.0% in February 2020 to 4.8% in 
April 2020. Subsequently, it decreased steadily, reaching a low of 2.7% in February 
2021, with the decline reflecting widespread monetary policy loosening measures by 
central banks. Interest rates started to increase again in March 2021 and were on an 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 43 –
28 
upward path throughout the rest of the year, rising to 5.4% in December 2021, 
reflecting higher inflationary pressures and, as from October 2021, monetary policy 
tightening in Romania. In the first 4 months of 2022, Romania’s long-term interest 
rate increased further to 6.6% in April 2022, in the context of continued inflationary 
pressures, further monetary policy tightening and greater risk aversion following 
Russia’s invasion of Ukraine. The long-term spread versus the German benchmark 
bond reached 586 basis points in that month, up from 310 basis points in February 
2021. 
The Commission has also examined additional factors, including balance of 
payments developments and the integration of markets. Romania's external balance 
(the combined current and capital account) deteriorated from -3.1% of GDP in 2020 
to -4.8% in 2021, mainly due to a widening in the goods trade deficit. The Romanian 
economy is well integrated with the euro area through trade and investment linkages. 
Selected indicators relating to the business environment show that Romania performs 
worse than many euro area Member States. In particular, companies face constraints 
to doing business such as corruption, overly regulated markets for business services, 
frequent legislative changes coupled with inadequate impact assessments. The 
financial sector in Romania is smaller and less developed than in the euro area. 
Romania's banking sector is well integrated with the euro area financial system, in 
particular through a high level of foreign ownership in its banking system. However, 
market-based financing is less developed, which is reflected in the very small 
markets for equity and private sector debt. In the context of the Macroeconomic 
Imbalance Procedure, the Commission concluded in its Alert Mechanism Report for 
2022 that Romania warranted an In-Depth Review (IDR). The latter concluded that 
Romania is experiencing macroeconomic imbalances. Vulnerabilities relate to 
external accounts and are linked to large fiscal deficits and to competitiveness issues 
that are re-emerging. 
The effective implementation of the reforms and investment set out in Romania’s 
recovery and resilience plan will address key macro-economic challenges. These 
include the sustainability of public finances, education, increasing greenhouse gas 
emissions and the lack of digital connectivity. Key investments are included for 
railway modernisation, the energy efficiency of buildings, the digitalisation of public 
administration and making the health system more resilient. Key reforms aim at  
addressing fiscal sustainability, improving access to financing, strengthening the 
public administration and modernising the social benefits system. The plan also aims 
at addressing the main issues related to respect of rule of law in Romania by 
strengthening the independence and increasing the efficiency of the judiciary, 
improving access to justice, and stepping up the fight against corruption. 
8. SWEDEN
In the light of its assessment on legal compatibility and on the fulfilment of the
convergence criteria, and taking into account the additional relevant factors, the
Commission considers that Sweden does not fulfil the conditions for the
adoption of the euro.
Legislation in Sweden – in particular the Sveriges Riksbank Act, the Instrument of
Government and the Law on the Exchange Rate Policy – is not fully compatible
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 44 – 
29 
with the compliance duty under Article 131 TFEU. Incompatibilities and 
imperfections exist in the fields of the independence of the central bank, the 
prohibition of monetary financing and central bank integration into the ESCB at the 
time of euro adoption. 
Sweden fulfils the criterion on price stability. The average inflation rate in Sweden 
during the 12 months to April 2022 was 3.7%, below the reference value of 4.9%. 
The Commission projects this to remain below the reference value in the months 
ahead. 
Sweden's annual HICP inflation rate averaged 2.7% in 2021, up from 0.7% in 2020. 
During 2021, annual HICP inflation was on a strong upward trend, and accelerated 
sharply in the first months of 2022, reaching 6.6% in April 2022. The trend was 
briefly interrupted in the middle of 2021, when inflation decreased due to a 
temporary easing in the rate of increase for prices of services and industrial goods, as 
they adjusted after the first wave of the pandemic. The overall pick-up in year-
onyear inflation mainly reflected markedly higher energy prices — foremost electricity 
prices —, and later in the year, broader price increases across various categories of 
the consumer price index. During 2021, inflation in Sweden was broadly in line with 
that of the euro area. In April 2022, annual HICP inflation stood at 6.6%. 
In the Commission’s Spring 2022 Economic Forecast, the Commission projects that 
inflation will increase to 5.3% in 2022, on the back of higher energy and commodity 
prices interacting with more persistent broader price increases, and supply chain 
disruptions, before falling back to 3.0% in 2023. The price level in Sweden is 
relatively high (about 116% of the euro area average in 2020), and given the level of 
economic development, convergence towards the prevailing euro area price level is 
unlikely. 
Sweden fulfils the criterion on public finances. Sweden is not the subject of a 
Council Decision on the existence of an excessive deficit. The general government 
balance improved from a deficit of 2.7% of GDP in 2020 to a deficit of 0.2% of GDP 
in 2021, reflecting the phasing out of several COVID-19 measures, dominating 
continued expenditure support in some areas, and a denominator effect as growth 
rebounded in 2021. The Commission’s Spring 2022 Economic Forecast expects the 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 45 –
30 
general government balance to reach -0.5% of GDP in 2022 and 0.5% in 2023, partly 
reflecting the withdrawal of fiscal support as the recovery takes hold. The public 
debt-to-GDP ratio decreased from 39.6% in 2020 to 36.7% in 2021 and is expected 
to decrease further to 33.8% in 2022 and to 30.5% in 2023. Debt sustainability risks 
for Sweden appear low in the medium term, particularly as government debt is 
projected to decline to a particularly low level by 2032 (around 11% of GDP). The 
sensitivity of the projections to adverse macro-financial developments is limited. 
Sweden has a strong fiscal framework that was reformed in 2019, preserving the key 
pillars of the previous set-up and strengthening these with new elements (such as a 
debt anchor at 35% of GDP). 
Sweden does not fulfil the exchange rate criterion. The Swedish krona does not 
participate in ERM II. Sweden operates a de jure floating exchange rate regime, 
allowing for foreign exchange market interventions by the central bank. After a long 
period of slow depreciation against the euro between 2013 and early 2020, the krona 
started to appreciate on the back of the economy’s resilience to the COVID-19 crisis. 
Between April 2020 and November 2021, the krona appreciated by almost 8% 
against the euro. The appreciation took place despite stable monetary conditions 
(compared with the euro area), where the three-month STIBOR-EURIBOR spread 
during 2020 and 2021 averaged 50 and 51 basis points, respectively. At the 
beginning of 2022, the krona depreciated, as Russia’s invasion of Ukraine spurred 
safe-haven flows, reflecting changes in risk appetite and temporary flows associated 
with dividend payments of multi-national firms. Subsequently, the krona regained 
somewhat. In April 2022, the spread stood at around 55 basis points and the 
exchange rate was 5% stronger against the euro than it had been 2 years earlier. 
Sweden fulfils the criterion on the convergence of long-term interest rates. The 
average long-term interest rate in the year to April 2022 was 0.4%, well below the 
reference value of 2.6%. Since the beginning of 2021, Swedish long-term interest 
rates have been fluctuating around a level of 0.3% on a monthly basis. This is 
slightly higher than the year before. The spread vis-à-vis the German benchmark 
bond remained low in 2020 and 2021, and even decreased slightly after a brief 
COVID-induced peak of 76 basis points in March 2021 to 46 basis points in 
February 2022. After a recent increase, the spread was 72 basis points in April 2022. 
The Commission has also examined additional factors, including balance of 
payments developments and the integration of markets. Sweden's external balance 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 46 –
31 
(the combined current and capital account) has remained in surplus, at 6.1% of GDP 
in 2020 and 5.5% in 2021. Sweden's economy is well-integrated with the euro area 
through trade and investment linkages. Selected indicators relating to the business 
environment show that Sweden performs better than most euro area Member States. 
The financial sector in Sweden is highly developed and well-integrated into the EU 
financial sector. Banking dominates the financial sector, but the insurance and 
pension funds are integral parts of significant size. Moreover, Sweden has one of the 
most developed credit and equity markets among EU Member States, and market 
financing is among the highest in the EU. In the context of the Macroeconomic 
Imbalance Procedure, the Commission concluded in its Alert Mechanism Report for 
2022 that an In-Depth Review was warranted for Sweden. Based on the assessment 
in the In-Depth Review, the Commission considers that Sweden is experiencing 
imbalances with vulnerabilities that relate to high and rising house prices and high 
household indebtedness, which exposes Sweden to the risk of adverse shocks and a 
disorderly correction of housing prices, with potential harmful implications for the 
real economy and the banking sector. 
The effective implementation of the reforms and investment set out in Sweden’s 
recovery and resilience plan (RRP) will address key macro-economic challenges. 
These include the green and digital transitions, demographic change, and 
strengthening the education and healthcare systems. Key investments include subsidy 
schemes to speed up the decarbonisation of industry and transport, the roll-out of 
high-speed broadband in sparsely populated areas and investment in learning and 
digital skills. Key reforms involve requiring fuel suppliers to blend sustainable 
biofuels in petrol, diesel and jet fuel, improving the sustainability of the pension and 
social security systems, combating money laundering, increasing the accessibility 
and capacity of the health care system, and promoting housing supply by reducing 
bottlenecks in the permit procedure. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 47 –

Convergence Report 2022 
Technical annex 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 49 –

1. INTRODUCTION
35 
1.1. ROLE OF THE REPORT 
The euro was introduced on 1 January 1999 by 
eleven Member States. Since then, Greece (2001), 
Slovenia (2007), Cyprus and Malta (2008), 
Slovakia (2009), Estonia (2011), Latvia (2014) and 
Lithuania (2015) have also adopted the euro. 
Member States for which the Council has not yet 
decided that they fulfil the necessary conditions for 
the adoption of the euro are referred to as ‘Member 
States with a derogation’. Article 140 of the Treaty 
lays down provisions and procedures for 
examining the convergence situation of Member 
States with a derogation (Box 1.1). At least once 
every two years, or at the request of a Member 
State with a derogation, the Commission and the 
European Central Bank (ECB) prepare 
Convergence Reports for such Member States. 
Denmark negotiated an opt-out arrangement before 
the adoption of the Maastricht Treaty (17) and does 
not participate in the third stage of EMU. Until 
Denmark indicates that it wishes to participate in 
the third stage and adopt the euro, it is not the 
subject of an assessment as to whether it fulfils the 
necessary conditions for such a participation.  
In 2020, the Commission and the ECB adopted 
their latest regular Convergence Reports (18). None 
of the Member States assessed in those reports was 
deemed to meet the necessary conditions for 
adopting the euro.  
In 2022, two years have elapsed since the last 
regular reports were prepared. Denmark has not 
expressed a wish to enter the third stage of 
EMU (19). Therefore, this convergence assessment 
covers Bulgaria, Czechia, Croatia, Hungary, 
Poland, Romania and Sweden. This Commission 
Staff Working Document is a Technical Annex to 
the Convergence Report 2022 and includes a 
detailed assessment of the progress with 
convergence, as required by Article 140(1) of the 
Treaty. 
(17) Protocol (No 16) on certain provisions relating to
Denmark. 
(18) European Commission, Convergence Report 2020, 
COM(2020) 237 final, 10 June 2020; European Central 
Bank, Convergence Report 2020, June 2020. 
(19) The United Kingdom has withdrew from the EU since the
May 2018 Convergence Report. 
The outbreak of the COVID-19 pandemic in 
March 2020 led to a severe economic downturn for 
the EU as a whole and in all the Member States. 
Unprecedented action taken at the level of the EU 
and the individual Member States cushioned the 
impact of the crisis and led to a robust recovery in 
2021. In particular, the swift activation of the 
general escape clause of the Stability and Growth 
Pact, coupled with the temporary framework on 
State aid, enabled large-scale fiscal support in all 
Member States. In parallel, the EU mobilised its 
budget, in particular with the EU temporary 
instrument to Support to mitigate Unemployment 
Risks in an Emergency (SURE), to mitigate the 
impact of the crisis on workers and companies. 
The ECB also took a broad set of monetary policy 
measures to preserve favourable financing 
conditions for all sectors of the economy in order 
to support economic activity and safeguard 
medium-term price stability. 
The roll-out of the Recovery and Resilience 
Facility (RRF), which is the centrepiece of 
NextGenerationEU, is further bolstering the EU’s 
resilience through large-scale financial support to 
Member States of up to EUR 723.8 billion (in 
current prices)  in grants (EUR 338 billion) and 
loans (EUR 385.8 billion)  to finance reforms and 
investments, especially those for the green and 
digital transitions. At the same time, the
strongerthan-expected recovery in 2021, supply chain 
bottlenecks and a surge in energy prices 
contributed to a sharp rise in inflation throughout 
the year and in 2022. 
Russia’s invasion of Ukraine on 24 February 2022 
forced a re-assessment of the outlook for the EU 
economy, which was hitherto expected to expand 
vigorously in 2022 and 2023. The crisis mainly has 
dealt a new supply-side shock to an economy that 
was already facing inflationary pressures. It has 
weakened recovery prospects and reinforced 
upward price pressures, while further underlining 
the need for higher private and public investment 
to diversify Europe’s energy supplies and improve 
energy security. Several of the Member States with 
a derogation assessed in this report are among the 
most heavily exposed to the crisis triggered by 
Russia’s invasion of Ukraine. To varying degrees, 
this exposure reflects the relatively high-energy 
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Convergence Report 2022 
36 
intensity of their economies, strong dependency by 
some on Russian gas and oil supplies, trade 
linkages with Russia and the provision of frontline 
assistance to people fleeing Ukraine. On 18 May 
2022, the Commission proposed a REPowerEU 
plan, for which the RRF will be a key tool. The 
plan aims to phase out dependence on fossil fuels 
from Russia well before 2030 by diversifying the 
EU’s gas supplies and speeding up the green 
transition.  
On 23 May 2022, the Commission also presented 
its European Semester spring 2022 package. 
Member States should primarily focus on the 
timely implementation of the RRPs. Therefore, the 
Commission proposes to the Council to address to 
all Member States with an approved RRP: i) a 
recommendation on fiscal policy, including
fiscalstructural reforms where relevant; ii) a 
recommendation on the implementation of the 
RRP and the cohesion policy programmes; iii) a 
recommendation on energy policy in line with the 
objectives of REPowerEU; iv) where relevant, an 
additional recommendation on outstanding and/or 
newly emerging structural challenges. The scope 
of the recommendations is larger for Member 
States that do not have approved RRPs. 
The successive economic shocks triggered by the 
COVID-19 pandemic and Russia’s invasion of 
Ukraine have important implications for the 
convergence assessment presented in this report. 
In particular, the outbreak of the COVID-19 
pandemic, the measures taken in response to that 
crisis, the surge in commodity prices, the supply 
bottlenecks and the robust recovery in 2021 have 
had a significant impact on some of the economic 
convergence indicators used in this report. This is 
especially the case for the assessment of the price 
stability criterion. Differences in inflation 
performance across the EU have increased mainly 
due to the heterogeneous impact of the recovery on 
Member States’ inflation rates and the differences 
in energy price inflation. In addition, national 
authorities have taken a range of fiscal and 
regulatory measures to cushion the impact of 
higher energy prices. While some of these 
measures, such as social transfers to most 
vulnerable households, do not have a direct impact 
on consumer prices, others have a more direct 
impact on the inflation convergence assessment. 
These include price caps in wholesale or retail 
energy markets, changes in indirect taxes on 
energy products, and subsidies on energy 
production and consumption. In addition,
longterm interest rates were influenced, initially, by the 
policy measures taken to stabilise financial 
markets and preserve favourable financing 
conditions and, later, by higher inflation 
expectations and the differentiated paths of 
monetary tightening across Member States. 
The 2020 economic recession and the fiscal 
response to the COVID-19 pandemic led to a sharp 
increase in government deficits and debt. 
Government deficits in most Member States rose 
to above the 3% of GDP reference value of the 
Treaty. In 2021, government deficits and debt 
improved and fifteen Member States had deficits 
higher than 3% of GDP. In March 2020, the 
European Commission, with the agreement of the 
EU Ministers of Finance of the Member States, 
activated the general escape clause of the Stability 
and Growth Pact. On 23 May 2022, in its 
Communication on the 2022 European Semester 
spring package, the Commission considered that 
the Union was not yet out of a period of severe 
economic downturn and that the conditions to 
maintain the general escape clause in 2023 and to 
deactivate it as of 2024 were met. The 
Commission invited the Council to endorse this 
conclusion to provide clarity to Member States. In 
spring 2020, 2021 and 2022, the Commission 
considered that a decision on whether to place 
Member States under the Excessive Deficit 
Procedure should not be taken, taking into account 
the extraordinary macroeconomic and fiscal 
impact of the COVID-19 pandemic that, together 
with the geopolitical situation in spring 2022, 
create exceptional uncertainty, including for 
designing a detailed path for fiscal policy (20). 
These conclusions have straightforward 
implications for the assessment of the criterion on 
the government budgetary position presented in 
this report. 
The impact of Russia’s invasion of Ukraine on the 
historical data used in the 2022 Convergence 
Report is limited. This is a consequence of the
cutoff date of the report (18 May 2022), which 
together with the Treaty-defined calculation 
methods of the price stability and long-term 
interest rate criteria (i.e. one year averages), mean 
that the corresponding data largely reflect the 
situation prior to Russia’s invasion. Instead, the 
extent to which the economic convergence 
(20) On 3 April 2020, the Council decided that an excessive
deficit existed in Romania based on the planned excessive
deficit in 2019. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 52 –
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Chapter 1 - Introduction 
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indicators are affected by the crisis triggered by 
Russia’s invasion as well as other ongoing 
economic developments is fully captured in the 
economic projections for 2022 and 2023, namely 
the Commission’s Spring 2022 Economic 
Forecast, which are used to assess the 
sustainability of convergence. 
The forward-looking elements of this report are 
based on inputs from the Commission’s Spring 
2022 Economic Forecast, which was published on 
16 May 2022. This forecast is the first 
comprehensive assessment from the Commission 
of the likely economic effects in 2022 and 2023 of 
the crisis triggered by Russia’s invasion of 
Ukraine, and as such, it is surrounded by higher 
than usual uncertainty (21).  
(21) Beyond the forecast horizon, the crisis could also have a
significant effect on the economic structures of the
Member States with a derogation, for instance the flow of
refugees could affect their demography and labour force in
the medium term, although at this stage this is subject to
Box 1.1: Article 140 of the Treaty
"1. At least once every two years, or at the request of a Member State with a derogation, the Commission 
and the European Central Bank shall report to the Council on the progress made by the Member States with 
a derogation in fulfilling their obligations regarding the achievement of economic and monetary union. 
These reports shall include an examination of the compatibility between the national legislation of each of 
these Member States, including the statutes of its national central bank, and Articles 130 and 131 and the 
Statute of the ESCB and of the ECB. The reports shall also examine the achievement of a high degree of 
sustainable convergence by reference to the fulfilment by each Member State of the following criteria: 
— the achievement of a high degree of price stability; this will be apparent from a rate of inflation which is 
close to that of, at most, the three best performing Member States in terms of price stability, 
— the sustainability of the government financial position; this will be apparent from having achieved a 
government budgetary position without a deficit that is excessive as determined in accordance with Article 
126(6), 
— the observance of the normal fluctuation margins provided for by the exchange-rate mechanism of the 
European Monetary System, for at least two years, without devaluing against the euro, 
— the durability of convergence achieved by the Member State with a derogation and of its participation in 
the exchange-rate mechanism being reflected in the long-term interest-rate levels. 
The four criteria mentioned in this paragraph and the relevant periods over which they are to be respected 
are developed further in a Protocol annexed to the Treaties. The reports of the Commission and the 
European Central Bank shall also take account of the results of the integration of markets, the situation and 
development of the balances of payments on current account and an examination of the development of unit 
labour costs and other price indices. 
2. After consulting the European Parliament and after discussion in the European Council, the Council shall,
on a proposal from the Commission, decide which Member States with a derogation fulfil the necessary
conditions on the basis of the criteria set out in paragraph 1, and abrogate the derogations of the Member
States concerned.
The Council shall act having received a recommendation of a qualified majority of those among its members 
representing Member States whose currency is the euro. These members shall act within six months of the 
Council receiving the Commission's proposal. 
The qualified majority of the said members, as referred to in the second subparagraph, shall be defined in 
accordance with Article 238(3)(a). 
3. If it is decided, in accordance with the procedure set out in paragraph 2, to abrogate a derogation, the
Council shall, acting with the unanimity of the Member States whose currency is the euro and the Member
State concerned, on a proposal from the Commission and after consulting the European Central Bank,
irrevocably fix the rate at which the euro shall be substituted for the currency of the Member State
concerned, and take the other measures necessary for the introduction of the euro as the single currency in
the Member State concerned."
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The remainder of the first chapter presents the 
methodology used for the application of the 
assessment criteria. Chapters 2 to 8 examine, on a 
country-by-country basis, the fulfilment of the 
convergence criteria and other requirements in the 
order in which they appear in Article 140(1) (see 
Box 1.1). The cut-off date for the statistical data 
included in this Convergence Report was 18 May 
2022.  
1.2. APPLICATION OF THE CRITERIA 
In accordance with Article 140(1) of the Treaty, 
the Convergence Reports shall examine the 
compatibility of national legislation with Articles 
130 and 131 of the Treaty and the Statute of the 
European System of Central Banks (ESCB) and of 
the European Central Bank. The reports shall also 
examine the achievement of a high degree of 
sustainable convergence by reference to the 
fulfilment of the four convergence criteria dealing 
with price stability, public finances, exchange rate 
stability and long term interest rates as well as 
some additional factors. The four convergence 
criteria are developed further in a Protocol 
annexed to the Treaty (Protocol No 13 on the 
convergence criteria). 
1.2.1. Compatibility of legislation 
In accordance with Article 140(1) of the Treaty, 
the legal examination includes an assessment of 
compatibility between a Member State’s 
legislation, including the statute of its national 
central bank, and Article 130 and 131 of the 
Treaty. This assessment mainly covers three areas. 
• First, the independence of the national central
bank and of the members of its
decisionmaking bodies, as laid down in Article 130,
must be assessed. This assessment covers all
issues linked to a national central bank's
institutional, financial independence and to the
personal independence of the members of its
decision-making bodies.
• Second, in accordance with Articles 123 and
124 of the Treaty, the compliance of the
national legislation is verified against the
prohibition of monetary financing and
privileged access. The prohibition of monetary
financing is laid down in Article 123(1) of the
considerable uncertainty. Assessing this impact is beyond 
the scope of this report. 
Treaty, which prohibits overdraft facilities or 
any other type of credit facility with the ECB 
or the central banks of Member States in favour 
of Union institutions, bodies, offices or 
agencies, central governments, regional, local 
or other public authorities, other bodies 
governed by public law, or public undertakings 
of Member States; and the purchase directly 
from these public sector entities by the ECB or 
central banks of debt instruments. As regards 
the prohibition on privileged access as set out 
in Article 124, the central banks, as public 
authorities, may not take measures granting 
privileged access by the public sector to 
financial institutions if such measures are not 
based on prudential considerations.  
• Third, in accordance with Article 131, the
integration of the national central bank into the
ESCB has to be examined, in order to ensure
that at the latest by the moment of euro
adoption, the objectives of the national central
bank are compatible with the objectives of the
ESCB as formulated in Article 127 of the
Treaty. The national provisions on the tasks of
the national central bank are assessed against
the relevant rules of the Treaty and the
ESCB/ECB Statute.
1.2.2. Price stability 
The price stability criterion is defined in the first 
indent of Article 140(1) of the Treaty: ‘the 
achievement of a high degree of price stability; this 
will be apparent from a rate of inflation which is 
close to that of, at most, the three best performing 
Member States in terms of price stability’. 
Article 1 of the Protocol on the convergence 
criteria further stipulates that ‘the criterion on price 
stability […] shall mean that a Member State has a 
price performance that is sustainable and an 
average rate of inflation, observed over a period of 
one year before the examination, that does not 
exceed by more than 1.5 percentage points that of, 
at most, the three best performing Member States 
in terms of price stability. Inflation shall be 
measured by means of the consumer price index on 
a comparable basis, taking into account differences 
in national definitions’.  
Since national consumer price indices (CPIs) 
diverge substantially in terms of concepts, methods 
and practices, they do not constitute the 
appropriate means to meet the Treaty requirement  
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 54 –
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Chapter 1 - Introduction 
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(Continued on the next page) 
Box 1.2: Assessment of price stability and the reference value
The numerical part of the price stability criterion implies a comparison between a Member State's average 
price performance and a reference value.  
A Member State’s average rate of inflation is measured by the percentage change in the unweighted average 
of the last 12 monthly indices relative to the unweighted average of the 12 monthly indices of the previous 
period, rounded to one decimal. This measure captures inflation trends over a period of one year as requested 
by the provisions of the Treaty. Using the commonly used inflation rate – calculated as the percentage change 
in the consumer price index of the latest month over the index for the equivalent month of the previous year – 
would not meet the one year requirement. The latter measure may also vary importantly from month to month 
because of exceptional factors.  
The reference value is calculated as the unweighted average of the average rates of inflation of, at most, the 
three best-performing Member States in terms of price stability plus 1.5 percentage points. The outcome is 
rounded to one decimal. While in principle the reference value could also be calculated on the basis of the 
price performance of only one or two best performing Member States in terms of price stability, it has been 
existing practice to select the three best performers. Defining the reference value in a relative way (as 
opposed to a fixed reference value) allows to take into account the effects of a common shock that affects 
inflation rates across all Member States.  
As Article 140(1) of the Treaty refers to 'Member States' and does not make a distinction between euro-area 
and other Member States, the Convergence Reports select the three best performers from all Member States – 
EU-15 for the Convergence Reports before 2004, EU-25 for the reports between 2004 and 2006, EU-27 for 
reports between 2007 and 2013, EU-28 for reports between 2014 and 2018 and EU-27 for the reports between 
2020 and 2022.  
The notion of 'best performer in terms of price stability' is not defined explicitly in the Treaty. It is 
appropriate to interpret this notion in a non-mechanical manner, taking into account the state of the economic 
environment and country-specific factors at the time of the assessment. In particular, an outlier analysis 
should be performed to identify those countries whose inflation rates cannot be seen as meaningful 
benchmarks. These outliers are identified on the basis of two criteria taken in combination: i) an inflation rate 
substantially below the euro area average; and ii) an inflation rate driven by country-specific factors that 
cannot be seen as representative of the process driving inflation in the euro area. 
Outliers were identified in the Convergence Reports of 2004, 2010, 2013, 2014 and 2016. In the 2004 report, 
Lithuania was not taken into account in the calculation of the reference value because its negative rate of 
inflation, which was due to country-specific economic circumstances, was significantly diverging from that of 
the other Member States, making Lithuania a de facto outlier that could not be considered as 'best performer' 
in terms of price stability. Its 12-month average inflation rate was 2.3 percentage points below that of the euro 
area (2.1%). In 2010, in an environment characterised by exceptionally large common shocks (the global 
economic and financial crisis and the associated sharp fall in commodity prices), a significant number of 
countries faced episodes of negative inflation rates (the euro-area average inflation rate in March 2010 was 
only slightly positive, at 0.3%). In this context, Ireland was excluded from the best performers on the ground 
that its average inflation rate (-2.3% in March 2010) deviated by a very wide margin from that of the euro 
area, mainly due to the severe economic downturn in that country. In 2013, Greece was excluded from the 
best performers, as its inflation rate was 1.8 percentage points lower than the euro area average of 2.2%, 
mainly reflecting the severe adjustment needs and the exceptional situation of the Greek economy. In 2014, 
Greece, Bulgaria and Cyprus were identified as outliers. In April 2014, the 12-month average inflation rate of 
Greece, Bulgaria and Cyprus were respectively -1.2%, -0.8% and -0.4%, significantly deviating from the euro 
area average of 1.0%. In case of Greece and Cyprus, negative inflation mainly reflected the severe adjustment 
needs and exceptional situation of the economy. In case of Bulgaria, it was due to an unusually strong  
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Box (continued) 
(Continued on the next page) 
combination of disinflationary factors, inter alia, a good harvest, administrative energy price reductions and 
declining import prices. In 2016, it was warranted to identify Cyprus and Romania as outliers, as their 
inflation rates deviated by a wide margin from the euro area average. In April 2016, the 12-month average 
(negative) inflation rates of Cyprus and Romania were respectively 1.9 percentage points and 1.4 percentage 
points below the euro area inflation rate of 0.1%. In case of Cyprus, deeply negative inflation mainly 
reflected the adjustment needs and exceptional situation of the economy. In case of Romania, it was mainly 
due to large VAT rate reductions. Table 1 lists the reference value in the Convergence Reports issued since 
1998.  
In April 2022, the three Member States with the lowest 12-month average inflation rates are: Malta (2.1%), 
Portugal (2.6%) and France (3.2%). The next Member States with the lowest average inflation are Finland 
(3.3%), Greece (3.6%) and Denmark (3.6%). The Commission’s assessment suggests that it is warranted to 
identify Malta and Portugal as outliers, as their inflation rates a.) deviated by a wide margin from the
euroarea average and b.) were driven by country-specific factors that limit their scope to act as meaningful 
benchmarks for other Member States. In past Convergence Reports those Member States that had an inflation 
rate of 1.5 percentage points or more below the euro area were generally considered as outliers.  
In addition, the inflation performances of Malta and Portugal were driven by country-specific factors. In the 
case of Malta, the country-specific factors that are reflected in the comparatively low average inflation rate 
include broadly stable energy prices in a context surging international oil and gas prices and larger changes in 
the weights used to calculate the HICP than in most other EU Member States in 2021. The absence of energy 
price inflation in Malta was enabled by government measures, including through financial support to the 
energy sector. A fixed price contract for the supply of liquefied natural gas also contributed.  
Table 1:
Inflation reference value in previous and current Convergence Reports
Convergence Report Cut-off month Three best Reference Euro area average
adoption date performers 1) 2) value 3) inflation rate 4)
1998 January 1998 Austria, France, Ireland 2.7 1.5
2000 March 2000 Sweden, France, Austria 2.4 1.4
2002 April 2002 United Kingdom, France, Luxembourg 5) 3.3 2.4
2004 August 2004 Finland, Denmark, Sweden 2.4 2.1
2006 May March 2006 Sweden, Finland, Poland 2.6 2.3
2006 December October 2006 Poland, Finland, Sweden 2.8 2.2
2007 March 2007 Finland, Poland, Sweden 3.0 2.1
2008 March 2008 Malta, Netherlands, Denmark 3.2 2.5
2010 March 2010 Portugal, Estonia, Belgium 1.0 0.3
2012 March 2012  Sweden, Ireland, Slovenia 3.1 2.8
2013 April 2013 Sweden, Latvia, Ireland 2.7 2.2
2014 April 2014 Latvia, Portugal, Ireland 1.7 1.0
2016 April 2016 Bulgaria, Slovenia, Spain 0.7 0.1
2018 March 2018 Cyprus, Ireland, Finland 1.9 1.4
2020 March 2020 Portugal, Cyprus, Italy 1.8 1.1
2022 April 2022 France, Finland, Greece 4.9 4.4
1) EU15 until April 2004; EU25 between May 2004 and December 2006; EU27 between January 2007 and June 2013; EU28 between July 2013
and January 2020; EU27 (without UK) from February 2020 onwards.
2) In case of equal rounded average inflation for several potential best performers, the ranking is determined on the basis of unrounded data.
3) Reference values are only computed at the time of Convergence Reports. All calculations of the reference value
between the Convergence Reports are purely illustrative.
4) Measured by the percentage change in the arthmetic average of the latest 12 monthly indices relative to the 
arithmetic average of the 12 monthly indices of the previous period.
5) Based on revised data, Germany would replace Luxembourg as one of the three Member States with the lowest
12-month average inflation in April 2002. This change would not affect the price and long-term interest rate reference values in April 2002.
Sources: Eurostat and European Commission calculations.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 56 –
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Chapter 1 - Introduction 
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that inflation must be measured on a comparable 
basis. To this end, the Council adopted on 23 
October 1995 a framework regulation (22) setting 
the legal basis for the establishment of a 
harmonised methodology for compiling consumer 
price indices in the Member States. This process 
resulted in the production of the Harmonised 
Indices of Consumer Prices (HICPs), which are 
used for assessing the fulfilment of the price 
stability criterion.  
As has been the case in past convergence reports, a 
Member State’s average rate of inflation is 
measured by the percentage change in the 
arithmetic average of the last 12 monthly indices 
relative to the arithmetic average of the 12 monthly 
indices of the previous period. The reference value 
is calculated as the arithmetic average of the 
average rate of inflation of the three '
bestperforming EU Member States in terms of price 
stability' plus 1.5 percentage points (see Box 1.2). 
Accordingly, the reference value is currently 4.9%, 
based on the data of France (3.2%), Finland (3.3%) 
and Greece (3.6%)  over the 12-month period 
covering May 2021-April 2022. Malta and 
Portugal were identified as outliers, as their 
inflation rates deviated by a wide margin from the 
euro area average reflecting country-specific 
economic circumstances (see Box 1.2).  
(22) Council Regulation (EC) No 2494/95 of 23 October 1995
concerning harmonised indices of consumer prices (OJ L
257, 27.10.1995, pp. 1-4), amended by Regulations (EC)
No 1882/2003 and No 596/2009 of the European
Parliament and of the Council, and repealed by Regulation 
(EU) 2016/792 of the European Parliament and of the
Council. 
The Protocol on the convergence criteria not only 
requires Member States to have achieved a high 
degree of price stability but also calls for a price 
performance that is sustainable. The requirement 
of sustainability aims at ensuring that the degree of 
price stability and inflation convergence achieved 
in previous years will be maintained after adoption 
of the euro. This deserves particular attention as 
sustained divergences in price developments in one 
or more euro area Member States can lead to the 
emergence of competitiveness losses that must be 
corrected via painful adjustment processes and can 
trigger negative spillover effects on other Member 
States.  
Inflation sustainability implies that the satisfactory 
inflation performance must essentially be due to 
the adequate behaviour of input costs and other 
factors influencing price developments in a 
structural manner, rather than reflecting the 
influence of cyclical or temporary factors. 
Therefore, this Technical Annex also takes account 
of the role of the macroeconomic situation and 
cyclical position in the inflation performance, of 
developments in unit labour costs as a result of 
trends in labour productivity and nominal 
compensation per head, and of developments in 
import prices to assess how external price 
developments have impacted on domestic 
inflation. Similarly, the impact of administered 
prices and indirect taxes on headline inflation is 
also considered.  
From a forward-looking perspective, the report 
includes an assessment of medium-term prospects 
for price developments. The analysis of factors that 
have an impact on the inflation outlook – cyclical 
Box (continued) 
In the case of Portugal, country-specific factors that are reflected in the comparatively very low average 
inflation rate include comparatively low energy inflation and the weaker cyclical position of the country 
compared with most of other EU Member States. A combination of factors weighed on energy inflation, 
including a broad range of regulatory measures that kept the growth in retail prices of electricity and natural 
gas well below the EU average. In addition, the COVID-19 crisis had a prolonged negative impact on 
Portuguese activity and inflation. The country’s activity was more severely hit than in most other EU Member 
States in the early stages of the pandemic and its recovery has since been comparatively slow. In the fourth 
quarter of 2021, Portugal’s GDP was still significantly below its pre-crisis peak and the gap was the second 
largest in the EU. This reflects mainly Portugal’s large exposure to tourism. Portugal’s vulnerability was 
magnified by the aviation-based nature of its tourism industry. Aviation-based tourism was hit by the 
COVID-19 crisis more severely and more durably than the road-based tourism prevalent in most other 
Member States. The relative weakness in Portugal’s recovery has had a lasting dampening effect on inflation 
in services, particularly in sectors related to tourism with Portugal posting, for instance, the lowest rate of 
inflation in the EU in the hotel and accommodation sector.  
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conditions, labour market developments and credit 
growth – is complemented by a reference to the 
most recent Commission’s forecast of inflation. 
That forecast can subsequently be used to assess 
whether the Member State is likely to meet the 
reference value also in the months ahead (23). 
Medium-term inflation prospects are also assessed 
by reference to the economies' key structural 
characteristics, including the functioning of the 
labour and product markets. 
1.2.3. Public finances 
The convergence criterion dealing with the 
government budgetary position is defined in the 
second indent of Article 140(1) of the Treaty as 
‘the sustainability of the government financial 
position; this will be apparent from having 
achieved a government budgetary position without 
a deficit that is excessive as determined in 
accordance with Article 126(6)’. Furthermore, 
Article 2 of the Protocol on the convergence 
criteria states that this criterion means that ‘at the 
time of the examination the Member State is not 
the subject of a Council decision under Article 
126(6) of the said Treaty that an excessive deficit 
exists’. 
The convergence assessment in the budgetary area 
is thus directly linked to the excessive deficit 
procedure which is specified in Article 126 of the 
Treaty and further clarified in the Stability and 
Growth Pact (see Box 1.3 for further information 
on the excessive deficit procedure as strengthened 
by the 2011 reform of the Stability and Growth 
Pact). The details of the excessive deficit 
procedure are defined in Regulation 1467/97 as 
amended in 2005 and 2011 which sets out the way 
in which government deficit and debt levels are 
assessed to determine whether an excessive deficit 
exists, under Article 126 of TFEU. The 
convergence assessment in the budgetary area is 
therefore judged by whether the Member State is 
subject to a Council decision under 126(6) on the 
existence of an excessive  deficit (24). 
(23) Based on the Commission services’ Spring 2022 Forecast,
the inflation reference value is forecast to stand at 6.3% in
December 2022. 
(24) The definitions of the government deficit and debt used in
this report are in accordance with the excessive deficit
procedure, as was the case in previous convergence reports.
These definitions are laid out in the amended Council
Regulation (EC) No 479/2009. In particular, government
debt is general government consolidated gross debt at
nominal value. Information regarding the excessive deficit
procedure and its application to different Member States
On 23 May 2022, the Commission adopted a 
report under Article 126(3) of the TFEU for 18 
Member States, including for Bulgaria, Czechia, 
Hungary and Poland (25). Overall, taking into 
account all relevant factors as appropriate, the 
analysis in the report suggests that the deficit 
criterion as defined in the Treaty and in Regulation 
(EC) No 1467/1997 is not fulfilled by Bulgaria, 
Czechia, Hungary and Poland. Taking into account 
all relevant factors, the analysis also suggests that 
the debt criterion as defined in the Treaty and in 
Regulation (EC) No 1467/1997 is not fulfilled by 
Hungary. The Commission considered, within its 
assessment of all relevant factors, that compliance 
with the debt reduction benchmark could imply a 
too demanding frontloaded fiscal effort that risks 
to jeopardise growth. Therefore, in the view of the 
Commission, compliance with the debt reduction 
benchmark is not warranted under the current 
exceptional economic conditions. In its 
conclusions, the Commission noted that the 
COVID-19 pandemic continues to have an 
extraordinary macroeconomic and fiscal impact 
that, together with the invasion of Ukraine by 
Russia, creates exceptional uncertainty, including 
for designing a detailed path for fiscal policy. On 
these grounds, the Commission considered that a 
decision on whether to place Member States under 
the EDP should not be taken in spring 2022. 
While Romania had become subject to an 
Excessive Deficit Procedure (EDP) due to the 
planned non-compliance with the deficit criterion 
in 2019, the Commission has not proposed to open 
other Excessive Deficit Procedures since the 
outbreak of the COVID-19 pandemic. In the 
context of the European Semester, the fiscal 
recommendations for 2022 and 2023 were 
consistent with the principles of cross-country 
differentiation,  while also taking into account the 
quality of public finances (see Box 1.4). 
since 2002 can be found at: 
http://ec.europa.eu/economy_finance/economic_governanc
e/sgp/deficit/index_en.htm. 
(25) Croatia was not discussed in this report. While its
government debt at end 2021 was also above 60% of GDP,
the general government deficit in 2021 and 2022 was  (and
is projected to remain) below 3% of GDP and it respected
the debt reduction benchmark in 2021.
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(Continued on the next page) 
Box 1.3: Excessive deficit procedure
The excessive deficit procedure (EDP) is specified in Article 126 of the Treaty, the associated Protocol on 
the excessive deficit procedure and Council Regulation (EC) No 1467/97 on speeding up and clarifying the 
implementation of the excessive deficit procedure (1). Together, these determine the steps to be followed to 
reach a Council decision on the existence and correction of an excessive deficit, which forms the basis for 
the assessment of compliance with the convergence criterion on the government budgetary position. The 
debt criterion in Article 126(2) of the Treaty was operationalised in the 2011 amendment of Council 
Regulation (EC) No 1467/97. 
Article 126(1) states that Member States shall avoid excessive government deficits. The Commission is 
required to monitor the development of the budgetary situation and of the stock of government debt in the 
Member States with a view to identifying gross errors (Article 126(2)). Compliance with budgetary 
discipline is examined by the Commission on the basis of the following two criteria: 
• whether the ratio of the planned or actual government deficit to gross domestic product exceeds a
reference value, specified in the Protocol on the EDP as 3% of GDP, unless:
− the ratio has declined substantially and continuously and reached a level that comes close to the
reference value;
− or, alternatively, the excess over the reference value is exceptional and temporary and the ratio
remains close to the reference value;
• whether the ratio of government debt to gross domestic product exceeds a reference value, specified in
the Protocol on the EDP as 60% of GDP, unless the ratio is sufficiently diminishing and approaching the
reference value at a satisfactory pace.
According to the EDP Protocol, the Commission provides the statistical data for the implementation of the 
procedure. Member States have to provide data on government deficits, government debt, nominal GDP and 
other associated variables twice a year, before 1 April and before 1 October (2). Eurostat validates the 
submitted data subject to its compliance with ESA2010 (3) rules and related Eurostat decisions. 
Under Article 126(3), the Commission prepares a report if a Member State does not fulfil the requirements 
under one or both of the above criteria. The report takes into account whether the government deficit 
exceeds government investment expenditure and all other relevant factors. These include developments 
related to the medium-term economic position (4), the medium-term budgetary position (5), the medium-term 
government debt position (6), and other factors which, in the opinion of the Member State concerned, are 
relevant and which the Member State has put forward.  
The Council and the Commission make a balanced overall assessment of the relevant factors. Those factors 
shall be taken into account in the steps leading to the decision on the existence of an excessive deficit when 
assessing compliance on the basis of the debt criterion. When assessing compliance on the basis of the 
deficit criterion in a country with a debt ratio exceeding the reference value, those factors shall be taken into 
account in the steps leading to the decision on the existence of an excessive deficit subject to the double 
(1) OJ L 209, 2.8.1997, p. 6. Regulation as amended by Regulation (EC) No 1056/2005 (OJ L 174, 7.7.2005, p. 5). 
(2) Council Regulation (EC) No 479/2009 on the application of the Protocol on the excessive deficit procedure (OJ L
145, 10.06.2009, p1), as amended. 
(3) Regulation (EU) No 549/2013 of the European Parliament and of the Council of 21 May 2013 on the European
system of national and regional accounts in the European Union, OJ L 174, 26.6.2013, p 1–727). 
(4) In particular, potential growth, including the various contributions, cyclical developments, and the private sector net
savings position. 
(5) In particular, the record of adjustment towards the medium-term budgetary objective, the level of the primary balance 
and developments in primary expenditure, the implementation of policies in the context of the prevention and
correction of excessive macroeconomic imbalances and in the context of the common growth strategy of the Union,
as well as the overall quality of public finances, in particular the effectiveness of national budgetary frameworks.
(6) In particular, debt dynamics and sustainability, including risk factors, the maturity structure and currency
denomination of the debt, stock-flow adjustment and its composition, accumulated reserves and other financial assets,
guarantees (in particular those linked to the financial sector), and implicit liabilities related to ageing and private debt,
to the extent that it may represent a contingent implicit liability for the government. 
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Box (continued) 
condition that the deficit is close to the reference value and its excess over it is temporary. Due consideration 
is foreseen for pension reforms introducing a multi-pillar system including a mandatory, fully-funded pillar 
and the net cost of the publicly managed pillar. 
In the next step of the procedure, the Economic and Financial Committee (EFC) formulates an opinion on 
the Commission report within two weeks of its publication (Article 126(4), Article 3.1 of Regulation 
1467/97). If the Commission considers that an excessive deficit exists or may occur, the Commission 
addresses an opinion to the Council (Article 126(5)). Then, on the basis of the Commission’s proposal and 
the overall assessment the Council decides whether an excessive deficit exists (Article 126(6)).  
If the Council decides that an excessive deficit exists, it has to issue without delay a recommendation to the 
Member State concerned to correct the deficit within a given period (Article 126(7)). According to 
Regulation 1467/97, the Council recommendation should specify the deadline for the correction of the 
excessive deficit, the annual budgetary targets, and a maximum deadline of six months for effective action to 
be taken by the Member State concerned. Within this deadline, the Member State concerned shall report to 
the Council on actions taken. The report shall include targets for government expenditure, revenue and 
discretionary measures consistent with the Council's recommendation, as well as information on the 
measures taken and the nature of those envisaged to achieve the targets.  
If effective action has been taken in compliance with a recommendation under Article 126(7) and, compared 
with the economic forecasts underlying the recommendation, unexpected adverse economic events with 
major unfavourable consequences for government finances occur subsequent to its adoption, the Council 
may decide, on a recommendation from the Commission, to adopt a revised recommendation under the same 
article. The revised recommendation may extend the deadline for the correction of the excessive deficit. In 
the case of severe economic downturn for the euro area or the EU as a whole, the Council may also decide, 
on recommendation by the Commission, to adopt a revised recommendation under Article 126(7), provided 
that this does not endanger fiscal sustainability in the medium term. 
If the Council establishes lack of effective action in response to its recommendations, the Council adopts a 
decision under Article 126(8) on the basis of a Commission recommendation immediately after the 
expiration of the deadline for taking action (or at any time thereafter when monitoring of the action taken by 
the Member State indicates that action is not being implemented or is proving to be inadequate). The 
provisions of Article 126(9 and 11) on enhanced Council surveillance and sanctions in case of
noncompliance, as well as the enforcement mechanisms introduced in 2011, are not applicable to Member 
States with a derogation (that is, those that have not yet adopted the euro), which is the case of the Member 
State considered in this report. Following a Council decision establishing, under Article 126(8), that the 
Member State did not take effective action in response to a Council recommendation under Article 126(7), 
the Council, on recommendation by the Commission, addresses to Member States with a derogation a new 
recommendation under Article 126(7).  
When, in the view of the Council, the excessive deficit in the Member State concerned has been corrected, 
the Council abrogates its decision on the existence of an excessive deficit, again on the basis of a 
Commission recommendation (Article 126(12)). 
More information about the EU fiscal surveillance framework can be found in the Vade Mecum on the 
Stability and Growth Pact, European Economy Institutional Paper 101, April 2019: 
https://ec.europa.eu/info/publications/vade-mecum-stability-and-growth-pact-2019-edition_en  
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Box 1.4: Fiscal policy in the EU since COVID-19 crisis
On 20 March 2020, the Commission issued a Communication where it considered that the conditions for 
activating the general escape clause of the Stability and Growth Pact (SGP) were fulfilled. The EU Finance 
Ministers endorsed the Commission’s view on 23 March 2020. 
The general escape clause can be activated in case of a severe economic downturn in the euro area or the EU 
as a whole. Specifically, in the preventive arm of the SGP, Regulation (EC) 1466/97, Articles 5(1) and 9(1), 
states that “in periods of severe economic downturn for the euro area or the Union as a whole, Member 
States may be allowed temporarily to depart from the adjustment path towards the medium-term budgetary 
objective, provided that this does not endanger fiscal sustainability in the medium term”. For the corrective 
arm, Regulation (EC) 1467/97, Articles 3(5) and 5(2), stipulates that in the case of a severe economic 
downturn, the Council may decide, on a recommendation from the Commission, to adopt a revised fiscal 
trajectory for Member States under an excessive deficit procedure. 
The general escape clause is a provision introduced with the SGP reform of 2011 (six-pack reform), in the 
wake of the global financial crisis, and was untested before the COVID-19 crisis. It allows for a collective 
departure from the normal requirements of the Pact. This has facilitated the deployment of large fiscal support 
to the healthcare sector, households and firms to cope with the pandemic and the related restrictions to 
economic activities. 
No new Excessive Deficit Procedure (EDP) has been opened since the activation of general escape clause. 
The situation created by the COVID-19 crisis first and by the Russia's invasion of Ukraine in February 2022 
create exceptional uncertainty, including for designing a detailed path for fiscal policy. 
A bold, coordinated fiscal policy response to the pandemic, unprecedented support from new EU instruments 
and the accommodative monetary policy have helped the EU economy weather the COVID-19 crisis and are 
underpinning the recovery. However, public deficits and debts increased significantly. In 2020, the EU 
aggregate deficit rose to 6.8% of GDP from 0.6% in 2019. It then fell to 4.7% of GDP in 2021 and, based on 
the Commission’s Spring 2022 Economic Forecast, it is expected to fall further in 2022 (to 3.6%) thanks to 
the improved cyclical conditions and the phasing out of the emergency temporary measures related to 
COVID-19, while measures to mitigate to impact of the energy crisis and to provide assistance to people 
fleeing Ukraine have a deficit-increasing impact in 2022. The aggregate EU government debt rose by 12.5 
percentage points in 2020, to 90% of GDP(1), and is expected to fall to around 87% by the end of 2022. 
For 2022, the Council provided qualitative recommendations on the 2021 Stability and Convergence 
Programmes in June 2021. The fiscal recommendations were differentiated on the basis of debt levels: 
• Member States with high debt were recommended to use the Recovery and Resilience Facility (RRF) to 
finance additional investment in support of the recovery, while pursuing a prudent fiscal policy and 
preserving nationally financed investment. Italy and Portugal were also recommended to limit the growth 
of nationally-financed current expenditure (net of discretionary revenue measures).
• Member States with low/medium debt were recommended to pursue/maintain a supportive fiscal stance
and preserve nationally financed investment. Lithuania, Latvia, Bulgaria and Croatia were also
recommended to keep the growth of nationally financed current expenditure under control.
For the purpose of these recommendations, all the Member States with a derogation were classified in the 
low/medium debt group.  
In 2022, based on the Commission’s Spring 2022 Economic Forecast and including the information 
incorporated in their 2022 Convergence Programme, the fiscal stance in 2022 is projected to be supportive in 
Bulgaria, Croatia, Poland and Sweden, as recommended by the Council. On the other hand, the fiscal stance 
in 2022 is projected to be broadly neutral in Czechia and Hungary, while the Council recommended a 
supportive stance. All the Member States with a derogation, except Czechia, plan to preserve their
nationallyfinanced investment, as recommended by the Council. In the case of Czechia, nationally-financed investment 
(1) Non-consolidated for intergovernmental loans. 
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1.2.4. Exchange rate stability 
The Treaty refers to the exchange rate criterion in 
the third indent of Article 140(1) as ’the 
observance of the normal fluctuation margins 
provided for by the exchange-rate mechanism of 
the European Monetary System, for at least two 
years, without devaluing against the euro’. 
Article 3 of the Protocol on the convergence 
criteria stipulates: ’The criterion on participation in 
the exchange rate mechanism of the European 
Monetary System […] shall mean that a Member 
State has respected the normal fluctuation margins 
provided for by the exchange-rate mechanism of 
the European Monetary System without severe 
tensions for at least the last two years before the 
examination. In particular, the Member State shall 
not have devalued its currency’s bilateral central 
rate against the euro on its own initiative for the 
same period’ (26). Based on the Council Resolution  
(26) In assessing compliance with the exchange rate criterion,
the Commission examines whether the exchange rate has
remained close to the ERM II central rate, while reasons
for an appreciation may be taken into account, in
accordance with the Common Statement on Acceding
Countries and ERM II by the Informal ECOFIN Council,
Athens, 5 April 2003. 
Box (continued) 
is projected to provide a contractionary contribution to the fiscal stance of 0.6 percentage point in 2022. In 
Croatia and Bulgaria, the growth in nationally-financed primary current expenditure (net of new revenue 
measures) in 2022 is projected to provide a significant expansionary contribution to the overall fiscal stance 
(of 1.0 and 1.4 percentage points, respectively). These significant expansionary contributions are only 
partially due to the measures to address the economic and social impact of the increase in energy prices and 
the costs to offer temporary protection to displaced persons from Ukraine. Therefore, on the basis of current 
Commission estimates, Croatia and Bulgaria do not sufficiently keep under control the growth of
nationallyfinanced current expenditure in 2022.  
In its Communication on the 2022 European Semester spring package of 23 May 2022, the Commission 
considered that the Union was not yet out of a period of severe economic downturn and the conditions to 
maintain the general escape clause in 2023 and to deactivate it as of 2024 were met. This consideration was 
made in the context of war in Europe, unprecedented energy price hikes and continued supply chain 
disturbances, with heightened uncertainty and strong downside risks to the economic outlook. The 
Commission invited the Council to endorse this conclusion to provide clarity to Member States.   
The Commission called for fiscal policy to be prudent in 2023, while standing ready to react to the evolving 
economic situation. Fiscal policy should combine higher investment with controlling the growth in 
nationally-financed primary current expenditure, while allowing automatic stabilisers to operate and 
providing temporary and targeted measures to mitigate the impact of the energy crisis and to provide 
assistance to people fleeing from Russia's invasion of Ukraine. Full and timely implementation of the RRPs is 
key to achieving higher levels of investment. Moreover, Member States’ fiscal plans for 2023 should be 
anchored by prudent medium-term adjustment paths reflecting fiscal sustainability challenges associated with 
high debt-to GDP levels that have increased further due to the pandemic. 
The Commission recommended that fiscal policies in 2023 should continue to be appropriately differentiated 
across Member States: 
• High-debt Member States should ensure prudent fiscal policy, in particular by limiting the growth of 
nationally-financed current expenditure below medium-term potential output growth, taking into account 
continued temporary and targeted support to households and firms (subject to State Aid rules) most 
vulnerable to energy price hikes and to people fleeing Ukraine.
• Low/medium-debt Member States should specifically ensure that the growth of nationally-financed 
current expenditure is in line with an overall neutral policy stance, taking into account continued 
temporary and targeted support to households and firms (subject to State Aid rules) most vulnerable to 
energy price hikes and to people fleeing Ukraine.
All Member States should stand ready to adjust current spending to the evolving situation and expand public 
investment for the green and digital transitions and for energy security, including by making use of the RRF, 
REPowerEU and other EU funds. 
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(Continued on the next page) 
Box 1.5: A reinforced approach to ERM II participation by means of upfront policy 
commitments by the applicant Member States
Participating in ERM II is an essential step for a Member State with a derogation on the way to fulfil the 
exchange rate criterion and to euro adoption. Fulfilling the exchange rate criterion through the smooth 
participation in ERM II is provided for in Article 140 of the TFEU, Protocol No 13 to the TFEU on the 
convergence criteria and the Resolution of the European Council on the establishment of an exchange-rate 
mechanism in the third stage of economic and monetary union adopted in Amsterdam on 16 June 1997 (1). 
In accordance with this framework, ERM II entry of a Member State with a derogation requires a mutual 
agreement of all ‘ERM II parties’. These include the finance ministers of euro area Member States, the 
European Central Bank, and the finance ministers and the central bank governors of the non-euro area 
Member States participating in ERM II. The European Commission provides analytical support to the ERM 
II process, but has no voting right and no right of initiative in the ERM II entry process. 
In July 2018, learning from past episodes of economic overheating in ERM II and the euro-area crisis, the 
ERM II parties clarified the modalities of a reinforced approach for future ERM II participation with a view 
of ensuring a smooth transition to, and participation in, ERM II, in their statement on Bulgaria’s path 
towards ERM II, stating that this approach would apply to all Member States wishing to join ERM II from 
then onwards (2). The reinforced approach was confirmed in the later statement of the ERM II parties of July 
2019 on Croatia’s path towards ERM II participation (3). 
According to this reinforced approach, the applicant Member State and ERM II parties agree on a number of 
policy commitments to be implemented by the former before joining ERM II. This package of so called 
prior policy commitments aims at maximising the country’s chances to operate smoothly in ERM II. It is 
country-specific, targeted and covers policy areas that are highly relevant for a smooth transition to and 
participation in ERM II including, for instance institutional quality, governance, the financial sector, fiscal 
policy, or the business environment. 
In particular, as being part of the euro area now also implies for a Member State to be part of the Banking 
Union’s pillars of the Single Supervisory Mechanism (SSM) and the Single Resolution Mechanism (SRM), 
the applicant Member State is expected to enter into ‘close cooperation’ with the ECB for banking 
supervision purposes at the latest by the time of its participation in ERM II. A Member State with a 
derogation can join the Banking Union before its euro adoption via an arrangement called ‘close 
cooperation’. Entering in close cooperation with the ECB means that the significant credit institutions 
established in the country concerned are supervised by the ECB via the involvement of the domestic national 
supervisor. Entering in close cooperation also implies participation in the Single Resolution Mechanism, 
including the Single Resolution Fund. 
In terms of process, the ECB and the Commission monitor the fulfilment of the prior-commitments 
undertaken by the applicant Member States in the respective areas of competence of the ECB and the Union 
and in close cooperation with the Member State concerned. The two institutions regularly inform ERM II 
parties on the progress made with the prior-commitments. A comprehensive assessment of the applicants’ 
banking sector is carried out by the ECB as part of the process of establishing close cooperation with the 
ECB. This includes an asset quality review and a stress test that aims at assessing whether banks are 
fundamentally sound. The results of the comprehensive assessment are made public on the ECB’s 
website (4). 
(1) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A31997Y0802%2803%29
(2) See: https://www.consilium.europa.eu/en/press/press-releases/2018/07/12/statement-on-bulgaria-s-path-towards-
ermii-participation/ 
(3) See: https://www.consilium.europa.eu/en/press/press-releases/2019/07/08/statement-on-croatia-s-path-towards-
ermii-participation/ 
(4) The results of the comprehensive assessment of six Bulgarian banks are available at: 
https://www.bankingsupervision.europa.eu/press/pr/date/2019/html/ssm.pr190726~1b474e3467.en.html 
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on the establishment of the ERM II (27), the 
European Monetary System has been replaced by 
the Exchange Rate Mechanism II upon the 
introduction of the euro, and the euro has become 
the centre of the mechanism. 
In its assessment of the exchange rate stability 
criterion, the Commission takes into account 
developments in auxiliary indicators such as 
foreign reserve developments and short-term 
interest rates, as well as the role of policy 
measures, including foreign exchange 
interventions, and international financial assistance 
wherever relevant, in maintaining exchange rate 
stability. 
The assessment of this criterion verifies the 
participation in ERM II and examines exchange 
rate behaviour within the mechanism. Currently 
two of the Member States assessed in this 
Convergence Report, namely Bulgaria and Croatia, 
(27) 97/C 236/03 of 16 June 1997, OJ C 236, 2.8.1997, p.5. 
participate in ERM II (see Box 1.5 for further 
information on ERM II participation). The relevant 
period for assessing exchange rate stability in this 
Technical Annex is 19 May 2020 to 18 May 2022.  
1.2.5. Long-term interest rates 
The fourth indent of Article 140(1) of the Treaty 
requires that ’the durability of convergence 
achieved by the Member State with a derogation 
and of its participation in the exchange rate 
mechanism’ is ’reflected in the long-term interest 
rate levels’. Article 4 of the Protocol on the 
convergence criteria further stipulates that ’the 
criterion on the convergence of interest rates […] 
shall mean that, observed over a period of one year 
before the examination, a Member State has had an 
average nominal long-term interest rate that does 
not exceed by more than two percentage points 
that of, at most, the three best performing Member  
Box (continued) 
In line with the long-standing ERM II practice, ERM II parties also expect applicant Member States to take 
further policy commitments at the moment of joining ERM II with the aim of achieving a high degree of 
sustainable economic convergence by the time the euro will be adopted. 
At the time of writing this report, Bulgaria, Croatia and Denmark were the only non-euro-area Member 
States participating in ERM II. Bulgaria and Croatia joined the ERM II on 10 July 2020 after having 
completed their respective prior policy commitments (5). Both countries established close cooperation with 
the ECB. In addition, the prior policy commitments of the Bulgarian authorities covered measures related to 
the macroprudential framework, the supervision of the non-banking financial sector, the insolvency 
framework, the anti-money laundering framework and the governance of state-owned enterprises (6). The 
additional prior policy commitments of the Croatian authorities covered measures related to the 
macroprudential framework, the anti-money laundering framework, the collection, production and 
dissemination of statistic, public sector governance and firms’ administrative and financial burden (7). 
At the time of ERM II entry, the Bulgarian and Croatian authorities also committed to pursue sound 
economic policies with the aim of preserving economic and financial stability and achieving a high degree 
of sustainable economic convergence. In particular, the Bulgarian authorities committed to implement 
specific policy measures (the so-called post-ERM II entry commitments) on the non-banking financial 
sector, state-owned enterprises, the insolvency framework and the anti-money laundering framework (8). 
The Croatian authorities committed to implement specific policy measures on the anti-money laundering 
framework, the business environment, state-owned enterprises and the insolvency framework (9). 
(5) For the details on the decision of the ERM II parties on Croatia and Bulgaria see: 
https://ec.europa.eu/commission/presscorner/detail/en/IP_20_1321 
(6) For more details on the prior-commitments taken by Bulgarian authorities see: 
https://www.consilium.europa.eu/media/36125/st11119-en18.pdf 
(7) For the details on the decision of the ERM II parties on Croatia and Bulgaria see: 
https://ec.europa.eu/commission/presscorner/detail/en/IP_20_1321 
(8) See: https://www.ecb.europa.eu/pub/pdf/annex/ecb.pr200710_annex~29156bba37.en.pdf 
(9) See: https://www.ecb.europa.eu/pub/pdf/annex/ecb.pr200710_1_annex.en.pdf 
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States in terms of price stability. Interest rates shall 
be measured on the basis of long-term government 
bonds or comparable securities, taking into 
account differences in national definitions’ (see 
Box 1.6). 
For the assessment of the criterion on the 
convergence of interest rates, yields on benchmark 
long-term bonds have been taken, using an average 
rate over the latest 12 months. The reference value 
for April 2022 is calculated as the simple average 
of the average long-term interest rates in France 
(0.3%), Finland (0.2%) and Greece (1.4%) plus 2 
percentage points, yielding a reference value of 
2.6%. 
1.2.6. Additional factors 
Article 140(1) TFEU also requires that the reports 
take into account other factors relevant to 
economic integration and convergence. These 
additional factors include financial, product and 
labour market integration and the development of 
the balance of payments. The analysis of the 
development of unit labour costs and other price 
indices, which is also prescribed by Article 140 of 
the Treaty, is covered in the price stability section. 
The assessment of additional factors gives an 
important indication of a Member State's ability to 
integrate into the euro area without difficulties. As 
regards the balance of payments, the focus is on 
the situation and development of the external 
balance (28). Market integration is assessed 
through  
(28) The external balance is defined as the combined current
and capital account (net lending/borrowing vis-à-vis the
rest of the world). This concept permits in particular to take 
full account of external transfers (including EU transfers),
which are partly recorded in the capital account. It is the
concept closest to the current account as defined when the
Maastricht Treaty was drafted. 
Box 1.6: Data for the interest rate convergence
The fourth indent of Article 140(l) of the Treaty requires that the durability of nominal convergence and 
exchange rate stability in Member States should be assessed by reference to long-term interest rates. Article 
4 of the Protocol on the convergence criteria adds that these “Interest rates shall be measured on the basis of 
long-term government bonds or comparable securities, taking into account differences in national 
definitions”. 
Article 5 of the Protocol requires that the Commission should provide the statistical data used for the 
application of the convergence criteria. However, in the context of the interest rate criterion, the ECB has 
developed the criteria for harmonising the series of 10-year benchmark bond yields on behalf of Eurostat 
and collects the data from the central banks. The selection of bonds for inclusion in this series is based on 
the following criteria: 
• issued by central government;
• a residual maturity as close as possible to 10 years;
• adequate liquidity, which is the main selection criterion; the choice between a single benchmark or the
simple average of a sample is based on this requirement;
• fixed coupon;
• yield gross of tax.
For sixteen Member States, the residual maturity of the benchmark bond is at least 9.5 years. For eleven 
Member States, the residual maturity of the benchmark bond is below 9.5 years, in particular for Lithuania 
and Luxembourg with residual maturity below 3 and 5 years respectively. All yields are calculated on the 
basis of secondary market rates, where available. For Czechia, Germany and Spain a basket of bonds is 
used, while a single benchmark bond is used in twenty-four Member States.  
Data used in this Report can be found on Eurostat ("Maastricht criterion bond yields (mcby): EMU 
convergence criterion bond yields", code: tec00097). The same series is also published by the ECB's 
Statistical Data Warehouse (code IRS.M.Country Code.L.L40.CI.0000.Currency Code.N.Z) and in a 
dedicated page in the ECB website with additional information: 
http://www.ecb.europa.eu/stats/financial_markets_and_interest_rates/long_term_interest_rates/html/index. 
en.html. 
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(Continued on the next page) 
Box 1.7: The Macroeconomic Imbalance Procedure (MIP)
Key elements of the MIP 
A key lesson from the economic and financial crisis was that the economic governance framework in the EU 
needed to be further strengthened to better support macroeconomic stability, including in aspects beyond 
fiscal policy. The Macroeconomic Imbalance Procedure (MIP) responds to that need by aiming at the 
detection, prevention and correction of macroeconomic imbalances that could harm economic stability in an 
EU country, the euro area, or the EU as a whole. It was a key element of the legislative package (the "Six-
Pack") to enhance the governance structures in the EU adopted in 2011.  
No simple and mechanistic criteria are available for the identification of macroeconomic imbalances because 
drivers of macroeconomic instability are multi-dimensional phenomena whose severity needs to be assessed 
along several aspects and taking into account also country-specific features, notably linked to the adjustment 
capacity of the economy. For this reason, the MIP relies on an annual two-step approach for the 
identification of imbalances. 
In a first step for the identification of imbalances under the MIP, the Alert Mechanism Report (AMR) 
identifies the Member States that require more in-depth investigation on whether they may be affected by 
macroeconomic imbalances. The AMR builds on the economic reading of a scoreboard of economic and 
financial indicators with indicative thresholds. The scoreboard covers different challenges Member States 
may be faced with and comprises fourteen indicators of external imbalances and competitiveness 
developments, internal imbalances, and the employment situation (1). In particular, it encompasses variables 
that the economic literature associates with crisis episodes. Beyond the scoreboard, the analysis in the AMR 
takes into account additional information and assessment tools, as well as previous in-depth assessments at 
country level. 
In a second step, the analysis carried out in the in-depth reviews (IDRs) for selected Member States provides 
the basis for the identification of imbalances, and their severity, by the Commission. IDR analysis makes use 
of updated and country-specific information and analytical tools developed by the Commission services.  
Both ‘imbalances’ and ‘excessive imbalances’ imply possible recommendations by the Council upon 
Commission proposal, which have so far been integrated in the single package of Country-Specific 
Recommendations (CSRs) under the European Semester. The identification of ‘excessive imbalances’ 
implies a stronger surveillance process, possibly leading to an Excessive Imbalance Procedure. The latter 
provides a framework underpinned by a corrective action plan designed by the concerned Member State, 
endorsed by the Commission and the Council and monitored by the Commission, and including the 
possibility of sanctions for euro area Member States in case of repeated non-compliance. Whilst the 
Excessive Imbalance Procedure has never been launched, Member States experiencing excessive imbalances 
have tended to receive more policy recommendations than other Member States. Over the last two years, the 
approach to CSRs, including MIP-relevant ones, was subject to some streamlining as economic policy 
coordination refocused first on the response to the COVID-19 pandemic crisis and subsequently on the 
preparation and implementation of the recovery and resilience plans to address the green and digital 
transition challenges for our economies and societies. The review of the EU economic governance 
framework, encompassing the MIP, is ongoing (2).  
(1) The variables are: current account, net international investment position, real effective exchange rates, unit labour cost, 
and export market shares; private sector debt, general government debt, private sector credit flow, change in total 
financial sector liabilities, house prices; unemployment rate, activity rate, long-term and youth unemployment.
(2) Communication from the Commission to the European Parliament, the Council, the European Central Bank, the 
European Economic and Social Committee, the Committee of the Regions, “The EU economy after COVID-19: 
implications for economic governance”, (COM(2021) 662 final).
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Chapter 1 - Introduction 
51 
trade, foreign direct investment and a smooth 
functioning of the internal market. Moreover, 
progress in financial integration is examined, 
together with the main characteristics, structures 
and trends of the financial sector. Given that 
Member States which adopt the euro also 
participate in the banking union, developments in 
national banking sectors are specifically looked at 
as well. 
Starting with the 2012 Convergence Report, the 
convergence assessment is aligned with the 
broader European Semester approach which takes 
an integrated look at the economic policy 
challenges facing EMU in ensuring fiscal 
sustainability, competitiveness, financial market 
stability and economic growth. 
The section on additional factors makes reference 
to the surveillance of macroeconomic imbalances 
under the Macroeconomic Imbalance Procedure, 
which was adopted in December 2011 as one of 
the key elements of the legislative package (the 
‘Six-Pack’) to enhance the governance structures 
in EMU, and integrates its results into the 
assessment (see Box 1.7). 
Box (continued) 
The 2022 Alert Mechanism Report (AMR) and In-Depth Reviews (IDR) 
In its latest AMR from November 2021, the Commission concluded that IDRs were warranted for 12 
Member States, which coincided with the ones that had been identified with imbalances or excessive 
imbalances in the previous annual MIP cycle. Three of those Member States are covered in this 
Convergence Report (Croatia, Romania, and Sweden). On the basis of the most recent IDRs, in May 2022, 
the Commission concluded that Croatia is no longer experiencing imbalances while Romania and Sweden 
continue experiencing imbalances (3).  
(3) Communication from the Commission to the European Parliament, the Council, the European Central Bank, the 
European Economic and Social Committee, the Committee of the Regions and the European Investment Bank “2022 
European Semester – Spring Package”, (COM(2022) 600 final). 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 67 –

2. BULGARIA
53 
2.1. LEGAL COMPATIBILITY 
2.1.1. Introduction 
The legal basis for the Bulgarska Narodna Banka 
(BNB – central bank of Bulgaria), the Law on the 
Bulgarian National Bank (the BNB Law) of 1997, 
has been amended since the 2020 Convergence 
Report. Bulgarian authorities have amended the 
BNB Law to remedy certain incompatibilities and 
imperfections highlighted in the Commission's 
2020 Convergence Report (29). In particular, it 
concerns issues flagged in previous convergence 
reports in the section on central bank independence 
and prohibition of monetary financing and 
privileged access. Other issues remain unresolved. 
Therefore, certain comments provided in the 2020 
report are repeated also in this year's assessment. 
2.1.2. Central Bank independence 
The Conflict of Interest Prevention and 
Ascertainment Act of 2008, which regarding the 
possibility to dismiss the Governor of the BNB 
had to be brought in line with Article 14.2 of the 
ESCB/ECB Statute, was fully repealed and 
replaced by the Act on Corruption Counteraction 
and Eviction of Illegally Acquired Property of 
2018 (30). Article 80(1) of the Act on Corruption 
Counteraction and Eviction of Illegally Acquired 
Property was supplemented and now explicitly 
provides that the ascertainment of a conflict of 
interest by an enforceable instrument shall be a 
ground for release from office, unless otherwise 
provided for in the Constitution or the Statute of 
the European System of Central Banks and of the 
European Central Bank. This provision is 
compatible with Article 14.2 of the ESCB/ECB 
Statute. 
Pursuant to Article 12(1) of the BNB Law, the 
Governor shall be elected by the National 
Assembly. The National Assembly has taken the 
view that it has the power to annul or amend its 
decisions, including decisions under Article 12(1) 
of the BNB Law. The National Assembly has 
substantiated this assertion by stating that pursuant 
to a Constitutional Court decision of 26 February 
(29) SG No. 12/2021 12.02.2021 
(30) SG No. 7/19.01.2018. 
1993, the Bulgarian Constitution does not 
explicitly prohibit the National Assembly from 
amending or annulling its decisions. Such 
understanding would allow the dismissal of the 
Governor under conditions other than those 
mentioned in Article 14.2 of the ESCB/ECB 
Statute. It should be ensured that the Governor, 
when properly elected or appointed, may not be 
dismissed under conditions other than those 
mentioned in Article 14.2 of the ESCB/ECB 
Statute. 
Article 13(2) of the BNB Law foresees that the 
Governor of the BNB shall swear an oath before 
the Parliament. The content of the oath laid down 
in paragraph one of the same provision refers inter 
alia to abiding by law and to contribute to the 
performance of the functions of the BNB. Article 
13(1) was amended to provide explicitly that upon 
taking office, the Governor, the Deputy Governors 
and the other three members of the Governing 
Council shall be sworn in to contribute to the 
independent performance of the functions 
entrusted to the Bank. However, the imperfection 
in this provision has only been partially solved. 
Since the Governor, the Deputy Governors and the 
other three members of the Governing Council are 
involved in the performance of ESCB-related 
tasks, any oath should make a clear reference to 
the central bank independence under Article 130 of 
the TFEU. The Governor of the BNB acts in dual 
capacity as a member of BNB’s decision-making 
bodies and of the relevant decision-making bodies 
of the ECB. Article 13 of the BNB Law needs to 
be adapted to reflect the status and the obligations 
and duties of the Governor of the BNB as member 
of the relevant decision-making bodies of the ECB. 
The oath as it stands is an imperfection and should 
be remedied. 
Article 44(1) second sentence of the BNB Law 
refers to the public institutions and bodies not 
having the right to influence the BNB, the 
Governor and the members of the Governing 
Council. The wording should be further improved 
by referring to the wording of Article 130 of the 
TFEU, which states that public authorities may not 
seek to influence the members of national central 
banks’ decision-making bodies. 
Article 3 of the BNB Law providing that ’in the 
formulation of the general outlines of the monetary 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 69 –
European Commission 
Convergence Report 2022 
54 
policy, the BNB and the Council of Ministers shall 
inform each other’ has been repealed. Thus, the 
incompatibility in the area of independence, with 
Article 130 of the TFEU and Article 7 of the 
ESCB/ECB has been solved. 
2.1.3. Prohibition of monetary financing and 
privileged access 
Article 45(1) of the BNB Law provides that the 
BNB shall not extend credits and guarantees, 
including through purchase of debt instruments, to 
the Council of Ministers, municipalities, other 
government and municipal institutions, 
organisations and undertakings in the public 
sector, European Union institutions, bodies, offices 
or agencies, the central government, regional, local 
or other public authorities, other bodies governed 
by public law or public sector entities of EU 
Member States. The list of national entities 
referred to in Article 45(1) is an imperfection and 
should be amended with a view to including the 
national public entities mentioned in Article 123(1) 
of the TFEU and Article 21.1 of the ESCB/ECB 
Statute. 
Article 45(3) of the BNB Law provides that the 
BNB shall not purchase in the primary and 
secondary markets public debt instruments. This 
paragraph is inconsistent with Article 45(1) of the 
BNB Law and with Article 123 of the TFEU given 
the word ‘direct’ refers to the prohibition to 
purchase debt instruments on the primary market 
only. Purchases on the secondary market are not 
prohibited unless they qualify as a circumvention 
of the objective of Article 123 of the TFEU. For 
this reason, the wording ‘and secondary” in Article 
45(3) should be removed. In addition, since the 
first paragraph of Article 45 of the BNB Law 
already covers the prohibition to buy directly debt 
instruments, i.e. on the primary market, the third 
paragraph’s content becomes redundant after 
adjustment. 
Pursuant to Article 45(2) in conjunction with 
Article 33(2) of the BNB Law, Article 45(1) of the 
BNB Law does not apply to the extension of 
credits to state-owned and municipal banks in 
emergency cases of liquidity risk that may affect 
the stability of the banking system. The scope of 
this exemption should be amended to be fully 
consistent with the wording of Article 123(2) of 
the TFEU and Article 21.3 of the ESCB/ECB 
Statute. 
2.1.4. Integration in the ESCB 
Objectives 
The secondary objective of the BNB (Article 2(2) 
of the BNB Law) is compatible with the Treaty on 
the Functioning of the European Union. 
Article 2(1) of the BNB Law correctly reflects that 
the primary objective of the BNB is to maintain 
price stability. However, as from the day that 
Bulgaria adopts the euro, the latter will replace the 
national currency (lev) in accordance with Article 
140 (3) of the TFEU. The reference to the wording 
‘through ensuring the stability of the national 
currency’ will become obsolete as from that day.  
The incompatibilities in the BNB Law are linked 
to the following ESCB/ECB tasks: 
• absence of a general reference to the BNB as
an integral part of the ESCB (Article 1(1) of
the BNB Law) and to its subordination to the
ECB’s legal acts (Articles 16 (1) and (2) and 60
of the BNB Law);
• definition of monetary policy and monetary
functions, operations and instruments of the
ESCB (Articles 2(1) and (3), 16(4) and (5), 28,
29, 30, 31, 32, 33, 35, 38, 41 and 61 of the
BNB Law);
• conduct of foreign exchange operations and the
definition of foreign exchange rate policy
(Articles 20(1), 28, 29, 30, 31, 32 of the BNB
Law);
• right to authorise the issue of banknotes and the
volume of coins (Articles 2(5), 16(9), 24 to 27
of the BNB Law);
• non-recognition of the role of the ECB in the
field of international cooperation (Articles 5,
16(12) and 37(4) of the BNB Law);
• ECB's right to impose sanctions (Article 61, 62
of the BNB Law).
There are also numerous imperfections regarding: 
• non-recognition of the role of the ECB in the
functioning of the payment systems (Articles
2(4) and 40(1) of the BNB Law);
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 70 – 
Convergence Report 2022 - Technical annex 
Chapter 2 - Bulgaria 
55 
• non-recognition of the role of the ECB and the
EU in the collection of statistics (Article 4(1)
and 42 of the BNB Law);
• non-recognition of the role of the ECB and of
the Council in the appointment of the external
auditor (Article 49(4) of the BNB Law);
• absence of an obligation to comply with the
Eurosystem's regime for the financial reporting
of NCB operations (Article 16(11), 46 and 49
of the BNB Law).
Tasks 
2.1.5. Assessment of compatibility 
The Commission welcomes the efforts of 
Bulgarian authorities to remedy the 
incompatibilities and imperfections in comparison 
to its previous 2020 Convergence Report. 
However, the BNB Law is not yet fully compatible 
with Article 131 of the TFEU as regards central 
bank independence, the prohibition of monetary 
financing and the integration in the ESCB at the 
time of euro adoption. 
2.2. PRICE STABILITY 
2.2.1. Respect of the reference value 
The 12-month average inflation rate, which is used 
for the convergence assessment, was above the 
reference value at the time of the last convergence 
assessment of Bulgaria in 2020. It then decreased 
to a low of 0.5% in March 2021, after which it 
increased rapidly throughout the rest of 2021. In 
April 2022, the reference value was 4.9%, 
calculated as the average of the 12-month average 
inflation rates in France, Finland and Greece plus 
1.5 percentage points. The corresponding inflation 
rate in Bulgaria was 5.9%, i.e. 1 percentage point 
above the reference value. The 12-month average 
inflation rate is projected to remain above the 
reference value in the months ahead. 
2.2.2. Recent inflation developments 
The annual HICP inflation rate decreased from 
1.3% in April 2020 to -0.3% in January 2021, then 
increased throughout 2021 and accelerated further 
to 12.1% in April 2022. The decline in the period 
April 2020 to January 2021 was mostly driven by 
deflation in unprocessed food prices and low 
inflation rates in processed food prices. Prices of 
meat and meat products fell after the price hike in 
2019 that was caused by the African swine fever, 
contributing to lower food inflation. The 
acceleration of inflation in 2021 was due to 
contributions from all broad categories. Fuel prices 
had a contribution of 3.5 percentage points to the 
annual inflation in December 2021. Inflation rates 
in Bulgaria have exceeded those of the euro area 
over the past two years. 
Core inflation (measured as HICP inflation 
excluding energy and unprocessed food) was on a 
-2
0
2
4
6
8
10
12
14
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Bulgaria Reference value
Graph 2.1: Bulgaria - Inflation criterion
(percent, 12-month moving average)
Note: The dots at the right end of the chart show the projected reference 
value and 12-month average inflation rate of the country in December 2022.
The reference values for 2016, 2018 and 2020 refer to the reference values 
calculated in the previous Convergence Reports.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Table 2.1: weights  
Bulgaria - Components of inflation (percentage change)1) in total   
2016 2017 2018 2019 2020 2021 Apr-22 2022
HICP -1.3 1.2 2.6 2.5 1.2 2.8 5.9 1000
Non-energy industrial goods -1.6 -1.1 -0.5 0.2 -0.1 0.7 2.3 308
Energy -7.0 5.8 6.4 1.4 -6.1 10.6 20.4 134
Unprocessed food -1.1 5.9 1.3 5.3 5.5 -0.3 7.4 52
Processed food -0.6 0.0 4.3 3.2 2.3 2.0 2.8 233
Services -0.6 0.0 4.3 3.2 2.3 2.0 2.8 273
HICP excl. energy and unproc. food -0.4 0.3 2.1 2.5 2.0 1.9 3.6 814
HICP at constant tax rates -1.5 1.0 2.4 2.4 1.5 3.2 6.0 1000
Administered prices HICP 0.1 1.6 2.2 2.6 1.7 2.4 3.6 175
1) Measured by the arithmetic average of the latest 12 monthly indices relative to the arithmetic average of the 12 monthly indices
in the previous period.
Source: Eurostat, European Commission calculations.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 71 – 
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Convergence Report 2022 
56 
declining path since April 2020, arriving at 0.6% 
in August 2021. It then accelerated sharply as of 
September 2021 and reached 3.9% in December 
2021. Core inflation remained above headline 
inflation for one year from April 2020 onwards 
and was then surpassed by overall HICP inflation 
due to energy price increases. Annual inflation in 
processed food was the most important 
determinant of core inflation dynamics. It 
decelerated from 4.9% in April 2020 to 1.3% in 
March 2021, and then gathered pace as of 
September 2021. The increase in processed food 
prices in Q4-2021 was driven by cost-push factors, 
such as higher prices of energy and agricultural 
production in this period. 
Annual average inflation in services decelerated in 
2020 and 2021. Weaker seasonal demand for 
travel, food and accommodation services in the 
summer exercised a sizable downward pressure on 
services prices in 2020 and 2021. Price weakness 
in the sector of hotels and restaurants was also 
magnified by a downward adjustment in wages 
during the months of lockdown. Price dynamics in 
non-energy industrial goods had a negligible 
influence on overall inflation in 2020 and most of 
2021. Towards the end of 2021, prices in this 
category also started to rise with contributions 
from higher energy and from intermediate input 
costs and import prices. 
2.2.3. Underlying factors and sustainability of 
inflation 
Macroeconomic policy mix and growth 
developments 
Due to the adverse impact of the pandemic, real 
GDP contracted by 4.4% in 2020, and then 
recovered by 4.2% in 2021. Across demand 
components, economic activity in 2020 contracted 
mostly due to lower external demand and reduced 
private investment and consumption. Exports of 
goods rebounded quickly already in Q3-2020, 
while exports of services remained subdued also in 
2021. Aggregate investment remained largely 
unchanged in 2020, despite the impulse from 
public investment, and then registered a sizable 
decline of 11% in 2021. The contraction in capital 
-4
-2
0
2
4
6
8
10
12
14
2016 2017 2018 2019 2020 2021
Bulgaria Euro area
Graph 2.2: Bulgaria - HICP inflation
(y-o-y percentage change)
Source: Eurostat.
Table 2.2:
Bulgaria - Other inflation and cost indicators (annual percentage change)
2016 2017 2018 2019 2020 2021 20221) 20231)
HICP inflation
Bulgaria -1.3 1.2 2.6 2.5 1.2 2.8 11.9 5.0
Euro area 0.2 1.5 1.8 1.2 0.3 2.6 6.1 2.7
Private consumption deflator
Bulgaria 1.7 4.6 2.4 2.0 -0.6 3.6 11.9 4.7
Euro area 0.4 1.3 1.5 1.1 0.5 2.3 5.8 2.7
Nominal compensation per employee
Bulgaria 5.8 10.5 9.7 6.9 7.2 9.5 9.7 7.7
Euro area 1.2 1.7 2.1 2.1 -0.7 4.1 3.6 3.5
Labour productivity
Bulgaria 2.5 1.0 2.8 3.7 -2.1 4.0 1.9 2.7
Euro area 0.4 1.0 0.2 0.3 -4.9 4.2 1.4 1.5
Nominal unit labour costs
Bulgaria 3.2 9.5 6.7 3.1 9.5 5.4 7.7 4.8
Euro area 0.8 0.7 2.0 1.9 4.4 0.0 2.2 2.0
Imports of goods deflator
Bulgaria -6.0 7.5 2.2 -0.1 -6.0 15.0 11.9 4.3
Euro area -3.3 3.3 2.6 -0.5 -3.8 9.6 13.2 0.8
1) Commission Spring 2022 Economic Forecast.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 72 –
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Chapter 2 - Bulgaria 
57 
formation in 2021 was driven by high uncertainty, 
combined with reduced business activity in the 
sectors most affected by the pandemic. In Q2-
2020, private consumption contracted sharply by 
3.2% quarter-on-quarter with the introduction of 
social distancing measures in March 2020, and 
then swiftly regained ground in Q3-2020. The 
social distancing measures subsequently 
introduced in late 2020 and in 2021 were less strict 
and more selective. Combined with the businesses 
adjusting to operate in the new environment (e.g. 
introducing home delivery), this largely avoided 
repeated demand slumps. In 2021, private 
consumption expanded strongly by 8%, 
underpinned by positive wage dynamics, limited 
job losses, due to the swift introduction of job 
retention schemes, supported by the SURE 
instrument and REACT-EU, and relatively 
optimistic expectations about economic activity. 
According to the Commission’s Spring 2022 
Economic Forecast, economic growth is forecast to 
slow down to 2.1% in 2022, due to both slower 
expansion in domestic and external demand. GDP 
is then forecast to grow by 3.1% in 2023. In 
response to increased energy and other input costs 
and general high uncertainty, firms are set to 
postpone investments and new hires. The slump in 
private investment is forecast to be fully 
compensated by public investments, supported by 
the Recovery and Resilience Plan. The decreased 
hiring intensity is expected to lead to a stabilisation 
of the unemployment rate slightly below 5%. 
Private consumption growth is expected to 
decelerate markedly to 2.8% in 2022 and then 
increase marginally to 3% in 2023. The relative 
slow-down in consumer spending is linked to the 
expected strong price increases in 2022, which are 
set to erode real disposable income. The output 
gap is projected to narrow, but remain negative in 
2022 and then turn slightly positive in 2023. 
In 2021, the fiscal stance (31) remained supportive 
at the same level as in 2020 (-0.6% of GDP), based 
on the Commission’s Spring 2022 Economic 
Forecast. The fiscal stance is expected to become 
(31) The fiscal stance is measured as the change in primary
expenditure (net of discretionary revenue measures),
excluding Covid-19 crisis-related temporary emergency
measures but including expenditure financed by
nonrepayable support (grants) from the Recovery and
Resilience Facility and other EU funds, relative to
mediumterm potential growth. A negative (positive) sign of the
indicator corresponds to an excess (shortfall) of primary
expenditure growth compared with medium-term economic
growth, indicating an expansionary (contractionary) fiscal
policy.
even more supportive in 2022 (-3.4% of GDP) due 
to the expenditures financed through the Recovery 
and Resilience Fund and other EU grants and 
temporary support to mitigate the impact of high 
energy prices on vulnerable households and firms 
(around 0.3% of GDP (32)). The budgetary costs 
related to people fleeing the war in Ukraine is 
assumed at 0.11% of GDP. The no policy-change 
forecast for 2023 shows a further supportive stance 
(-1.3% of GDP) thanks to the increasing 
expenditure financed by Recovery and Resilience 
Fund and other EU grants, despite the assumed 
phasing out of energy crisis measures. 
The BNB pursues its primary objective of price 
stability through an exchange rate anchor in the 
context of a currency board arrangement (CBA) 
with the lev pegged to the euro. The CBA serves 
as a key macroeconomic policy anchor. During the 
COVID-19 crisis, the sound public finances and a 
stable banking sector combined with the exchange 
rate stability, ensured by the currency board, 
allowed Bulgaria to finance itself at favourable 
interest rates. In March 2020, the Bulgarian 
National Bank introduced a package of measures 
in response to the COVID-19 crisis, amounting to 
BGN 9.3 billion to preserve the stability and 
improve the flexibility of the banking system. 
These measures included reducing the commercial 
banks’ foreign exposure by BGN 7 billion and full 
capitalisation of profits for BGN 1.6 billion, and 
both were discontinued at the beginning of 2022. 
In April 2020, the BNB approved a non-legislative 
moratorium on loan repayments, in line with the 
Guidelines of the European Banking Authority 
(EBA/GL/2020/02) until end-2020. This measure 
expired at the end of 2021, with a total of BGN 8.1 
billion of loans deferred under the arrangement. 
The central bank also agreed with the ECB in 
April 2020 to set up a precautionary currency 
agreement (swap line) to provide euro liquidity up 
to EUR 2 billion until end-2020. Given the 
uncertain economic outlook, the risks to the
debtservice capacity of borrowers, and the quality of 
banks’ assets, the BNB decided in March 2022 to 
respond to the continued strong lending activity in 
the house-loan segment by increasing the 
countercyclical capital buffer rate applicable to 
domestic credit risk exposures from 0.5% to 1.0% 
from October 2022 and to 1.5% in effect from the 
beginning of 2023. 
(32) In incremental terms. The level amount is around 0.9% of
GDP in 2022. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 73 –
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58 
Wages and labour costs 
At the onset of the COVID-19 pandemic 
employment quickly adjusted downwards in the 
sectors most affected by the domestic and external 
demand slump — manufacturing, trade, transport, 
hotels and restaurants and other services. 
Nevertheless, the number of persons employed fell 
by less compared to the economic activity in these 
sectors. On aggregate, gross value added declined 
by 6.6% quarter-on-quarter in Q2-2020, while the 
number of persons employed fell by 2.2% in the 
same period. Further job losses in the subsequent 
periods were prevented by the quick rebound in 
manufacturing production, the relaxation of 
containment measures and swift introduction of 
subsidised short-time work schemes. The recovery 
in employment levels continued in 2021 across all 
sectors. On average for 2020, the number of 
employed dropped by 2.3% and then grew by 0.2% 
in 2021. Nominal compensation per employee in 
the most affected sectors contracted sizably in Q2-
2020, reflecting to a large extent the reduction in 
hours worked (33). In the following periods 
aggregate wage growth resumed its upward trend, 
in line with the stabilisation and partial recovery of 
the labour market situation. On aggregate, 
compensation per employee grew by 7.2% in 2020 
and 9.5% in 2021, broadly in line with the
precrisis trend. 
Labour productivity dropped by 4.5% in Q2-2020 
as a result of labour hoarding in the sectors most 
affected by the COVID-19 crisis. It then recovered 
to pre-pandemic levels at the beginning of 2021. 
Overall, aggregate labour productivity declined by 
2.1% in 2020 and then rebounded by 4% in 2021. 
The aggregate numbers, however, obscure 
diverging trends. Productivity in manufacturing 
exhibited a strong rebound already in 2020, while 
in the retail and wholesale trade, catering and 
accommodation services productivity is still on a 
declining path. The dynamics in nominal unit 
labour cost (ULC) have been strongly influenced 
by fluctuations in labour productivity. Wages 
resumed their steady growth after the contraction 
at the onset of the COVID-19 crisis in Q2-2020, 
which was driven by wage cuts in the private 
sector. In particular, nominal ULC went up by 
5.8% quarter-on-quarter in Q2-2020 and then 
(33) While the job retention schemes were introduced fairly
swiftly at the onset of the spring 2020 lockdown, they were
arguably less generous than in other EU countries. With
time the scope and coverage has widened. This evolution
can largely explain the less distorted figures for Bulgaria at
the beginning of the crisis. 
returned to trend growth rates, typical for the
precrisis period. On average, ULC increased by 9.5% 
in 2020 and then by 5.4% in 2021. According to 
the Commission’s Spring 2022 Economic 
Forecast, ULC is expected to increase by 7.7% in 
2022 and 4.8% in 2023. 
External factors 
Given the high import component of aggregate 
demand, imported inflation plays an important role 
in domestic price formation. Import prices of 
mineral fuels, food and other manufactured goods 
and materials are particularly relevant for inflation 
in Bulgaria. Since mid-2021, the prices for 
electricity on the unregulated domestic market 
have increased four-fold, following the regional 
and global price increase. In 2021, the domestic 
‘Day ahead’ market became more tightly linked to 
the EU electricity market, as its trading platform 
was integrated with the ones in Greece and 
Romania. 
The lev’s nominal effective exchange rate, which 
is determined by the price of the lev vis-à-vis the 
currencies of 36 major trade partners, appreciated 
by 2.8% in 2020 and 2.7% in 2021. The 
appreciation at the end of 2021 was strongly 
influenced by the depreciation of the Turkish lira 
against the euro. Turkey is the most important 
trading partner for Bulgaria outside the EU, 
accounting for 6.1% of total exports and 7.8% of 
total imports in 2021. 
Administered prices and taxes 
The share of administered prices in the HICP 
basket is relatively high at around 17%, compared 
to 13% in the euro area. Regulated prices of 
electricity, heat and water follow a seasonal 
pattern, as they are usually updated at the 
-3
0
3
6
9
12
15
2016 2017 2018 2019 2020 2021 2022 2023
Productivity (real GDP per person employed)
Nominal compensation per employee
Nominal unit labour costs
HICP inflation
(y-o-y % change)
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Graph 2.3: Bulgaria - Inflation, productivity and wage trends
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 74 –
Convergence Report 2022 - Technical annex 
Chapter 2 - Bulgaria 
59 
beginning of the year or in the summer months. 
Administered price inflation accelerated from 
1.7% in 2020 to 2.4% in 2021 on the back of 
increasing energy prices. The National Assembly 
imposed a moratorium on future increases in the 
price for electricity, central heating and water 
supply in December 2021. The moratorium 
expired at the end of March 2022. Meanwhile, the 
government introduced support programmes for 
firms, public utilities and household gas 
consumers. Without the moratorium, the energy 
regulator had envisaged a 12% increase in the 
electricity price. Administered price inflation 
surpassed overall HICP in 2020 and then went 
below headline consumer price inflation in 2021. 
Changes in indirect taxes had a negative effect on 
inflation in 2020 and 2021. As a response to the 
pandemic and the containment measures, VAT on 
hotels, restaurants and other tourist services, as 
well as the sale of books and other items was 
temporarily reduced as of mid-2020. Annual 
constant-tax HICP was thus 0.3 of a percentage 
point and 0.4 of a percentage point above headline 
inflation in 2020 and 2021, respectively. The 
measures were still in place in 2021, which 
explains the persistence in the inflation differential 
in 2021 through the carry-over effect from 2020. 
In the euro area, annual constant-tax HICP also 
exceeded the headline inflation by 0.3 of a 
percentage point in 2020, but then fell below 
overall inflation by -0.2 of a percentage point in 
2021. 
Medium-term prospects 
Looking forward, annual HICP inflation is 
expected to accelerate significantly in 2022 on the 
back of persistently high costs of energy and other 
intermediate products, expected increases in 
regulated gas and heating prices, as well as higher 
international food prices and growing import 
deflators. In 2023, inflation is forecast to abate 
relative to the previous year, but to remain 
somewhat elevated at 5.0%, due to the lagged 
indirect effect of high energy cost on final goods 
and services prices. In the context of the weaker 
expected labour market pressures, the
secondround effects via a wage-price spiral are projected 
to be limited. 
In parallel to the introduction of the moratorium on 
prices of utilities between 15 December 2021 and 
31 March 2022, the government introduced 
support programmes for firms, public utilities 
suppliers and household gas consumers that have 
so far mitigated the impact of sharp increases in 
energy prices. The discontinuation of natural gas 
supplies by Gazprom in late April is expected to be 
compensated through alternative sources, leading 
to a one-off increase in gas prices.  
The level of consumer prices in Bulgaria stood at 
about 55% of the euro area average in 2020. This 
suggests that there is a significant potential for 
price level convergence in the long term, as GDP 
per capita in PPS (about 55% of the euro-area 
average in 2021) increases towards the euro-area 
average. 
Medium-term inflation prospects will depend on 
wage and productivity developments as well as on 
the functioning of product and services markets. 
These developments may be substantially affected 
by the cyclical position of the economy. The 
sizable inflows of EU funds, including the RRF 
funding, could bring the economic output above 
potential. In that context, an important aspect to 
minimise the overheating pressures and maximise 
long-term productivity gains is ensuring that public 
investments effectively expand the production 
capacity of the economy in the medium term. This 
could be done via investments in physical and 
human capital and reforms to improve the 
functioning of product and labour markets, so that 
demand increase is matched by positive supply 
side reactions. 
2.3. PUBLIC FINANCES 
2.3.1. Recent fiscal developments 
After a period of budget surpluses, the general 
government balances recorded deficits of 4.0% and 
4.1% of GDP in 2020 and 2021, respectively, as 
the Bulgarian government took measures to 
respond to the pandemic-induced shock. Measures 
like those raising or preserving remuneration in the 
public and private sector sustained income taxes 
and revenues from social contributions. However, 
the reduced economic activity led to a decline in 
receipts from taxes on production and imports, 
while sales starkly declined too. As a result, total 
revenue decreased by around 1.3% and by 0.3 
percentage points as a percentage of GDP. By 
contrast, the expenditure-to-GDP ratio increased 
by 5.7 percentage points during the same period as 
the government introduced emergency measures 
like higher wage bonuses for medical staff, 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 75 – 
European Commission 
Convergence Report 2022 
60 
subsidies to corporations, pension top-ups and the 
purchase of medical equipment. In 2021, revenues 
largely recovered, thanks to higher receipts from 
higher taxes on production and imports, income 
and wealth taxes, and the upswing in sales. 
Overall, total public revenue as a percentage of 
GDP increased by 0.9 of a percentage point from 
2020 to 2021, slightly lowered by the recovery of 
GDP. Emergency measures remained largely in 
place, leading to a further 1.1 percentage point in 
the expenditure-to-GDP ratio. 
Bulgaria entered the crisis with a strong fiscal 
position, as reflected by budget surpluses in 
previous years and a low debt-to-GDP ratio of 
20% in 2019. The primary deficits in 2020 and 
2021 translated into a rising debt-to-GDP ratio, 
reaching 25.1% in 2021, which had already 
increased to 24.7% in 2020. A positive snowball 
effect of 0.6% of GDP on gross public debt 
contributed to the rise in 2020. However, given 
Bulgaria’s strong commitment towards sound 
fiscal policy, a negatively turning interest
rategrowth differential and the expected gradual 
phase-out of emergency measures, the government 
debt-to-GDP ratio is set to stay below 26% in the 
medium-term. 
2.3.2. Medium-term prospects 
The elections held at the end of 2021, and the 
subsequent protracted government formation, 
delayed the usual adoption of the 2022 budget, 
which the National Assembly adopted on 25 
February 2022. The budget includes, among 
others, the gradual increase in the excise duty on 
tobacco and toll taxes, increases in the minimum 
wage, and changes in pension policy parameters. 
While initially Bulgaria’s budget balance was 
expected to largely improve due to the gradual 
phasing-out of pandemic-related measures from 
4.3% in 2021 to 1.8% of GDP in 2022, the 
worsened economic outlook due to Russia’s 
invasion of Ukraine and rising energy costs 
impede the deficit recovery. Key emergency 
support measures that remain in place to fight the 
pandemic include the provision of vaccines and 
medical products, pension top-ups, and business 
support schemes. As a consequence of Russia’s 
invasion of Ukraine, the Bulgarian government has 
introduced new measures like the evacuations of 
Bulgarian nationals residing in Ukraine and the 
provision of humanitarian aid (e.g. providing 
accommodation and daily allowances for up to 
three months upon arrival) to Ukrainian refugees 
arriving in Bulgaria. According to Commission 
estimations, the related total costs of the flow of 
refugees, due to the Russian military aggression in 
Ukraine, amount to 0.11% and 0.16% of GDP in 
2022 and 2023. 
On 29 April 2022, Bulgaria submitted its 2022 
Convergence Programme. According to the 
Programme, the headline deficit is projected to 
increase to 5.3% of GDP in 2022 and 2.9% in 
2023. 
Table 2.3:
Bulgaria - Budgetary developments and projections (as % of GDP unless indicated otherwise)
Outturn and forecast 1) 2016 2017 2018 2019 2020 2021 20221) 20231)
General government balance 0.3 1.6 1.7 2.1 -4.0 -4.1 -3.7 -2.4
- Total revenue 35.1 37.1 38.7 38.4 38.1 39.0 40.2 40.7
- Total expenditure 34.8 35.4 37.0 36.3 42.0 43.1 43.9 43.1
of which:
- Interest expenditure 0.9 0.8 0.7 0.6 0.5 0.5 0.5 0.5
p.m.: Tax burden 29.2 29.8 29.7 30.3 30.6 32.4 32.6 33.1
Primary balance 1.2 2.4 2.4 2.7 -3.5 -3.6 -3.1 -1.9
Fiscal stance 2) -0.6 -0.6 -3.4 -1.3
Government gross debt 29.1 25.1 22.1 20.0 24.7 25.1 25.3 25.6
p.m: Real GDP growth (%) 3.0 2.8 2.7 4.0 -4.4 4.2 2.1 3.1
1) Commission’s Spring 2022 Economic Forecast.
2) A negative (positive) sign of the indicator corresponds to an excess (shortfall) of primary expenditure growth
compared with medium-term economic growth, indicating an expansionary (contractionary) fiscal policy.
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 76 –
Convergence Report 2022 - Technical annex 
Chapter 2 - Bulgaria 
61 
The Commission’s Spring 2022 Economic 
Forecast, which is based on a no-policy change 
assumption, forecasts a general government deficit 
of around 3.7% of GDP in 2022. The projected 
government deficit is lower than the planned 
deficit in the Convergence Programme due to 
different underlying macroeconomic assumptions, 
including the inflow of people fleeing the war in 
Ukraine and the associated costs, higher growth in 
revenues from taxes on production and imports as 
well as a smaller increase in intermediate 
consumption. The Commission projects the 
general government deficit to further decrease to 
around 2.4% of GDP in 2023, as the costs of both 
COVID-19 and energy price measures are set to 
phase out. 
In 2022, the fiscal stance is projected in the 
Commission’s Spring 2022 Economic Forecast to 
continue to be supportive, at -3.4% of GDP (34). 
The positive contribution to economic activity of 
expenditure financed by the Recovery and 
Resilience Facility grants and other EU funds is 
projected to increase by1.1 percentage points of 
GDP in 2022, compared to 2021. Nationally 
financed investment is projected to provide as well 
an expansionary contribution to the fiscal stance in 
2022 by 1.1 percentage points of GDP. At the 
same time, the growth in nationally financed 
primary current expenditure (net of discretionary 
revenue measures) in 2022 is projected to provide 
an expansionary contribution of -1.4 percentage 
points to the overall fiscal stance, as current 
expenditure is set to grow at a faster pace than 
medium-term potential growth. However, some of 
this expansion is due to measures related to the 
energy crisis (-0.2 of a percentage point) and the 
assistance to those fleeing Ukraine (-0.1 of a 
percentage point). In 2023, the fiscal stance is 
projected at -1.3% of GDP. The additional positive 
contribution to economic activity of expenditure 
financed by Recovery and Resilience Facility 
grants and other EU funds is projected to increase 
by 0.7 of a percentage point of GDP, compared to 
2022. Nationally financed investment is projected 
to be expansionary too by 0.2 percentage points of 
GDP (35). The growth in nationally financed 
primary current expenditure is projected to provide 
an expansionary contribution of -0.5 of a 
percentage point to the overall fiscal stance in 
2023. This includes the impact from the phasing 
(34) For a definition of the fiscal stance used in this report, see
footnote in Section 2.2.3 on underlying factors and
sustainability of inflation. 
(35) Other nationally financed capital expenditure is projected
to provide a neutral contribution. 
out of the measures addressing the increased 
energy prices (0.82% of GDP). 
The deficit is set to fall below the Treaty threshold 
of 3% in 2023. While the global economic outlook 
remains uncertain, the positive impact of 
investments financed through the Recovery and 
Resilience Fund, as well as the continued phasing 
out of COVID-19 and energy price measures, 
improve the deficit to 2.4% of GDP. The 
government debt-to-GDP ratio is forecast to 
increase slightly to 25.6% due to the persistent 
primary deficits, but cushioned by economic 
growth. 
Debt sustainability risks appear medium over the 
medium term. Government debt is projected to 
increase, reaching around 37% of GDP in 2032. 
This projection assumes that the structural primary 
balance remains constant (except for the impact of 
ageing) at the forecast level for 2023 of -2.2% of 
GDP, hence below the 2019 level.  
The sensitivity to possible macro-fiscal shocks 
contributes to this assessment. While Bulgaria’s 
debt is projected to stay at a low level by 2032 
under all deterministic scenarios, the stochastic 
projections point to a particularly large degree of 
uncertainty. 
Several factors mitigate risks, including the 
lengthening of debt maturity in recent years 
historically low borrowing costs and the expected 
positive impact on long-term growth of reforms 
under the Recovery and Resilience Plan.
Riskincreasing factors include Bulgaria’s negative net 
international investment position, the substantial 
share of public debt in foreign currency and 
contingent liability risks stemming from the poor 
-4
-3
-2
-1
0
1
2020 2021 2022 2023
Net nationally financed  primary current expenditure Nationally financed investment
Other capital expenditure Expenditure financed by RRF grants and EU funds
Fiscal stance
Expansionary
Contractionary
Source: Commission's Spring 2022 Economic Forecast.
Graph 2.4: Bulgaria - Fiscal stance and its components
(percent of GDP)
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 77 –
European Commission 
Convergence Report 2022 
62 
financial performance of some state-owned 
enterprises (36). 
Bulgaria has developed a strong institutional 
setting. According to the Commission’s Fiscal 
Governance Database, with nine national fiscal 
rules in place at the general and subnational level, 
Bulgaria has the highest number of fiscal 
constraints in the EU, while also showing an 
improving track-record of compliance. The rules 
system, however, appears complex, not least 
because of using different accounting standards 
(both Maastricht-based and cash-based), which 
raises the need to streamline the process. In 2020, 
Bulgaria added additional flexibility in the form of 
escape clauses to four rules targeting the general 
government to enable the necessary fiscal 
adjustments in the face of the COVID shock 
(according to the Commission’s Fiscal Governance 
Database). Based on its broad remit, the Fiscal 
Council has gradually established a system for 
releasing its mandatory monitoring reports on the 
annual and medium-term fiscal plans and 
compliance with all the numerical rules laid down 
in the Public Finance Act. However, issues remain 
with respect to the management and planning of 
the government finances. The Ministry of Finance 
does not always seem to have enough information 
for the purposes of budgetary planning on the 
detailed content of major public expenditures. This 
together with the failure to produce fiscal 
projections in terms of the European System of 
National and Regional Accounts (ESA), and a 
systematic underestimation of budget projections 
raise the need to strengthen the capacity of the 
administration to plan, forecast and report on the 
general government budget in both accrual (ESA) 
and cash terms. 
2.4. EXCHANGE RATE STABILITY 
The Bulgarian lev joined the ERM II on 10 July 
2020 and in parallel, the Bulgarian National Bank 
entered into a close cooperation with the ECB. 
After joining, Bulgaria committed to pursue a set 
of policy measures, the so-called post-entry 
commitments, to ensure that their participation in 
the mechanism is sustainable and achieves a high 
degree of economic convergence ahead of the euro 
adoption. The measures cover four policy areas: 
the non-banking financial sector, the insolvency 
framework, the anti-money laundering framework, 
(36) For further details see the 2021 Fiscal Sustainability
Report. 
and governance of state-owned enterprises. 
Bulgaria is currently working towards the 
completion of these post-commitments, in close 
liaison with the Commission, who monitors their 
progress. 
Bulgaria introduced its CBA on 1 July 1997, 
pegging the Bulgarian lev to the German mark and 
subsequently to the euro (at an exchange rate of 
1.95583 BGN/EUR). Under the CBA, the BNB 
has to cover its monetary liabilities with foreign 
reserves fully. The BNB is obliged to exchange 
monetary liabilities and euro at the official 
exchange rate without any limit. 
Bulgaria's international reserves increased to 
around EUR 35 billion by the end of 2021, after 
having increased from EUR 25 billion at the 
beginning of 2020 to around EUR 31 billion at the 
end of the same year. International reserves 
increased in the course of 2021 mainly because of 
positive net currency inflows. The  transfers of EU 
funds and the BNB’s net purchases of reserve 
currency from commercial banks account for most 
of the inflows. With the further increase in 
international reserves in 2021, their share as a 
percentage of GDP also increased to 51% from 
around 50% at the end of 2020. 
The BNB does not set monetary policy interest 
rates. The monetary policy of the euro area affects 
the domestic interest rate environment directly 
through the operation of Bulgaria's CBA. The 
BNB discontinued the production of short-term 
reference rates (e.g. SOFIBOR) as of 1 July 2018. 
Instead, the central bank publishes a base interest 
rate (BIR) based on the index LEONIA Plus (LEv 
OverNight Interest Average Plus), which is a 
reference rate of concluded and effected overnight 
deposit transactions in Bulgarian levs on the 
interbank market in Bulgaria. In June 2020, the 
BIR stood at -0.7%. Since then it has been very 
1.8
1.9
2.0
2.1
2016 2017 2018 2019 2020 2021
Graph 2.5: Bulgaria - BGN/EUR exchange rate
(monthly averages)
Source: ECB.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 78 –
Convergence Report 2022 - Technical annex 
Chapter 2 - Bulgaria 
63 
stable until the end of 2021, when the BIR 
exhibited more volatility. After an increase to -
0.45% in December, it fell back to -0.6% in 
February 2022. As a result, beside the short 
increase at the beginning of the year, the interest 
rate differential of the BIR to the 1-month Euribor 
rate has remained relatively stable at around -7 
basis points in March 2022. 
    
2.5. LONG-TERM INTEREST RATES 
Long-term interest rates used for the convergence 
examination reflect the secondary market yield on 
a single benchmark Bulgarian government bond 
with a residual maturity of around 10 years. 
    
The Bulgarian 12-month moving average
longterm interest rate relevant for the assessment of the 
Treaty criterion was below the reference value in 
the 2020 convergence assessment of Bulgaria. 
Since then the interest rates has been very low and 
very stable. It stood at 0.3% at the end of 2020 and 
edged down to 0.2% by the end of 2021. In April 
2022, the reference value, given by the average of 
long-term interest rates in France, Finland and 
Greece plus 2 percentage points, stood at 2.6%. At 
the same time, the 12-month moving average of 
the yield on the Bulgarian benchmark bond stood 
at 0.5%, i.e. 2.1 percentage points below the 
reference value. 
The Bulgarian long-term interest rate has been 
very low and rather stable since the beginning of 
2020, remaining within a band of 0.1-0.4%. There 
was only a brief peak in June-July, 2020, when the 
interest rate increased to 0.7%. The low long-term 
interest rates reflect the loose monetary policy in 
the euro area. The spread to German long-term 
benchmark rates has also remained broadly stable 
within a band of 0.4-0.8 of a basis point, with a 
brief episode above 100 basis points in mid-2020. 
At the beginning of 2022, Bulgarian long-term 
interest rate started to increase and reached 1.6% 
in April. The German long-term interest rate also 
increased, but by a slightly smaller amount, 
resulting in the spread breaking through the
abovementioned bounds to 0.9 of a basis point. 
    
2.6. ADDITIONAL FACTORS 
The Treaty (Article 140 TFEU) calls for an 
examination of other factors relevant to economic 
integration and convergence that the Commission 
should take into account in its assessment. The 
assessment of the additional factors — including 
balance of payments developments, as well as 
product, labour and financial market integration — 
gives an indication of a Member State's ability to 
integrate into the euro area without difficulties. 
In November 2021, the Commission published its 
last Alert Mechanism Report (AMR 2022) under 
the Macroeconomic Imbalance Procedure (MIP – 
see also Box 1.7), which concluded that it was not 
necessary to carry out further in-depth analysis in 
the context of the MIP. In the past, vulnerabilities 
-30
-20
-10
0
10
20
30
40
50
2016 2017 2018 2019 2020 2021
Graph 2.6: Bulgaria - Annual effective interest rate spread to 1-M Euribor
(basis points, monthly values)
Source: Eurostat and National Bank of Bulgaria.
0
2
4
6
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Bulgaria Reference value
Graph 2.7: Bulgaria - Long-term interest rate criterion
(percent, 12-month moving average)
Source: European Commission.
-2
0
2
4
2016 2017 2018 2019 2020 2021
Bulgaria Germany
Graph 2.8: Bulgaria - Long-term interest rates
(percent, monthly values)
Source: Eurostat.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 79 – 
European Commission 
Convergence Report 2022 
64 
in the financial sector were coupled with high 
indebtedness and non-performing loans in the 
corporate sector. Consistent policy action and a 
favourable macroeconomic environment have 
reduced risks and vulnerabilities before the onset 
of the COVID-19 crisis. Taking into account the 
assessment in its 2020 In-Depth Review, the 
Commission concluded that Bulgaria was 
experiencing no imbalances. Notwithstanding the 
progress made, non-performing loans are still 
relatively high albeit declining in the segment of 
corporate loans granted by domestically owned 
banks. 
Increased vulnerabilities in the housing market 
stem from the higher, although still contained, risk 
for overvaluation. House prices accelerated to a 
growth rate of 8.7% in 2021. In parallel, mortgage 
growth increased rapidly to 16.5% in 2021, while 
as a percentage of GDP, mortgages remain low 
compared to the euro area. The European Systemic 
Risk Board has issued a warning to Bulgaria in 
February 2022 to address these risks, as it 
considers macroprudential polices only partially 
appropriate and sufficient. Based on similar 
concerns, the Bulgarian National Bank increased 
the countercyclical capital buffer in March 2022, 
from 0.5% to 1% as of 1 October 2022, and 1.5% 
in effect from the beginning of 2023. 
Bulgaria submitted its recovery and resilience plan 
on 15 October 2021. The Commission’s positive 
assessment on 7 April 2022 and the Council’s 
approval on 4 May, paved the way for the 
implementation of the Recovery and Resilience 
Plan and the disbursement of EUR 6.3 billion in 
grants (37) over the period 2022-2026, which is 
equivalent to 10.2% in 2019 GDP. 
Bulgaria’s plan includes an extensive set of 
mutually reinforcing reforms and investments (56 
investments and 47 reforms) that contribute to 
effectively addressing all or a significant subset of 
the economic and social challenges outlined in the 
country-specific recommendations addressed to 
Bulgaria by the Council in the European Semester 
in 2019 and 2020. 
The plan will address key macro-economic 
challenges such as social inclusion, education and 
skills, healthcare, decarbonisation and digital 
(37) The maximum financial contribution for Bulgaria in
ANNEX IV of Regulation (EU) 2021/241 is determined at
EUR 6.3 billion, but 30% of the total amount available
shall be recalculated with actual data by 30 June 2022.. 
transition and business environment. Key 
investments are included in renewable energy 
production, electricity storage and interconnection 
capacities, energy efficiency of buildings and in 
the digitalisation of public administration and 
digital skills. Key reforms include the introduction 
of a framework for coal phase-out, the 
liberalisation of the electricity market, a 
comprehensive educational reform, and a 
strengthening of the minimum income scheme. A 
significant number of reforms and investments are 
expected to reinforce the institutional framework. 
These include reforms to improve the functioning 
of the judiciary system and the anti-corruption 
bodies, to strengthen anti-money laundering and 
insolvency frameworks, public procurement, 
whistle-blower protection, regulation of lobbying, 
e-government and integrity of public servants.
The plan devotes 58.9% of its total allocation to 
measures supporting climate objectives and 25.8% 
to the digital transition, all while respecting the do 
no significant harm principle. 
The implementation of the investments in the 
Bulgarian plan, along with other investments under 
NextGenerationEU, is estimated to raise Bulgaria’s 
GDP by 1.9% to 2.9% by 2026, of which 0.6% due 
to the positive spillover effects of the coordinated 
implementation of NextGenerationEU across 
Member States (Pfeiffer et al. 2021) (38). This does 
not take into account the positive impact of 
structural reforms on growth. 
2.6.1. Developments of the balance of 
payments 
Bulgaria’s external balance (i.e. the combined 
current and capital accounts) shrank, but remained 
positive at 1.5% and 0.3% of GDP in 2020 and 
2021, respectively. The reduction was driven by 
the current account, which turned slightly negative 
in 2020 and 2021, from a surplus of 1.9% in 2019. 
Secondary income, which largely consists of 
remittances from abroad, fell roughly by 50% in 
2020 and 2021 possibly due to the worsened 
economic situation of nationals residing abroad. In 
addition to the deterioration of the secondary 
income balance, the deterioration of the external 
position in 2020 was also caused by an abrupt 
(38) See Pfeiffer P., Varga J. and in ’t Veld J. (2021),
“Quantifying Spillovers of NGEU investment”, European
Economy Discussion Papers, No. 144 and Afman et al.
(2021), “An overview of the economics of the Recovery
and Resilience Facility”, Quarterly Report on the Euro
Area (QREA), Vol. 20, No. 3 pp. 7-16. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 80 –
Convergence Report 2022 - Technical annex 
Chapter 2 - Bulgaria 
65 
contraction in exports of services, reflecting the 
imposed travel restrictions and the weaker external 
demand for tourist services. The trade balance 
became less negative than in the preceding years, 
as nominal imports contracted more than nominal 
exports on account of positive terms of trade 
effects. The higher share of mineral fuels in 
imports than in exports, combined with the 31% 
oil price drop in 2020, partially explains these 
terms of trade gains. In 2021, the external balance 
of services improved, but remained below 2019 
levels as a share of GDP, as the recovery in 
tourism revenues was incomplete. The balance of 
goods deteriorated in 2021 as imports of goods 
increased faster than exports of goods. The 
recovery in economic activity and private 
consumption spurred growth in imports of 
intermediate, investment and consumer goods. 
Exports of goods also grew strongly in 2021 and 
benefitted from further gains in terms of trade. The 
capital account remained in surplus. 
The financial account, net of official reserves, 
deteriorated in 2020 and then improved in 2021. In 
March 2020, as part of a package of measures to 
preserve the stability of the banking system at the 
onset of the COVID-19 pandemic, the Bulgarian 
National Bank imposed a limit on commercial 
banks’ foreign exposures. These measures to 
increase the liquidity in the banking system 
resulted in a simultaneous net outflow of other 
investments and an increase in official reserves at 
the central bank. In 2021, the banking sector 
maintained high liquidity and capital adequacy 
ratios and improved profitability. This positive 
development led to renewed investment in other 
assets abroad by the foreign-owned banks, while 
official reserves kept growing, albeit less strongly. 
The net inflow of Foreign Direct Investment (FDI) 
remained positive with positive contributions from 
debt instruments in 2020 and from reinvested 
earnings in 2020 and 2021. 
The negative net international investment position 
continued to shrink rapidly in 2020-2021. Net 
external liabilities consist mostly of FDI equity, 
which have been relatively stable as a share of 
GDP after the crisis of 2009. 
In 2020-2021, measures of competitiveness 
exhibited different dynamics depending on the 
deflator used. The rate of appreciation of the real 
effective exchange rate (REER) deflated by ULC, 
accelerated, as labour hoarding pushed up labour 
 
 
      
 
 
Table 2.4:
Bulgaria - Balance of payments (percentage of GDP)
2016 2017 2018 2019 2020 2021
Current account 3.1 3.3 0.9 1.9 -0.1 -0.4
of which: Balance of trade in goods -2.0 -1.5 -4.8 -4.7 -3.2 -4.9
                 Balance of trade in services 7.0 5.8 7.3 8.0 5.0 6.6
                 Primary income balance -5.0 -4.3 -4.8 -4.2 -3.5 -3.3
                 Secondary income balance 3.1 3.3 3.2 2.9 1.5 1.1
Capital account 2.2 1.0 1.1 1.4 1.5 0.7
External balance 1) 5.3 4.3 2.0 3.3 1.5 0.3
Financial account 9.0 3.9 5.6 3.9 4.1 4.9
of which: Direct investment -1.2 -2.5 -1.3 -2.0 -4.5 -1.7
                Portfolio investment -1.4 5.4 2.8 2.6 1.2 3.4
                Other investment 2) 4.5 1.2 1.7 4.2 -2.1 -2.1
                Change in reserves 7.1 -0.2 2.4 -0.9 9.4 5.3
Financial account without reserves 1.9 4.1 3.1 4.8 -5.4 -0.4
Errors and omissions 3.8 -0.4 3.5 0.6 2.6 4.6
Gross capital formation 19.0 19.8 21.2 21.0 20.3 19.6
Gross saving 23.5 24.9 22.2 22.9 19.9 18.5
Net international investment position -47.5 -43.0 -37.0 -30.2 -27.1 -19.8
1) The combined current and capital account.
2) Including financial derivatives.
Sources: Eurostat, European Commission calculations, Bulgarian National Bank.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 81 – 
European Commission 
Convergence Report 2022 
66 
costs. (39) The appreciation in REER deflated by 
HICP has been more moderate, reflecting 
moderate price inflation until mid-2021. The swift 
acceleration of inflation at the end of 2021 has not 
caused real appreciation vis-à-vis the rest of the 
world, since inflation picked up globally, including 
in major trade partners. 
    
The swift rebound of exports following their 
decline in Q2-2020, caused by the global demand 
slump, indicates that exporting firms managed to 
maintain their export market share. The global 
hikes in prices of energy and other materials pose 
challenges to domestic producers to remain 
competitive, in addition to the problems caused by 
supply bottlenecks. So far, terms of trade 
developments have been favourable for exporters. 
The high energy intensity of the economy, 
however, bear some risks for the economic 
outlook. Firms are expected to respond to the
costpush shock by restricting nominal wage growth 
and postponing new hiring and investment 
decisions. This cost-saving strategy to maintain 
competitive position is set to be more prominent in 
manufacturing, while the services sector is 
expected to pass through higher costs to final 
consumers. Apart from the direct and indirect 
impact of the war on goods exports, Bulgarian 
firms are forecast to maintain market shares 
abroad. 
According to the Commission’s Spring 2022 
Economic Forecast, the current account balance is 
expected to deteriorate further to -1.8% in 2022 
and remain at that level in 2023. 
                                                          
(39) The REER based on unit labour costs should be interpreted 
with prudence as unit labour costs were distorted by labour 
retention schemes in some countries, including Bulgaria. 
2.6.2. Market integration 
The economy is well integrated with the euro area 
through trade and investment linkages. After a 
period of decline between 2017 and 2020, the ratio 
of trade openness rebounded to close to 64% in 
2021, which is close to the peak of above 68% in 
2017. Bulgaria thus remains a relatively open 
economy. Trade with the euro area was close to 
29% of total trade in 2021. Outside the EU, 
Bulgaria's main trading partners are Turkey and 
Russia (especially for energy imports). 
Net FDI inflows increased, but remained relatively 
low at 4.5% of GDP in 2020 and 1.7% of GDP in 
2021. The stock of FDI amounted to 75% of GDP 
in 2020 and 71% in 2021. The decline in 2021 is 
explained by the high nominal GDP growth. 26% 
of all FDI stock is directed to industry (excluding 
construction), 22% are invested in real estate, 
while the trade sector attracted 15% of total FDI 
stock. 
The business environment is generally not 
supportive of investment, and institutional quality 
remains a challenge. According to the World 
Bank's Worldwide Governance Indicators (2020), 
Bulgaria ranks low in voice and accountability, 
government effectiveness, rule of law and control 
of corruption compared with the average of the 
five euro area Member States with the lowest 
scores. (40) Bulgaria also ranks relatively low in 
the World Bank’s Ease of Doing Business 
indicator, where it maintained its rank of 61 
between 2019 and 2020, but in a longer 
perspective the trend has been negative (41). In 
addition, institutions remain among the least 
performing areas in the Global Competitiveness 
Index. In the Council Implementing Decision, 
approving the Recovery and Resilience Plan, the 
authorities have committed to a number of 
measures that address challenges identified in the 
Cooperation and Verification Mechanism (CVM), 
the Rule of Law Report, and also the recitals to the 
country-specific recommendations. This includes 
problems with the functioning of the judiciary, 
corruption and issues with the accountability and 
                                                          
(40) A Member State is considered to have a ‘low’ (‘high’) 
ranking compared with the average five euro area Member 
States with the lowest scores for each indicator if its score 
is at least 0.3 percentage points lower (higher) than that of 
the average of this euro area group. 
(41) The World Bank Doing Business (DB) program was 
paused in 2021. The programme will continue with a new 
governance and improved accountability and transparency 
under the name Business Enabling Environment (BEE). 
The first edition of the BEE is expected in 2023. 
80
90
100
110
120
130
140
150
2016 2017 2018 2019 2020 2021
Graph 2.9: Bulgaria - Effective exchange rates
NEER REER, HICP deflated REER, ULC deflated
(vs. 36 trading partners;  monthly averages;
index numbers, 2016 = 100)
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 82 – 
Convergence Report 2022 - Technical annex 
Chapter 2 - Bulgaria 
67 
criminal liability of the Prosecutor General. For the 
latter, important elements are the introduction of 
necessary safeguards and guarantees for an 
independent investigation of the Prosecutor 
General and his deputies; possibility for a judicial 
review of a prosecutor’s decision not to open an 
investigation, and annual reporting by the 
Prosecutor General on investigations and 
convictions in corruption cases. Anti-corruption 
measures include the set-up of a new
anticorruption body with criminal investigation 
powers, introduction of legislative measures to 
protect whistle-blowers and to regulate lobbying 
activities, and the establishment of an integrity 
verification mechanism for civil servants 
occupying positions that have a high corruption 
risk. 
    
Labour and skills shortages as well as skills 
mismatches relative to labour market needs 
represent a significant barrier to business 
investment and limit productivity gains. The 
uptake of digital technologies is slow in both 
public and private sectors and Bulgaria ranks last 
among EU Member States in digital skills. There 
are measures in the Recovery and Resilience Plan 
focusing on improving the labour market relevance 
of the education and lifelong-learning systems, 
including targeting the development of digital 
skills, and more broadly on advancing 
digitalisation. This should also help to alleviate 
some of the labour market bottlenecks and to 
modernise the economy. 
The 4th Anti-money Laundering Directive 
imposed transposition by 26 June 2017. Bulgaria 
communicated to the Commission several adopted 
measures to transpose the Directive between April 
2018 and November 2019. The Commission’s 
analysis of the communicated measures concluded 
that the Directive had been fully transposed. An 
assessment of the concrete implementation and 
effective application of the 4th Anti-money 
Laundering Directive in Bulgaria is at present 
ongoing. 
As regards the 5th Anti-money Laundering 
Directive, whose transposition deadline elapsed on 
10 January 2020, Bulgaria has notified national 
transposition measures and declared the 
transposition to be complete. The Commission is 
at present completing its analysis of whether there 
are any potential completeness or conformity 
issues in the transposition or implementation of the 
Directive. 
The COVID-19 crisis has entailed employment 
losses and increased inactivity rates. More severe 
adverse outcomes have largely been avoided 
through the swift transition to short-time work 
schemes that were supported by the state. 
Unemployment increased in Q2-2020 and then 
-0.5
0.0
0.5
1.0
1.5
Voice and Accountability
Political Stability and Absence of
Violence/Terrorism
Government Effectiveness
Regulatory Quality
Rule of Law
Control of Corruption
Bulgaria Euro area average five lowest Euro area average
Graph 2.10: Bulgaria - 2020 World Bank's Worldwide Governance Indicators
Note: Estimate of governance ranges from -2.5 (weak) to 2.5 (strong). 
Source: World Bank.
 
 
  
 
 
Table 2.5:
Bulgaria - Market integration
2016 2017 2018 2019 2020 2021
Trade openness 1) (%) 64.4 68.0 66.5 64.2 57.1 64.2
Trade with EA in goods &amp; services 2)+3) (%) 29.4 30.2 30.2 28.5 25.4 28.6
World Bank's Ease of Doing Business Index rankings 4) 39 50 59 61 61 -
IMD World Competitiveness Ranking 5) 50 49 48 48 48 53
Internal Market Transposition Deficit 6) (%) 1.7 1.3 0.7 0.6 1.6 -
Real house price index 7) 105.3 109.3 113.8 118.3 124.4 130.5
 1) (Imports + Exports of goods and services / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics, Balance of Payments).
 2) (Imports + Exports of goods with EA-19 / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics).
 3) Trade in services with EA-19 (average credit and debit in % of GDP at current prices) (Balance of Payments).
 4) Data not available for 2021. The Ease of Doing Business report by the World Bank was discontinued in September 2021. 
 5) International Institute for Management Development (IMD).
 6) Percentage of internal market directives not yet communicated as having been transposed, relative to the total.
    (November data, as of 2016 date refers to the year of publication).
 7) Deflated house price index (2015=100) (Eurostat). 
Sources: Eurostat, World Bank, International Institute for Management Development, European Commission calculations.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 83 – 
European Commission 
Convergence Report 2022 
68 
broadly stabilised until the end of 2021. The 
COVID-19 crisis highlighted the existing social 
vulnerabilities, such as a high share of population 
at risk of poverty and social exclusion, high levels 
of inactivity in some population groups (e.g. 
NEETs, Roma), combined with regional disparities 
and skills mismatches. The high social inequalities 
weigh on the prospects for fair and inclusive 
growth. 
Demographic developments strongly affect the 
labour market, and may constrain future economic 
growth. The population has shrunk by around 10% 
for the past decade on account of both mortality 
due to ageing and emigration. Furthermore, the 
share of population in working age (15-64 year) is 
also on a declining path, coming down from 68.5% 
in 2010 to 63.9% in 2020. 
The financial sector in Bulgaria is smaller and less 
developed than in the euro area. Relative to GDP, 
assets managed by the financial sector are a quarter 
of that of the euro area. The financial sector has 
grown since 2016, but not at the same pace as in 
the euro area. Banking dominates the Bulgarian 
financial sector and makes up more than 53% of 
the financial sector’s assets. The central bank is the 
second largest holder of financial assets with a 
share of 26%, more than all non-banking financial 
intermediaries together. Although these shares are 
larger than in the euro area, they compare well 
with the five euro-area Member States with the 
smallest financial sectors. 
The insurance and the pension-fund sector in 
Bulgaria is much smaller than in the euro area, 
relative to GDP. However, the sector’s share of the 
total financial sector is comparable to that of the 
euro area. Since end-2016, the Bulgarian sector 
has increased its holdings of financial assets by 
3.5 % of GDP, in the euro area it increased by 
12.3 percentage points. Nevertheless, the financial 
position of the National Bureau of Bulgarian 
Motor Insurers has come into question due to 
delays in the claims handling process in one 
undertaking. This has led to monitoring by the 
international Council of Bureaux, which is still 
ongoing. Moreover, the introduction of the
bonusmalus system has not progressed in the last two 
years. The investment-funds sector plays a very 
small role in the Bulgarian financial system, but its 
size is comparable to those of the five euro-area 
Member States with the smallest financial sectors. 
As to the financing of the economy, Bulgaria has 
less developed credit and equity markets relative to 
GDP than countries in the euro area, and market 
financing (debt securities and listed shares) is 
relatively under developed. However, Bulgaria is 
still fully comparable to the five euro-area Member 
States with the smallest national capital markets. 
Loans are the dominant source of funding and 
make up 116% of GDP in 2020, compared to 
240% of GDP in the euro area. Still, corporate debt 
surpasses the fundamental threshold, although the 
gap has been narrowing and the prudential 
benchmark is satisfied. (42) Equity and
privatesector-debt markets are very small compared to 
those of the euro area and represent only 14% of 
GDP altogether. This compares to 83% for
privatesector debt and 73% for listed stocks in the euro 
area. Government debt is significantly lower than 
in the euro area. In terms of share in the sum of 
liabilities, loans in Bulgaria are comparable to that 
of the euro area. For securities, the differences 
(42) Methodology to compute the fundamentals-based and the
prudential benchmarks based on Bricongne et al. (2017). 
Table 2.6:
Bulgaria - Allocation of assets by financial sub-sector
Ratio to GDP (%)
BG EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Financial corporations (total) 184 191 722 796 177 215
Central bank 49 50 45 78 37 61
Monetary financial institutions 99 102 286 311 97 98
Other financial intermediaries 17 17 202 179 20 28
Non-MMF investment funds1) 1 2 100 127 4 5
Insurance co. and Pension Funds 18 21 90 102 18 23
Share of total (%)
BG EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Central bank 27 26 6 10 21 29
Monetary financial institutions 54 53 40 39 55 46
Other financial intermediaries 9 9 28 22 11 12
Non-MMF investment funds 1 1 14 16 2 2
Insurance co. and Pension Funds 10 11 12 13 10 11
1) MMF stands for money market funds.
Source: Eurostat.
Table 2.7:
Bulgaria - Financing of the economy1)
Ratio to GDP (%)
BG EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Liabilities (total) 393 376 743 770 324 335
Loans 127 116 238 236 115 112
Non-financial co. debt securities 4 3 12 15 3 4
Financial co. debt securities 1 1 74 68 11 12
Government debt securities 25 22 83 95 51 57
Listed shares 12 10 65 73 17 18
Unlisted shares 68 73 186 193 55 56
Other equity 93 88 51 56 42 48
Trade credits and advances 64 64 33 35 29 29
Share of total (%)
BG EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Loans 32 31 32 31 35 33
Non-financial co. debt securities 1 1 2 2 1 1
Financial co. debt securities 0 0 10 9 3 3
Government debt securities 6 6 11 12 16 17
Listed shares 3 3 9 9 5 5
Unlisted shares 17 20 25 25 18 18
Other equity 24 23 7 7 13 14
Trade credits and advances 16 17 4 5 9 9
1) The table focuses on the financing needs of a country and how these are met by the financial system.
 The table is constructed from the liabilities of all economic sectors, but only considers loans, debt securities, 
equity and trade credits. The sum of liabilities in the table only reflects the total for the liabilities considered.
Source: Eurostat.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 84 –
Convergence Report 2022 - Technical annex 
Chapter 2 - Bulgaria 
69 
reflect the smaller share of market funding 
available in Bulgaria. 
Bulgaria's banking sector is well integrated into the 
euro-area financial sector, in particular through a 
high level of foreign ownership in the banking 
system. The share of foreign-owned institutions in 
total bank assets stood at 77% in 2020. Bank 
concentration, as measured by the market share of 
the five largest credit institutions in total assets, 
has increased significantly since 2016, and reached 
almost 67% in 2020. This is 14 percentage points 
above the euro area average in 2020. In parallel 
with the inclusion of the Bulgarian lev in the ERM 
II, the Bulgarian National Bank entered into a 
close cooperation with the ECB, effectively 
joining the Banking Union. As of 1 October 2020, 
Bulgaria joined the Single Resolution Mechanism, 
and the ECB became responsible for the direct 
supervision of the significant institutions in 
Bulgaria, as well as the oversight of less 
significant institutions. 
Although intra-EU integration in equity and debt 
markets, as measured by the home bias in portfolio 
investments, are in general relatively low across 
EU Member States, Bulgaria is commensurate to 
levels of integration of the average euro-area 
Member State in debt markets. (43) Moreover, 
integration in this market segment has improved 
markedly between 2016 and 2020. Concerning 
portfolio investments in equity, however, the home 
bias is very strong in Bulgaria relative to euro-area 
Member States. Almost all investments in equity 
markets take place domestically. 
(43) Home bias in portfolio investments measures the average
propensity of investors in a Member State to invest
domestically as compared with investing in other EU
countries. The indicator ranges between 0 and 1, with a
value of 0 indicating that investors prefer domestic over
foreign assets. The inverse of the home bias can be
interpreted as one measure of financial integration among
EU countries.
0
20
40
60
80
100
BG, 2016 BG, 2020 EA, 2016 EA, 2020
Concentration in the banking sector (CR5 ratio)
Share of foreign institutions as % of total assets
Graph 2.11: Bulgaria - Foreign ownership and concentration 
in the banking sector
(in percent, weighted averages)
Source: ECB, Structural financial indicators.
0.0
0.2
0.4
BG, 2016 BG, 2020 EA, 2016 EA, 2020 EA Low,
2016
EA Low,
2020
Debt Equity
Graph 2.12: Bulgaria - Intra-EU integration in equity and debt portfolio 
investment
Note: The chart shows the extent of home bias in debt and equity markets. A value 
index of 1 implies ‘full integration’ with the financial markets of other Member States, 
while 0 denotes ‘no integration’.
Source: FinFlows database: European Commission, Joint Research Centre (JRC). 
(index)
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 85 –

3. CZECHIA
71 
3.1. LEGAL COMPATIBILITY 
3.1.1. Introduction 
The Česká národní banka (ČNB – Czech national 
bank, hereafter ČNB) was established on 
January 1, 1993. Its main legal basis is the Czech 
National Council Act No. 6/1993 Coll. on the 
Czech National Bank, adopted on 17 December 
1992 (the ČNB Law). 
Following the Commission’s 2020 Convergence 
Report, the ČNB Law was amended (44). However, 
since there have been no amendments as regards 
the incompatibilities highlighted in the 
Commission's 2020 Convergence Report, the 
comments made in the latter report are repeated 
also in this year's assessment. 
3.1.2. Central Bank independence 
Article 9(1) of the ČNB Law prohibits the ČNB 
and its Board from taking instructions from the 
President of Czechia, Parliament, the Government, 
administrative authorities, European Union 
institutions, any government of a Member State of 
the European Union or any other body.  
Article 9(1) of the ČNB Law needs to be adapted 
to fully reflect the provisions of Article 130 of the 
TFEU and Article 7 of the Statute and 
consequently expressly prohibit third parties from 
giving instructions to the ČNB and its Board 
members who are involved in the performance of 
ESCB-related tasks. 
The power for the Chamber of Deputies of the 
Parliament to impose modifications to the annual 
financial report, which was previously submitted 
and rejected (Article 47(5) of the ČNB Law) could 
hamper the ČNB’s institutional independence. 
Moreover, it is formulated in a very general 
manner, which could create situations where the 
Parliament requests changes affecting the financial 
independence of the ČNB. Thus, the current 
wording of Article 47(5) of the ČNB Law 
constitutes an incompatibility, which should be 
removed from the Act. 
(44) The amendments stem from the Act. No. 219/2021 Coll.,
Act No. 238/2020 Coll., Act No. 353/2021 Coll. and Act
No. 417/2021 Coll.
Article 6(10) of the ČNB Law provides that 
members of the Bank Board, which also includes 
the Governor of the ČNB, may be relieved from 
office only if they no longer fulfil the conditions 
required for the performance of their duties or if 
they have been guilty of serious misconduct. 
Although Article 6(10) of the ČNB Law extends 
the protection offered by Article 14.2 of the 
ESCB/ECB Statute to Governors against arbitrary 
dismissal to all Bank Board members of the ČNB, 
it remains silent on the Governor’s right in case of 
dismissal to seek a remedy before the Court of 
Justice of the European Union. However, pursuant 
to footnote 22, the Commission understands that 
the possibility to seek legal redress by the 
Governor before the Court of Justice of the 
European Union, as enshrined in Article 14.2 of 
the ESCB/ECB Statute, would apply. However, 
the ČNB Law would benefit from a more explicit 
clarification.  
Pursuant to Article 11(1) of the ČNB Law, the 
Minister of Finance or another nominated member 
of the Government may attend the meetings of the 
Bank Board in an advisory capacity and may 
submit motions for discussion. Article 11(2) 
entitles the Governor of the ČNB, or a Vice-
Governor nominated by him, to attend the 
meetings of the Government in an advisory 
capacity. With regard to Article 11(1) of the ČNB 
Law, although a dialogue between a central bank 
and third parties is not prohibited as such, it should 
be ensured that this dialogue is constructed in such 
a way that the Government should not be in a 
position to influence the central bank when the 
latter is adopting decisions for which its 
independence is protected by the TFEU. The active 
participation of the Minister, even without voting 
right, in discussions where monetary policy is set 
would structurally give to the Government the 
opportunity to influence the central bank when 
taking its key decisions. Therefore, Article 11(1) 
of the ČNB Law is incompatible with Article 130 
of the TFEU, as Member States have to undertake 
not to seek to influence the members of the 
decision-making bodies of the national central 
bank. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 87 –
European Commission 
Convergence Report 2022 
72 
3.1.3. Prohibition of monetary financing and 
privileged access 
Pursuant to Article 33a of the ČNB Law, where the 
Financial Market Guarantee System has 
insufficient funds to carry out its duties arising 
from the legislation on deposit insurance and this 
situation might jeopardise the stability in the 
financial market, the ČNB may, upon request, 
exceptionally provide it with short-term credit, for 
a period of up to three months, guaranteed by 
government bonds or other securities underwritten 
by the Government and owned by the Financial 
Market Guarantee System. The Financial Market 
Guarantee System qualifies as a “body governed 
by public law” within the meaning of Article 
123(1) of the TFEU, being closely dependent on 
the public sector entities referred to in Article 
123(1) of the TFEU. The governing body of the 
Financial Market Guarantee System is composed 
of two employees of the Czech National Bank, two 
employees of the Ministry of Finance, and one 
representative appointed on a proposal from the 
Czech Banking Association. Although only a 
minority of the members of the Financial Market 
Guarantee System’s governing body are 
representatives of the Ministry of Finance, the 
Ministry of Finance has the right to appoint and 
dismiss all the members of the Financial Market 
Guarantee System’s governing body. Therefore, 
the provisions laid down in Article 33a of the ČNB 
Law regarding the possibility of ČNB granting 
short-term credit to the Financial Market 
Guarantee System are not compatible with the 
monetary financing prohibition and the relevant 
legal framework should be amended accordingly.  
Article 34a(1) first half-sentence of the ČNB Law 
prohibits the ČNB from providing overdraft 
facilities or any other type of credit facility to the 
bodies, institutions or other entities of the 
European Union, central governments, regional or 
local authorities or other bodies governed by 
public law, other entities governed by public law 
or public undertakings of the Member States of the 
European Union. The list of entities does not fully 
mirror the one in Article 123(1) of the TFEU and, 
therefore, has to be amended. 
Moreover, the footnote in Article 34a(2) of the 
ČNB Law should refer to Article 123(2) of the 
TFEU instead of globally to Article 123 of the 
TFEU. 
3.1.4. Integration in the ESCB 
Objectives 
Pursuant to Article 2(1) of the ČNB Law, "in 
addition" to the ČNB's primary objective of 
maintaining price stability, the ČNB shall work to 
ensure financial stability and the safety and sound 
operation of the financial system and – without 
prejudice to its primary objective – support the 
general economic policies of the Government and 
the European Union. Article 2(1) of the ČNB Law 
needs to be amended with a view to achieving 
compatibility with Article 127 TFEU and Article 2 
of the ESCB/ECB Statute. Compatibility with the 
ESCB's objectives requires a clear supremacy of 
the primary objective over any other objective. 
Tasks 
The incompatibilities in this area, following the 
TFEU provisions and ESCB/ECB Statute, include: 
• definition of monetary policy and monetary
functions, operations and instruments of the
ECB/ESCB (Articles 2(2)(a), 5(1) and 23 to 26,
28, 29, 32, 33 of the ČNB Law);
• conduct of exchange rate operations and the
definition of exchange rate policy (Articles 35
and 36 of the ČNB Law);
• holding and management of foreign reserves
(Articles 35(c), 36 and 47a of the ČNB Law);
• non-recognition of the competences of the ECB
and of the Council on the banknotes and coins
(Article 2(2)(b), Articles 12 to 22 of the ČNB
Law);
• ECB's right to impose sanctions (Article 46a of
the ČNB Law);
• the possibility for Parliament to demand
amendments to the report of the ČNB on
monetary policy developments and to
determine the content/scope of the
extraordinary report in view of the absence of a
specification regarding the non-
forwardlooking nature of the reports (Article 3 of the
ČNB Law).
• There are also some imperfections regarding:
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 88 –
Convergence Report 2022 - Technical annex 
Chapter 3 - Czechia 
73 
• the partial absence of reference to the role of
the ECB and of the EU in the collection of
statistics (Article 41);
• non-recognition of the role of the ECB in the
functioning of the payment systems (Articles
2.2 c), 38 and 38a of the ČNB Law);
• non-recognition of the role of the ECB and of
the Council in the appointment of the external
audit of the ČNB (Article 48(2) of the ČNB
Law);
• absence of an obligation to comply with the
Eurosystem's regime for the financial reporting
of NCB operations (Article 48 of the ČNB
Law);
• non-recognition of the role of the ECB in the
field of international cooperation (Article 2(3)
of the ČNB Law).
3.1.5. Assessment of compatibility 
As regards the independence of the central bank, 
the prohibition of monetary financing and the 
integration of the central bank in the ESCB at the 
time of euro adoption, the ČNB Law is not fully 
compatible with the compliance duty under Article 
131 of the TFEU. The Czech authorities are 
invited to remedy the above-mentioned 
incompatibilities. 
3.2. PRICE STABILITY 
3.2.1. Respect of the reference value 
The 12-month average inflation rate, which is used 
for the convergence assessment, was above the 
reference value at the time of the last convergence 
assessment of Czechia in 2020. After a gradual 
increase up to 3.4% in October 2020, it steadily 
decreased to 2.7% in summer 2021, before 
increasing steeply to 6.2% in April 2022. In April 
2022, the reference value was 4.9%, calculated as 
the average of the 12-month average inflation rates 
in France, Finland, and Greece plus 1.5 percentage 
points. The corresponding inflation rate in Czechia 
was 6.2%, i.e. 1.3 percentage points above the 
reference value. According to the Commission’s 
Spring 2022 Economic Forecast, the 12-month 
average inflation rate is projected to remain well 
above the reference value in the months ahead. 
3.2.2. Recent inflation developments 
The annual HICP inflation rate experienced 
considerable volatility in the past two years. After 
peaking at 3.8% in January 2020, it followed a 
broad downward path in 2020 to reach a low of 
2.1% in February 2021. The deceleration was 
mainly due to declining energy prices. HICP 
inflation then increased steadily from 2.2% to 
5.4% at the end of 2021, exceeding the central 
bank’s upper tolerance band of 3.0% continuously 
from August onwards (45). It surged further to 
13.2% in April 2022. The acceleration of inflation 
since the beginning of 2021 is explained by a 
combination of strong domestic demand and 
external factors related to supply chain bottlenecks 
and surging energy prices. Since end 2018, annual 
HICP inflation has been higher in Czechia than in 
the euro area.  
Core inflation (measured as HICP inflation 
excluding energy and unprocessed food prices) 
was above headline inflation in 2020 and 2021. 
This was mainly due to on average rather low 
energy inflation and slowdown of the food prices. 
The annual core inflation oscillated between 3.3% 
and 4.2% in 2020. It then decelerated moderately 
up to summer 2021 due services inflation before 
accelerating steadily to reach a rate of 6.4% in 
December and 10.4% in April 2022. Prices of 
services slowed down between summer 2020 and 
September 2021, but started gathering pace 
afterwards. The surge in core inflation since 
summer 2021 has been broad-based, with services, 
non-energy industrial goods and processed food 
prices all increasing strongly.  
(45) It is important to note that the ČNB’s tolerance band is
based on CPI inflation, which was even higher during the
same period due to a different basket composition. 
0
2
4
6
8
10
12
14
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Czechia Reference value
Graph 3.1: Czechia - Inflation criterion
(percent, 12-month moving average)
Note: The dots at the right end of the chart show the projected reference 
value and 12-month average inflation rate of the country in December 2022.
The reference values for 2016, 2018 and 2020 refer to the reference values 
calculated in the previous Convergence Reports.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 89 –
European Commission 
Convergence Report 2022 
74 
3.2.3. Underlying factors and sustainability of 
inflation 
Macroeconomic policy mix and growth 
developments 
Due to the negative impact of the global pandemic, 
the Czech economy decelerated in 2020, when real 
GDP declined by 5.8%. The Czech economy 
rebounded by 3.3% in 2021, as activity benefited 
from the easing of pandemic-related restrictions. 
Private consumption was the main driver of GDP 
growth in 2021, supported by low unemployment 
and a pick-up in real disposable income growth, 
partially due to income tax changes. Private 
consumption is expected to remain the main driver 
of the economic recovery, reflecting high 
employment levels, pent-up demand and a 
declining saving rate of households. A sharp 
increase in the cost of living, in particular due to 
high energy prices is, however, likely to weigh on 
domestic spending. Gross fixed capital formation 
declined strongly in 2020 (by 7.5%), largely 
influenced by low investment activity in the 
automotive industry. Facing further problems 
related to supply chains, investment activity 
remained low during much of 2021 and started 
rebounding only towards the end of 2021. 
According to the Commission’s Spring 2022 
Economic Forecast, real GDP is expected to 
increase by about 1.9% in 2022 and 2.7% in 2023. 
Consequently, the Czech economy is projected to 
reach the pre-pandemic output level only during 
the second quarter of 2023. 
In order to help combat the negative effects of the 
COVID pandemic on the economy, the fiscal 
stance was strongly expansionary in 2020 and in 
2021 (46), through employment retention schemes 
as well as support targeted at the most affected 
sectors. The fiscal stance is expected to turn 
neutral in 2022 (+0.1% of GDP) as the expenditure 
financed through the RRF and other EU grants 
contributes positively by around 1.0% of GDP. 
Still, the phase-out of the pandemic-related 
measures is to help offset some of the inflationary 
pressures. Additional measures to cope with the 
inflow of people fleeing Ukraine as well as the 
support to households affected by the high 
inflation are also to provide an expansionary 
contribution. Government consumption 
contributed positively to GDP growth with a real 
growth of 3.4% in 2020 and 1.6% in 2021 but its 
real growth pace is expected to slow down to 0.6% 
in 2022, before picking up to 1.3% in 2023. On the 
other hand, public investments growth rate is likely 
(46) The fiscal stance is measured as the change in primary
expenditure (net of discretionary revenue measures),
excluding COVID-19 crisis-related temporary emergency
measures but including expenditure financed by
nonrepayable support (grants) from the Recovery and
Resilience Facility and other EU funds, relative to
mediumterm potential growth. A negative (positive) sign of the
indicator corresponds to an excess (shortfall) of primary
expenditure growth compared with medium-term economic
growth, indicating an expansionary (contractionary) fiscal
policy 
-2
0
2
4
6
8
10
12
14
2016 2017 2018 2019 2020 2021
Czechia Euro area
Graph 3.2: Czechia - HICP inflation
(y-o-y percentage change)
Source: Eurostat.
Table 3.1: weights  
Czechia - Components of inflation (percentage change)1) in total   
2016 2017 2018 2019 2020 2021 Apr-22 2022
HICP 0.6 2.4 2.0 2.6 3.3 3.3 6.2 1000
Non-energy industrial goods 0.8 0.6 0.6 0.5 2.6 4.3 6.7 269
Energy -2.5 1.2 3.2 4.8 -1.5 1.7 12.1 117
Unprocessed food 0.5 2.2 2.3 1.4 8.4 -1.3 0.3 52
Processed food 1.2 4.4 1.7 2.7 5.0 4.3 5.5 249
Services 1.5 2.9 2.6 3.4 3.6 3.1 5.1 314
HICP excl. energy and unproc. food 1.2 2.6 1.8 2.3 3.7 3.8 5.7 831
HICP at constant tax rates 0.4 2.6 1.9 2.6 3.2 3.4 6.0 1000
Administered prices HICP 1.4 1.1 1.5 3.7 3.6 0.8 4.5 145
1) Measured by the arithmetic average of the latest 12 monthly indices relative to the arithmetic average of the 12 monthly indices
in the previous period.
Source: Eurostat, European Commission calculations.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 90 –
Convergence Report 2022 - Technical annex 
Chapter 3 - Czechia 
75 
to accelerate in 2022 and 2023 with the help of EU 
funds, with investments-to-GDP ratio expected to 
increase towards a past decade high of 5%. 
The ČNB conducts monetary policy within an 
inflation targeting framework. The use of the 
exchange rate as an additional monetary policy 
instrument was discontinued in April 2017. The 
decision was supported by macroeconomic data 
and forecasting scenarios indicating a sustainable 
fulfilment of the 2% inflation target over the 
forecast horizon. After a hike in February 2020, 
the ČNB eased significantly its main policy rate 
(the 2-week repo rate) cutting it by 200 basis 
points in three steps in March and May to 0.25%, 
to counter the impact of the pandemic on the 
Czech economy. The key policy rate was kept at 
this low level until June 2021. Due to strongly 
increasing domestic inflation pressures, the ČNB 
Board raised its policy rates as from summer 2021. 
Overall, the main policy rate increased by 
550 basis points to reach 5.75% after the ČNB 
Board’s decision at the meeting in early May 2022. 
From early March 2022, the ČNB has been 
repeatedly active in the exchange rate market 
(stabilising intervention) in the aftermath of the 
Russia’s invasion of Ukraine (47), although shortly, 
on the back of self-stabilising mechanisms in the 
exchange rate market. 
(47) The details are provided in Section 3.4 on exchange rate
stability.
Wages and labour costs 
The labour market continued to perform well in 
2020 and 2021. Despite its tightness, Czechia’s 
labour market was in a good position to absorb the 
impact of the crisis. Cushioned by temporary job 
retention schemes supporting self-employed and 
companies, the unemployment rate increased only 
slightly to 2.6% in 2020 (annual average) and to 
2.8% in 2021. As a result, nominal wage growth 
continued to be buoyant in 2020 and 2021 
(supported by increases for public sector 
employees). Although wage growth moderated 
significantly in 2020 due to the impact of the 
pandemic and supply chain disruptions, the still 
high growth rate compared to the historical 
average is mainly attributable to persisting labour 
shortages, due to e.g. demographic factors, and to 
an increase in the minimum wage (48). Wages in 
both the public and private sector showed similar 
growth dynamics in 2020 and 2021. 
On the sectoral level, differences in wage growth 
are observed. Notably, the sectors that have been 
most adversely affected by supply chain 
disruptions and that have faced relatively less 
labour shortages experienced lower wage 
(48) Despite the increase in the minimum wage, the relative
value in PPS of the statutory minimum wage in Czechia is 
the fifth lowest in the EU, after Latvia, Bulgaria, Estonia,
and Slovakia.
Table 3.2:
Czechia - Other inflation and cost indicators (annual percentage change)
2016 2017 2018 2019 2020 2021 20221) 20231)
HICP inflation
Czechia 0.6 2.4 2.0 2.6 3.3 3.3 11.7 4.5
Euro area 0.2 1.5 1.8 1.2 0.3 2.6 6.1 2.7
Private consumption deflator
Czechia 0.4 2.3 2.5 2.8 2.8 3.1 11.7 5.4
Euro area 0.4 1.3 1.5 1.1 0.5 2.3 5.8 2.7
Nominal compensation per employee
Czechia 4.0 7.2 8.1 7.2 3.2 5.7 2.4 5.3
Euro area 1.2 1.7 2.1 2.1 -0.7 4.1 3.6 3.5
Labour productivity
Czechia 0.9 3.6 1.8 2.8 -4.2 3.2 -0.3 2.4
Euro area 0.4 1.0 0.2 0.3 -4.9 4.2 1.4 1.5
Nominal unit labour costs
Czechia 3.0 3.5 6.1 4.3 7.7 2.4 2.8 2.8
Euro area 0.8 0.7 2.0 1.9 4.4 0.0 2.2 2.0
Imports of goods deflator
Czechia -3.8 0.6 -0.6 0.6 -1.0 4.9 8.2 2.9
Euro area -3.3 3.3 2.6 -0.5 -3.8 9.6 13.2 0.8
1) Commission Spring 2022 Economic Forecast.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 91 –
European Commission 
Convergence Report 2022 
76 
increases. The RRP will support Czechia in 
overcoming such sectoral imbalances by 
promoting policies that are inclusive and targeted 
at boosting skills, fostering the green and digital 
transition, stimulating entrepreneurship and 
diminishing current macroeconomic risks 
stemming for instance from import dependencies 
in energy. 
Labour productivity declined in 2020 and 
recovered only partially in 2021. As compensation 
per employee kept growing at a faster pace than 
productivity, nominal unit labour costs grew by 
7.7% in 2020, and 2.4% in 2021. According to the 
Commission’s Spring 2022 Economic Forecast 
wage growth is expected to have picked up in 
2021, grow slightly less in 2022 and increase more 
again in 2023, while productivity remains subdued 
in 2022 with an expected pick-up in 2023. Unit 
labour cost growth will also notably depend on the 
way labour shortages are addressed and the scope 
companies have to increase wages, during this time 
of elevated inflation. In the medium- to long term, 
inflation is expected to lead to increases in nominal 
wages. In the short-term, wage growth is, however, 
expected to be somewhat limited given inflation, 
supply chain disruptions and overall 
macroeconomic uncertainty reducing profit 
margins and therefore limiting the possibilities of 
companies to increase wages. Overall, the risks of 
significant second-round effects of wage increases 
– a wage-price spiral – appear to be constrained.
External factors 
Given the size and openness of the Czech 
economy, import prices have a sizeable effect on 
domestic price formation. The imports of goods 
deflator fell by 1% in 2020, mainly due to 
declining oil prices. The fall was more moderate 
than in the euro area (-3.8%). In 2021, goods’ 
import prices increased by about 4.9%, driven by 
prices for machinery and transport equipment as 
well as increasing energy prices. 
The nominal effective exchange rate (measured 
against the main 36 trading partners) depreciated 
in spring 2020 but recovered afterwards, 
contributing to bringing import prices down during 
that period. Import prices are set to remain broadly 
stable in 2022, as the effect of the expected 
appreciation of the koruna in 2022 should be offset 
by inflationary pressures stemming from the 
supply chain bottlenecks and by elevated oil 
prices. 
Administered prices and taxes 
The share of administered prices in the HICP 
basket stabilised at 15.6% in 2021, slightly above 
the euro area average of 13.3%. Changes in 
administered prices were a significant driver of 
inflation in 2020, as they increased by 3.6%, i.e. 
faster than headline HICP. This was not the case in 
2021, where growth in administered prices was 
just 0.8%, compared to 3.3% for the overall HICP. 
Increases in heat energy were the main contributor 
to the increase in administered prices in 2020 and 
their decline in 2021. HICP at constant tax rates 
was around the same level as headline inflation 
both in 2020 (3.2%) and 2021 (3.4%). 
Administered prices picked up sharply in January 
2022, due to a surge in energy prices and the 
reintroduction of VAT on electricity and gas (the 
non-prolongation of the government support 
measures in late 2021). 
Medium-term prospects 
Annual HICP inflation increased in early 2022, 
driven by increasing energy prices, accompanied 
by increasing food prices and prices of services, as 
well as further rises in administered prices, 
changes to indirect taxes and non-energy industrial 
goods inflation. Inflation is expected to remain 
elevated in the second half of 2022, before 
moderating in 2023, as global supply side 
distortions take time to resolve, and the on-going 
tightening of domestic monetary conditions comes 
into effect. According to the Commission’s Spring 
2022 Economic Forecast, annual HICP inflation is 
projected to average at 11.7% in 2022 and 4.5% in 
2023. In order to combat the effects of the high 
inflation, the government lowered temporarily the 
excise duties on petrol and diesel (from June until 
September 2022) and reduced the road tax on cars 
-6
-3
0
3
6
9
12
15
2016 2017 2018 2019 2020 2021 2022 2023
Productivity (real GDP per person employed)
Nominal compensation per employee
Nominal unit labour costs
HICP inflation
Graph 3.3: Czechia - Inflation, productivity and wage trends
(y-o-y % change)
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 92 –
Convergence Report 2022 - Technical annex 
Chapter 3 - Czechia 
77 
and trucks. However, it is expected that these 
measures will have only a limited effect on 
inflation. Support measures targeted at the
lowincome households have also been introduced and 
the household allowance have been increased. 
The risks to the inflation outlook are unusually 
high overall. The main upside risks are weaker 
anchoring of inflation expectations and slower 
appreciation of the koruna because of tightening of 
monetary policy abroad. At the same time, higher 
than expected wage growth and repercussions of 
Russian’s invasion of Ukraine could push prices 
up. By contrast, consolidation of public finances is 
a slight downside risk to inflation.  
The level of consumer prices in Czechia was about 
73% of the euro-area average in 2020, suggesting 
that there is still potential for further price level 
convergence in the long term. Since 2012, Czechia 
has steadily converged to the euro area average in 
GDP per capital in PPS, to about 88% in 2021 (the 
COVID-19 pandemic brought about a small tick 
down from 89% reached in 2020). 
3.3. PUBLIC FINANCES 
3.3.1. Recent fiscal developments 
On the back of an ample fiscal expansion launched 
to combat the effects of the COVID crisis, Czechia 
reported a deficit of the general government 
budget of 5.8% in 2020 and 5.9% in 2021. While 
government revenues proved more resilient with 
the revenue-to-GDP ratio dropping only 1 pp from 
41.4% in 2019 to 40.5% in 2021, the
expenditureto-GDP ratio expanded from 41.0% in 2019 to 
46.4% in 2021. Temporary COVID-related 
measures taken by the government accounted for 
extra expenses of about 2.7% of yearly GDP on 
average in 2020 and 2021. Among the largest 
temporary measures are the short-time work 
schemes, i.e. “Antivirus” programme and the 
Compensatory bonus for self-employed or the 
companies support programs “COVID-Uncovered 
costs” and “COVID-2021”. These temporary 
schemes were instrumental in maintaining 
employment for businesses affected by the 
crisis. (49) They were supplemented by permanent 
measures like the decrease in the personal income 
tax (about 1.8% of GDP per year) as well as cuts in 
VAT for certain services or the elimination of the 
residential transaction tax. 
The 2021 general government deficit of 5.9% of 
GDP (almost unchanged vs 5.8% in 2020) was 
significantly better than the estimate of 8.8% in the 
2021 Convergence Programme. This is explained 
by a higher nominal GDP growth of 7.6% 
compared to 4.9% in the program but also lower 
take-up for some of the pandemic-related support 
measures. 
                                                          
(49) However, a recently published review of government 
accounts by the independent Supreme Audit Office found 
most of the 2021 increase of government expenditures as 
not related to the COVID-19 pandemic. 
 
 
  
 
 
Table 3.3:
Czechia - Budgetary developments and projections (as % of GDP unless indicated otherwise)
Outturn and forecast 1) 2016 2017 2018 2019 2020 2021 20221) 20231)
General government balance 0.7 1.5 0.9 0.3 -5.8 -5.9 -4.3 -3.9
- Total revenue 40.5 40.5 41.5 41.4 41.6 40.5 40.2 39.8
- Total expenditure 39.8 39.0 40.6 41.1 47.3 46.4 44.5 43.7
   of which: 
- Interest expenditure 0.9 0.7 0.7 0.7 0.8 0.7 0.9 0.9
p.m.: Tax burden 35.1 35.4 36.0 36.0 36.1 35.1 34.0 33.6
Primary balance 1.6 2.2 1.6 1.0 -5.0 -5.1 -3.4 -3.0
Fiscal stance 2) 0.0 -1.3 0.1 0.1
Government gross debt 36.6 34.2 32.1 30.1 37.7 41.9 42.8 44.0
p.m: Real GDP growth (%) 2.5 5.2 3.2 3.0 -5.8 3.3 1.9 2.7
1) Commission’s Spring 2022 Economic Forecast.
2) A negative (positive) sign of the indicator corresponds to an excess (shortfall) of primary expenditure growth 
compared with medium-term economic growth, indicating an expansionary (contractionary) fiscal policy.
Source: European Commission.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 93 – 
European Commission 
Convergence Report 2022 
78 
While public debt is still low compared to other 
EU Member States, the pace of its growth in 2020-
2021 was high, with public debt-to-GDP ratio 
increasing from 30.1% in 2019 to 41.9% in 2021, 
driven by the negative headline balance only partly 
offset by nominal GDP growth. Liquidity support 
for households and companies in the form of 
guarantees did not have a direct budgetary impact, 
but the guarantees provided in response to the 
COVID-19 pandemic represent contingent 
liabilities, estimated by the Commission services at 
around 1.5% of 2022 GDP as of March 2022. 
3.3.2. Medium-term prospects 
The 2022 budget approved by the Czech 
parliament in March 2022 envisages a central 
government deficit of 4.2% of GDP and aims to 
start a correction of the high deficit registered in 
the previous years. The budget maintains the tax 
cuts implemented in 2020 (e.g. the cut in the 
personal income tax) and focuses instead on 
limiting public expenses growth. A planned 
phasing-out of the temporary COVID-19 support 
measures will help contain related expenses. 
Public wages growth for 2022 has been limited to 
6% for health personnel, while other public 
employees’ categories had either small indexation 
or their salaries frozen. On the other hand, due to 
high inflation, pensions are set to be boosted by 
two automatic indexations (in January and in June 
2022), thus continuing to add pressure on 
expenditure. Investments are to expand further on 
the back of a higher contribution of EU funds 
including the Recovery and Resilience Facility 
(RRF). In light of the increase in energy prices, the 
Government adopted measures to help households 
and companies to cope with the economic and 
social impact of rising prices. The measures 
consist of a temporary decrease in excises duties 
on fuel prices (0.1% of GDP) but also increase in 
housing allowances targeted at lower income 
households (0.1% of GDP). The budgetary costs 
related to assisting people fleeing Ukraine is 
assumed, according to Commission’s Spring 2022 
Economic Forecast at close to 0.4% of GDP. 
The 2022 Convergence Programme has been 
approved by the government on 11 May 2022. The 
Program aims to provide a consolidation path of 
the public finances over the medium term. The 
Program expects the general headline balance at 
4.5% in 2022 and at 3.2% in 2023. The 
consolidation path is mostly based on containment 
of expenses that are forecast to grow slower than 
the nominal GDP growth, thus creating savings of 
1.4% of GDP in 2022 and another 1.8% of GDP in 
2023, compared with the levels from 2021. The 
government deficit in 2022 is impacted by the 
additional measures taken by the government to 
counter the social and economic impact of the 
increase in energy prices, as well as the provision 
of humanitarian assistance to people fleeing 
Ukraine. 
According to the Commission’s Spring 2022 
Economic Forecast and based on a no-policy 
change scenario, the government balance is 
expected to decrease to 4.3% of GDP in 2022 and 
further to 3.9% in 2023, as revenues are expected 
to grow strongly on the back of high nominal GDP 
growth, while COVID-19 temporary emergency 
measures are expected to be phased out. 
In 2022, the fiscal stance is projected in the 
Commission’s Spring 2022 Economic Forecast to 
be broadly neutral, at +0.1% of GDP (50). The 
positive contribution to economic activity of 
expenditure financed by Recovery and Resilience 
Facility grants and other EU funds is projected at 
2.0 percentage points of GDP in 2022, higher by 
1.0 percentage points of GDP compared to 2021. 
Nationally financed investment is projected to 
provide a contractionary contribution to the fiscal 
stance of 0.6 percentage points in 2022. At the 
same time, the growth in nationally financed 
primary current expenditure (net of new revenue 
measures) in 2022 is projected to provide a 
contractionary contribution of 0.7 percentage 
points of GDP to the overall fiscal stance, as 
current expenditure is set to grow at a slower pace 
than medium-term potential growth. 
(50) For a definition of the fiscal stance used in this Report, see
footnote in Section 3.2.3 on underlying factors and
sustainability of inflation. 
-2
-1
0
1
2
2020 2021 2022 2023
Net nationally financed  primary current expenditure Nationally financed investment
Other capital expenditure Expenditure financed by RRF grants and EU funds
Fiscal stance
Expansionary
Contractionary
Graph 3.4: Czechia - Fiscal stance and its components
(percent of GDP)
Source: Commission's Spring 2022 Economic Forecast. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 94 –
Convergence Report 2022 - Technical annex 
Chapter 3 - Czechia 
79 
In 2023, the fiscal stance is projected at +0.1% of 
GDP. The positive contribution to economic 
activity of expenditure financed by Recovery and 
Resilience Facility grants and other EU funds is 
projected to increase by 0.1 percentage points of 
GDP in 2023. Nationally financed investment is 
projected to provide an expansionary contribution 
to the fiscal stance of 0.2 percentage points of 
GDP (51), whereas the growth in nationally 
financed primary current expenditure is projected 
to provide a contractionary contribution of 0.4 
percentage points to the overall fiscal stance in 
2023.  
The government-debt-to-GDP ratio is forecast by 
the Commission to increase to 42.8% in 2022 and 
44.0% in 2023, which is about 6 percentage points 
higher than in 2020, driven by the negative 
headline balance, being only partly offset by the 
robust nominal GDP growth. 
Debt sustainability risks appear medium over the 
medium term, as government debt is projected to 
increase to around 61% of GDP in 2032. This 
projection assumes that the structural primary 
balance (except for the impact of ageing) remains 
constant at the forecast level for 2023 of -2.5% of 
GDP, hence below the 2019 level.  
The sensitivity to possible macro-fiscal shocks also 
contributes to this assessment. In particular, if only 
half of the projected improvement in the structural 
primary balance in 2022–2023 were to occur, the 
projected debt ratio in 2032 would be almost 10 
percentage points of GDP higher than in the 
baseline.  
Some factors mitigate risks, including and the 
expected positive impact on long-term growth of 
reforms under the Recovery and Resilience Plan. 
In addition, Czechia’s negative net international 
investment position is contained, and this position 
is even positive when excluding non-defaultable 
instruments. Risk-increasing factors include the 
possible materialisation of state guarantees granted 
to firms and self-employed during the COVID-19 
crisis though this risk appears limited given the 
relatively low level and low take-up (52). 
The capacity of the Czech fiscal framework to 
ensure sustainable public finances is under test. 
(51) Other nationally financed capital expenditure is projected
to provide a neutral contribution. 
(52) For further details see the 2021 Fiscal Sustainability
Report. 
The act establishing the Czech fiscal rules was 
amended twice in 2020: the April amendment 
allowed for a larger structural deficit and a longer 
adjustment path, while the December 2020 
amendment corresponded to a “tax package”, 
which widened further the structural deficit. As the 
debt outlook has deteriorated, there is a higher risk 
that the threshold for triggering the debt brake (at 
55% of GDP) would be reached over the medium 
term. Moreover, the increase of the general 
government deficit over the forecast horizon is 
mostly due to permanent measures. Against this 
background and in line with its mandate, the Czech 
Fiscal Council found the 2020 budget compliant 
with the national fiscal rules and that the starting 
position for debt projections had significantly 
worsened the fiscal sustainability prospects over 
the long-term. The Committee on Budgetary 
Forecasts, tasked with assessing the 
macroeconomic and budgetary forecasts, 
confirmed the realism of the forecasts in all its 
2021 assessments. The local governments 
continued to have a positive albeit decreasing 
contribution to the general government balance in 
2020. Only six municipalities with debt above 60% 
of their average revenues over the previous four 
years had to take remedial action with respect to 
the debt reduction rule (53). Finally, a draft law 
amending Act No 166/1993 is currently under 
consideration to broaden the mandate of the 
Supreme Audit Office.  
3.4. EXCHANGE RATE STABILITY 
The Czech koruna does not participate in ERM II. 
Since the late 1990s, the ČNB has been operating 
an explicit inflation targeting framework combined 
with a de jure floating exchange rate regime, 
allowing for foreign exchange market 
interventions by the central bank (54). The ČNB is 
legally allowed to conduct foreign exchange 
interventions to influence the koruna exchange rate 
and moderate excessive exchange rate volatility in 
exceptional situations (e.g. in 2022). 
Following the expiry of the ČNB's exchange rate 
commitment in April 2017, the koruna followed a 
(53) Should the debt of a local authority exceed 60% of its
average annual revenues over the last four budget years,
the debt reduction rule implies that the local authority shall
reduce its debt in the following year by at least 5% of the
difference between the amount of its debt and 60% of its
average revenues over the last four budget years.
(54) Since 2010, the inflation target is set at 2% with a tolerance 
band of +/- 1%. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 95 –
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80 
gradual appreciation trend against the euro, 
strengthening from above 27 CZK/EUR in early 
April 2017 to 25.5 CZK/EUR in May 2018, around 
which level it oscillated until end of 2019. 
Following the lock-down measures taken in the 
early stages of the COVID-19 pandemic, the 
koruna depreciated significantly above 27 
CZK/EUR in March. It then oscillated between 26 
CZK/EUR and slightly above 27 CZK/EUR before 
entering an appreciation phase from late 2020 to 
reach 24.5 CZK/EUR early 2022. The appreciation 
was mostly driven by a sharp monetary tightening 
by the ČNB. However, in the wake of the Russia’s 
invasion of Ukraine the Czech koruna experienced 
strong depreciation pressures, which triggered 
short-lived stabilising interventions of the ČNB in 
the foreign exchange market in early March. In 
April 2022, the koruna was trading again around 
24.4 CZK/EUR. The ČNB has entered the foreign 
market around mid-May again to support the 
Czech koruna with the aim to limit its depreciation 
following the appointment of the new governor. 
The 3-month interest rate differential vis-à-vis the 
euro area decreased sharply by about 200 basis 
points in the months following the beginning of 
the COVID-19 pandemic to approach 70 basis 
points in spring 2020. The narrowing of the spread 
was the result of the substantial monetary policy 
easing in Czechia in response to the pandemic. 
Afterwards, the ČNB kept its policy rates 
unchanged and the three-month interest rate spread 
relative to the euro fluctuated between 80 and 90 
until June 2021. The subsequent strong tightening 
cycle by the ČNB from August 2021 led to a 
steady and large rise in the Czech 3-month 
PRIBOR and, accordingly, of the spread vis-à-vis 
the euro area which climbed up strongly and 
surpassed the mark of 580 basis points in April 
2022. 
International reserves held by the ČNB increased 
from EUR 133 billion at the end of 2019 (59% of 
GDP) to about EUR 157 billion (62% of GDP) at 
the beginning of 2022. The level of reserve assets 
was mainly influenced by a rise in returns on the 
ČNB’s securities and inflows of EU funds. 
3.5. LONG-TERM INTEREST RATES 
Long-term interest rates in Czechia used for the 
convergence examination reflect secondary market 
yields on a basket of government bonds with the 
average residual maturity of close to, but below, 10 
years.  
The Czech 12-month average long-term interest 
rate relevant for the assessment of the Treaty 
criterion was well below the reference value at the 
time of the last convergence assessment in 2020. 
Since then it has followed a gradual downward 
trend up to February 2021, followed by a rise to 
about 2.2% in early 2022. In April 2022, the 
reference value, given by the average of long-term 
interest rates in France, Finland, and Greece plus 
2 percentage points, stood at 2.6%. In that month, 
the 12-month moving average of the yield on the 
20
22
24
26
28
30
2016 2017 2018 2019 2020 2021
Graph 3.5: Czechia - CZK/EUR exchange rate
(monthly averages)
Source: ECB.
0
100
200
300
400
500
600
700
2016 2017 2018 2019 2020 2021
Graph 3.6: Czechia - 3-M Pribor spread to 3-M Euribor
(basis points, monthly values)
Source: Czech national Bank, Eurostat and Thomson Reuters.
0
2
4
6
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Czechia Reference value
Graph 3.7: Czechia - Long-term interest rate criterion
(percent, 12-month moving average)
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 96 –
Convergence Report 2022 - Technical annex 
Chapter 3 - Czechia 
81 
Czech benchmark bond stood at 2.5%, i.e. 0.1 
percentage points below the reference value. 
 
The long-term interest rate of Czechia fell in the 
first months of 2020 as the ČNB’s eased its 
monetary policy in response to the COVID-19 
pandemic. It reached a local through of 0.9% in 
summer 2020 before increasing slowly to about 
1.9% in Spring 2021. After a few months of 
oscillations around that level, it then rose rapidly 
to 2.6% in November 2021 and over 3% in early 
2022 to reach 4.0% in April 2022, in line with the 
ČNB’s sharp tightening of the monetary policy 
stance and a rapid increase in inflation. 
Consequently, the spread vis-à-vis the German 
long-term benchmark bond widened first by about 
90 basis points between summer 2020 and spring 
2021 and again by about 70 basis points between 
summer 2021 and early 2022 when it crossed 300 
basis points. In April, it came close to 330 basis 
points. 
3.6. ADDITIONAL FACTORS 
The Treaty (Article 140 TFEU) calls for an 
examination of other factors relevant to economic 
integration and convergence to be taken into 
account in the assessment. The assessment of the 
additional factors – including balance of payments 
developments, product, labour and financial 
market integration – gives an important indication 
of a Member State's ability to integrate into the 
euro area without difficulties. 
In December 2021, the Commission published its 
tenth Alert Mechanism Report (AMR 2022) under 
the Macroeconomic Imbalance Procedure (MIP – 
see also Box 1.7), which highlighted issues 
relating to competitiveness and pressures in the 
housing market in Czechia. However, since overall 
risks remained limited, no In-Depth Review (IDR) 
was warranted for that country. While considerable 
improvements in current accounts have been 
recorded in Czechia, nominal unit labour costs 
have increased significantly, on the back of strong 
wage rises and acute labour market shortages, 
although some deceleration is expected. At the 
same time, Czechia is exposed to risks relating to 
the trade policy environment (such as import of 
commodities, strong dependence on the German 
economy) and related disruption of global value 
chains (especially in car manufacturing). Real 
house price growth has remained elevated both in 
2020 and even accelerated in 2021. House prices 
appear to be overvalued in several regions in 
Czechia. The real house price index has continued 
the upward trend started in 2013, driven by supply 
constraints and strong demand. In 2021, it 
exceeded its 2015 level by about 61% (55). 
Czechia submitted its recovery and resilience plan 
on 1 June 2021. The Commission’s positive 
assessment on 19 July 2021 and Council’s 
approval on 8 September 2021 paved the way for 
the implementation of the RRP and the 
disbursement of EUR 7 billion in grants over the 
period 2021–2026, which is equivalent to 3.1% of 
2019 GDP. 
Czechia’s plan includes a set of mutually 
reinforcing reforms and investments (91 
investments and 33 reforms) that contribute to 
effectively addressing all or a significant subset of 
the economic and social challenges outlined in the 
country-specific recommendations (CSRs) 
addressed to Czechia by the Council in the 
European Semester in 2019 and 2020.  
The plan will address key macro-economic 
challenges such as technological changes, such as 
those posed by automation and the green 
transition, investment in research and 
development, new childcare facilities, and
upskilling and reskilling actions. Key investments are 
included on energy efficiency of buildings, digital 
skills and access to finance for companies. Key 
reforms are aimed at addressing the quality of 
public administration (including digitalisation), 
increasing the capacity of childcare facilities, 
improving access to and the resilience of the 
                                                          
(55) The very fast growth of house prices in real terms (almost 
11% p.a. since 2019) has been mostly driven by constraints 
of structural nature. The macroprudential regulation has 
been broadly appropriate; see ESRB, “Vulnerabilities in 
the real estate sectors of the EEA countries”, ESRB, 
Frankfurt, February 2022. 
-2
0
2
4
6
2016 2017 2018 2019 2020 2021
Czechia Germany
Graph 3.8: Czechia- Long-term interest rates
(percent, monthly values)
Source: Eurostat.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 97 – 
European Commission 
Convergence Report 2022 
82 
healthcare sector, improving education 
programmes, upgrading labour market services, 
supporting research activities and the introduction 
of innovation in firms. The business environment 
is being improved by several e-government 
measures, anti-corruption reforms, including 
strengthening the institutional and administrative 
framework linked to avoiding conflict of interest 
and a comprehensive reform of the procedure for 
granting building permits, which currently 
represent major obstacles to investment in 
Czechia. The plan devotes 42% of its total 
allocation to measures supporting climate 
objectives, 22% to the digital transition and 35% to 
social expenditure; all while respecting the do no 
significant harm principle.  
The implementation of the investments planned in 
Czechia’s plan, along with other investments under 
NextGenerationEU (NGEU), is estimated to raise 
Czechia’s GDP by 0.8% to 1.2% by 2026, of 
which 0.3% due to the positive spillover effects of 
the coordinated implementation of NGEU across 
Member States (Pfeiffer et al. 2021) (56). This does 
                                                          
(56) See Pfeiffer P., Varga J. and in’t Veld J. (2021), 
“Quantifying Spillovers of NGEU investment”, European 
not take into account the positive impact of 
structural reforms on growth.   
3.6.1. Developments of the balance of 
payments 
According to balance of payments data, Czechia’s 
external balance (i.e. the combined current and 
capital account) rose strongly in 2020, reaching 
3.2% of GDP before decreasing to 0.7% of GDP in 
2021. These developments in the external balance 
mostly mirror those of the current account surplus 
with the capital account remaining broadly stable 
at about 1.4% of GDP (57), following the below–
one-per-cent balance in previous few years. The 
trade surplus was strongly affected by the uneven 
impact of the COVID-19 pandemic on exports and 
imports: it increased strongly in 2020 before 
falling back in 2021. In contrast to previous years, 
                                                                                   
Economy Discussion Papers, No. 144 and Afman et al. 
(2021), “An overview of the economics of the Recovery 
and Resilience Facility”, Quarterly Report on the Euro 
Area (QREA), Vol. 20, No. 3 pp. 7–16. 
(57) In 2020, the current account recorded the highest surplus in 
the history of Czechia, both in absolute terms and relative 
to GDP. The main reason was a reduction of the deficit on 
primary income as a result of a massive drop in the outflow 
of income on direct investment of non-residents in Czechia. 
 
 
    
 
 
Table 3.4:
Czechia - Balance of payments (percentage of GDP)
2016 2017 2018 2019 2020 2021
Current account 1.8 1.5 0.4 0.3 2.0 -0.8
of which: Balance of trade in goods 5.4 5.1 3.7 4.1 4.9 1.2
                 Balance of trade in services 2.2 2.4 2.2 1.8 1.8 1.8
                 Primary income balance -5.3 -5.0 -4.8 -5.0 -4.3 -3.3
                 Secondary income balance -0.6 -1.0 -0.7 -0.6 -0.5 -0.5
Capital account 1.1 0.9 0.2 0.4 1.2 1.6
External balance 1) 2.9 2.4 0.7 0.8 3.2 0.7
Financial account 2.5 2.3 1.1 0.1 2.9 0.2
of which: Direct investment -3.9 -0.9 -0.9 -2.4 -2.6 -0.1
                Portfolio investment -3.5 -5.2 0.6 -1.8 -2.4 1.2
                Other investment 2) -1.8 -16.0 0.6 2.4 7.0 -5.8
                Change in reserves 11.7 24.4 0.9 1.9 0.8 4.8
Financial account without reserves -9.2 -22.1 0.2 -1.8 2.0 -4.7
Errors and omissions -0.3 -0.2 0.4 -0.6 -0.3 -0.5
Gross capital formation 26.0 26.4 27.2 27.6 25.9 30.1
Gross saving 25.8 27.2 26.6 26.7 28.4 27.8
Net international investment position -27.2 -24.9 -24.4 -19.8 -16.3 -15.6
1) The combined current and capital account.
2) Including financial derivatives.
Sources: Eurostat, European Commission calculations, Czech National Bank.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 98 – 
Convergence Report 2022 - Technical annex 
Chapter 3 - Czechia 
83 
net exports contributed negatively to economic 
growth in 2021. While net trade in services was 
broadly balanced (as a sudden drop associated with 
travel services was compensated with an increase 
in other services, such as ICT), net exports of 
goods were negative, in particular through supply 
shortages, longer delivery times and increased 
transportation cost, as well as through the 
deteriorated macroeconomic situation in the main 
trading partners. With record credits and debits, 
the capital account recorded the highest surplus 
since 2015. It was driven by a high growth in the 
utilisation of funds from the EU budget and a 
sharp drop in net payments for emission 
allowances (ETS). 
The crisis also temporarily affected the primary 
income balances (as a result of lower payments of 
factors of production to abroad) but left the 
secondary income balance broadly unchanged; the 
income balance as a whole stayed less negative 
compared to the pre-pandemic years. The capital 
account balance remained in surplus and increased 
to a level of about 1.2% of GDP in 2020 and 1.6% 
in 2021. A considerable net outflow of capital 
connected with the surplus on the current and 
capital accounts was evident on the financial 
account in 2020 (-0.2% of GDP), recovering in 
2021 (1.4% of GDP). The net international 
investment position slightly worsened in 2021, due 
to a faster accumulation of liabilities relative to 
assets, however, remained close to -16% as in 
2020. 
    
Measured by the export market share, the trade 
performance declined in 2020. In 2020–2021, 
measures of competitiveness exhibited different 
dynamics depending on the deflator used. The rate 
of appreciation of the real effective exchange rate 
(REER) deflated by ULC, accelerated, as labour 
hoarding pushed up labour costs. The appreciation 
in REER deflated by HICP has been more 
moderate, reflecting moderate price inflation until 
mid-2021. The swift acceleration of inflation at the 
end of 2021 has not caused a real appreciation
visà-vis the rest of the world, since inflation has 
picked up globally, including major trade 
partners (58). 
According to the Commission’s Spring 2022 
Economic Forecast based on national accounts 
data, the external balance is expected to contribute 
slightly negatively to GDP growth in 2022. 
However, as the external environment is expected 
to improve, the trade balance is set to increase in 
2023. 
3.6.2. Market integration 
The Czech economy is highly integrated with the 
euro area through trade and investment linkages, 
although the related indicators decreased during 
the reporting period. The trade openness of 
Czechia declined slightly in 2020 but remained 
very high at around 87% of GDP in 2021. The 
share of trade with euro area countries stood at 
around 53% of GDP in 2021 (51% in 2020). 
Neighbouring euro-area countries, such as 
Germany, Poland and Slovakia are among its most 
important trade partners. 
FDI inflows did not recover from a large drop 
recorded in 2020 (over 3% of GDP), followed by 
another decline of about 3% of GDP in 2021. 
Nevertheless, the stock of FDI inflows as 
percentage of GDP reached about 82% in 2021, 
despite labour market shortages and increasing 
wages. Austria, Belgium, France, the Netherlands 
and Switzerland are the biggest investor partners 
providing more than half of the FDI inflows as of 
end of 2021. Financial services, manufacturing, 
trade, hotels and restaurants are the main target 
sectors for FDI inflows. The geographical 
proximity to EU core markets, a relatively good 
infrastructure and a highly educated labour force 
have supported the attractiveness of the country for 
foreign investors. 
Czechia’s performance in international rankings of 
competitiveness and ease of doing business has 
been worsening over recent years and it is thus 
relatively weaker than in many euro-area Member 
States. In the IMD’s World Competitiveness 
                                                          
(58) The REER based on unit labour costs should be interpreted 
with prudence as unit labour costs were distorted by labour 
retention schemes in some countries, including Czechia. 
90
95
100
105
110
115
120
125
130
135
2016 2017 2018 2019 2020 2021
Graph 3.9: Czechia - Effective exchange rates
NEER REER, HICP deflated REER, ULC deflated
(vs. 36 trading partners;  monthly averages;
index numbers, 2016 = 100)
Source: European Commission.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 99 – 
European Commission 
Convergence Report 2022 
84 
Index, Czechia’s position is around the middle of 
the ladder and has worsened somewhat lately 
(from 33 in 2020 to 34 in 2021, from a total of 64 
surveyed economies), with attractiveness issues 
related to the effectiveness of the legal 
environment, the competency of the government 
and the quality of corporate governance.  
According to the World Bank's Ease of Doing 
Business indicator, Czechia maintained the same 
ranking in 2020, as in 2019, i.e. 41, but a relative 
worsening can be noticed with respect to 2018 or 
2017, when it ranked 35th and 30th 
respectively (59). 
Corruption remains an issue of concern in Czechia. 
Legal and institutional frameworks to address 
corruption are broadly in place, while the 
Government has prioritised some anti-corruption 
measures. A number of planned reform initiatives 
in the fight against corruption were not adopted 
(59) The World Bank Doing Business (DB) program was
paused in 2021. The programme will continue with a new
governance and improved accountability and transparency
under the name Business Enabling Environment (BEE).
The first edition of the BEE is expected in 2023. 
before the end of the parliamentary term in 2021, 
including reforms on lobbying, whistleblowing, 
the Supreme Audit Office mandate, and a code of 
conduct for members of Parliament (some 
measures are included in the Recovery and 
Resilience Plan). Concerns remain over cases of 
high-level corruption. 
According to the World Bank's Worldwide 
Governance Indicators (2020), Czechia ranks 
higher than the average of the five euro area 
Member States with the lowest scores for 
regulatory quality, political stability and absence 
of violence, rule of law and government 
effectiveness (60). 
According to the 2020 Single Market Scoreboard, 
Czechia's transposition deficit of EU Directives 
was at 1.1%, a stable result for the 3rd consecutive 
year, very close to the EU average (1%) and the 
target (0.5%) proposed by the European 
Commission in the Single Market Act (2011). 
The Czech Republic has taken steps to improve its 
Anti-Money Laundering and Countering the 
Financing of Terrorism (AML/CFT) framework. 
The Register on Beneficial Owners and the Central 
Register of Bank Accounts were established to 
improve transparency of beneficial owners and to 
provide quicker access to bank account 
information. The Czech authorities have achieved 
a substantial level of effectiveness in international 
(60) A Member State is considered to have a ‘low’ (‘high’)
ranking compared with the average five euro area Member
States with the lowest scores for each indicator if its score
is at least 0.3 percentage points lower (higher) than that of
the average of this euro area group. 
0.0
0.4
0.7
1.1
1.4
Voice and Accountability
Political Stability and Absence
of Violence/Terrorism
Government Effectiveness
Regulatory Quality
Rule of Law
Control of Corruption
Czechia Euro area average five lowest Euro area average
Graph 3.10: Czechia - 2020 World Bank's Worldwide Governance Indicators
Note: Estimate of governance ranges from -2.5 (weak) to 2.5 (strong). 
Source: World Bank.
Table 3.5:
Czechia - Market integration
2016 2017 2018 2019 2020 2021
Trade openness 1) (%) 88.8 90.1 89.0 86.0 83.2 86.8
Trade with EA in goods &amp; services 2)+3) (%) 54.9 55.6 54.4 52.5 50.5 53.1
World Bank's Ease of Doing Business Index rankings 4) 27 30 35 41 41 -
IMD World Competitiveness Ranking 5) 27 28 29 33 33 34
Internal Market Transposition Deficit 6) (%) 1.5 1.2 0.7 0.8 1.5 -
Real house price index 7) 106.8 116.5 123.4 131.0 138.3 160.6
 1) (Imports + Exports of goods and services / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics, Balance of Payments).
 2) (Imports + Exports of goods with EA-19 / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics).
 3) Trade in services with EA-19 (average credit and debit in % of GDP at current prices) (Balance of Payments).
 4) Data not available for 2021. The Ease of Doing Business report by the World Bank was discontinued in September 2021. 
 5) International Institute for Management Development (IMD).
 6) Percentage of internal market directives not yet communicated as having been transposed, relative to the total.
(November data, as of 2016 date refers to the year of publication).
 7) Deflated house price index (2015=100) (Eurostat). 
Sources: Eurostat, World Bank, International Institute for Management Development, European Commission calculations.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 100 –
Convergence Report 2022 - Technical annex
Chapter 3 - Czechia 
85 
cooperation; confiscation of proceeds and 
instrumentalities of crime; and FT investigations 
and prosecutions. On the other hand, the Czech 
Republic has achieved moderate results in the 
other areas covered by the FATF standards and its 
transposition of the 5th AMLD is still under 
assessment by the European Commission. 
The Czech labour market performed strongly in 
2020 and 2021. Despite a slight increase to 2.6% 
in 2020 and 2.7% in 2021, Czechia remained the 
best performer in terms of unemployment in the 
EU for the fourth year in a row. The employment 
rate of those aged between 20 and 64 reached 
79.7% in 2020, which was eight percentage points 
above the EU average. However, labour shortages 
are pervasive and hamper Czechia´s growth 
potential. The protection of permanent employees 
against collective and individual dismissals is 
relatively strict (as measured by the 2013 OECD 
employment protection indicator) whereas the 
duration of unemployment benefits is below the 
EU average. Cross-border migration flows have 
remained relatively subdued, although the tight 
labour market has started to attract workers from 
both EU and non-EU countries. 
The financial sector in Czechia continues to be 
smaller and somewhat less developed than in the 
euro area. Relative to GDP, assets managed by the 
financial sector are slightly above one third of that 
of the euro area, however, surpassing the five
euroarea Member States with the smallest financial 
sectors. The size of the financial sector has 
increased by about 45 percentage points since 
2016, reaching almost 260% of GDP in 2020. 
Banks dominate the Czech financial sector and 
make up around 52% of the financial sector’s 
assets in 2020. The central bank is the second 
largest holder of financial assets with a share of 
24% (more than double compared to the euro area 
average) and has exactly the same share as all
nonbanking financial intermediaries together. 
Although these shares are larger and more 
dominating than in the euro area, they compare 
well with the five euro-area Member States with 
the smallest financial sectors. 
The insurance and the pension-fund sectors in 
Czechia continues to be smaller (five-times) than 
in the euro area, relative to GDP. However, the 
sector’s share of the total financial sector is 
relatively comparable to that of the euro area. 
Since end-2016, the Czech sector has not changed 
its holdings of financial assets relative to GDP 
(slightly reducing its share in the Czech financial 
sector), compared to an increase by about 12 
percentage points in the euro area. The
investmentfunds sector plays a very small role in the Czech 
financial system, but its size is comparable to that 
of the five euro-area Member States with the 
smallest financial sectors. 
As to the financing of the economy, Czechia has 
less developed credit and equity markets relative to 
GDP than countries in the euro area, and market 
financing (especially debt securities and listed 
shares) is relatively under-developed. However, 
Czechia is still comparable to the five euro-area 
Member States with the smallest national capital 
markets. Loans are the dominant source of funding 
and make up 96% of GDP in 2020, compared to 
240% of GDP in the euro area. Unlisted shares and 
other equity are another important source of 
funding and stand at 70% and 63% of GDP in 
2020 (related to FDI), compared to 192% and 55% 
in the euro area respectively. The decrease of the 
share of trade credits and advances, the fourth 
Table 3.6:
Czechia - Allocation of assets by financial sub-sector
Ratio to GDP (%)
CZ EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Financial corporations (total) 215 259 722 796 177 215
Central bank 46 62 45 78 37 61
Monetary financial institutions 120 136 286 311 97 98
Other financial intermediaries 23 33 202 179 20 28
Non-MMF investment funds1) 7 10 100 127 4 5
Insurance co. and Pension Funds 19 19 90 102 18 23
Share of total (%)
CZ EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Central bank 21 24 6 10 21 29
Monetary financial institutions 56 52 40 39 55 46
Other financial intermediaries 11 13 28 22 11 12
Non-MMF investment funds 3 4 14 16 2 2
Insurance co. and Pension Funds 9 7 12 13 10 11
1) MMF stands for money market funds.
Source: Eurostat.
Table 3.7:
Czechia - Financing of the economy1)
Ratio to GDP (%)
CZ EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Liabilities (total) 341 341 743 770 324 335
Loans 94 96 238 236 115 112
Non-financial co. debt securities 7 6 12 15 3 4
Financial co. debt securities 15 20 74 68 11 12
Government debt securities 39 38 83 95 51 57
Listed shares 13 10 65 73 17 18
Unlisted shares 66 70 186 193 55 56
Other equity 61 63 51 56 42 48
Trade credits and advances 47 36 33 35 29 29
Share of total (%)
CZ EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Loans 28 28 32 31 35 33
Non-financial co. debt securities 2 2 2 2 1 1
Financial co. debt securities 4 6 10 9 3 3
Government debt securities 11 11 11 12 16 17
Listed shares 4 3 9 9 5 5
Unlisted shares 19 21 25 25 18 18
Other equity 18 19 7 7 13 14
Trade credits and advances 14 11 4 5 9 9
1) The table focuses on the financing needs of a country and how these are met by the financial system.
 The table is constructed from the liabilities of all economic sectors, but only considers loans, debt securities, 
equity and trade credits. The sum of liabilities in the table only reflects the total for the liabilities considered.
Source: Eurostat.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 101 –
European Commission 
Convergence Report 2022 
86 
source of private funding (36% of GDP), brings it 
at par with its euro area average counterpart. 
Financing through private debt markets remains 
low vis-à-vis their euro area counterparts, and also 
equity markets are very small compared to those of 
the euro area and represent 10% of GDP. This 
compares to 83% for private-sector debt and 73% 
for listed stocks in the euro area. Government debt 
is also lower than in the euro area. In terms of 
share of the sum of liabilities, loans in Czechia are 
comparable to that of the euro area, while trade 
credits and advances are higher than in the euro 
area. For security and equity financing, the large 
differences reflect the smaller share of market 
funding available in Czechia compared to the euro 
area. 
The Czech financial sector is highly integrated into 
the EU financial sector. This integration is 
noticeable in ownership linkages of the banking 
system. Foreign institutions held more than 90% of 
banking sector's assets via their local branches and 
subsidiaries in 2020. Concentration in the banking 
sector, as measured by the market share of the 
largest five credit institutions in total assets, edged 
up from almost 64% in 2018 to over 65% in 2020 
and thus continued to exceed the euro-area average 
of 53% by about 12 percentage points. 
Although intra-EU integration in equity and debt 
markets, as measured by the home bias in portfolio 
investments, are in general relatively low across 
EU Member States, Czechia is roughly comparable 
in terms of levels of integration of the low
euroarea Member State in equity markets (61). 
Integration in this market segment, has slightly 
worsened between 2016 and 2020. The very large 
(61) Home bias in portfolio investments measures the average
propensity of investors in a Member State to invest
domestically as compared with investing in other EU
countries. The indicator ranges between 0 and 1, with a
value of 0 indicating that investors prefer domestic over
foreign assets. The inverse of the home bias can be
interpreted as one measure of financial integration among
EU countries.
home bias indicates that an overwhelming majority 
of investments in equity markets does still take 
place domestically. Similarly, in case of debt 
markets, the home bias remains very strong in 
Czechia relative to euro-area Member States. The 
very large home bias indicates that most of the 
transactions in the debt market take place 
domestically. 
0
20
40
60
80
100
CZ, 2016 CZ, 2020 EA, 2016 EA, 2020
Concentration in the banking sector (CR5 ratio)
Share of foreign institutions as % of total assets
Graph 3.11: Czechia - Foreign ownership and concentration 
in the banking sector
(in percent, weighted averages)
Source: ECB, Structural financial indicators. 
0.0
0.2
0.4
CZ, 2016 CZ, 2020 EA, 2016 EA, 2020 EA Low,
2016
EA Low,
2020
Debt Equity
Graph 3.12: Czechia - Intra-EU integration in equity and debt portfolio 
investment
Note: The chart shows the extent of home bias in debt and equity markets. A value index 
of 1 implies ‘full integration’ with the financial markets of other Member States, while 0 
denotes ‘no integration’.
Source: FinFlows database: European Commission, Joint Research Centre (JRC). 
(index)
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 102 –
4. CROATIA
87 
4.1. LEGAL COMPATIBILITY 
4.1.1. Introduction 
The main legal rules governing the Croatian 
National Bank (Hrvatska narodna banka – HNB) 
are laid down in Article 53 of the Constitution of 
the Republic of Croatia (62) and the Act on the 
Croatian National Bank (the HNB Act) (63). The 
HNB Act was amended in 2013 with a view to 
Croatia entering the European Union on 1 July 
2013. The Act provides for specific rules applying 
to the HNB as of EU accession of Croatia and a 
specific chapter for rules applying to the HNB as 
of the moment the euro becomes the official 
currency of the Republic. The Act also contains 
provisions regarding the close cooperation of 
Croatia with the ECB for banking supervision 
purposes (64). Article 53 of the Constitution of the 
Republic of Croatia and the HNB Act have not 
been amended since the Commission’s 2020 
Convergence Report. 
4.1.2. Central Bank independence 
The principle of independence of the HNB is laid 
down in Article 53 of the Constitution and in 
Articles 2 (2) and 71 of the HNB Act. Article 71 of 
the HNB Act contains a specific reference to the 
principle of central bank independence as 
enshrined in the TFEU, stating that the HNB and 
members of its decision-making bodies shall be 
independent in achieving its objective and carrying 
out its tasks under the Act and relevant EU rules in 
accordance with Article 130 of the TFEU while 
adding that public authorities have to respect such 
independence. As regards the rules on a possible 
removal of the HNB Governor from office, Article 
81 of the HNB Act makes a specific reference to 
the relevant wording of Article 14.2 of the 
ESCB/ECB Statute. 
(62) Constitution as amended and published in the Official
Journal of the Republic of Croatia no. 56/90, 135/97,
113/2000, 123/2000, 124/2000, 28/2001, 55/2001 and
76/2010, 5/2014. 
(63) Official Journal of the Republic of Croatia no. 75/2008 and
54/2013. 
(64) Decision (EU) 2020/1016 of the European Central Bank of
24 June 2020 on the establishment of close cooperation
between the European Central Bank and Hrvatska Narodna
Banka (ECB/2020/31). 
No incompatibilities and imperfections exist in this 
area. 
4.1.3. Prohibition of monetary financing and 
privileged access 
No incompatibilities and imperfections exist in this 
area. The rules on prohibition of lending to the 
public sector pursuant to Article 78 of the HNB 
Act include a specific reference to the prohibition 
of monetary financing as laid down in Article 123 
of the TFEU. 
4.1.4. Integration in the ESCB 
Objectives 
The objectives of the HNB are laid down in 
Articles 3 and 72 of the HNB Act and are fully 
compatible with the objectives applying to the 
European System of Central Banks pursuant to 
Article 127 of the TFEU. 
Tasks 
The provisions under chapters VIII and IX of the 
HNB Act define the tasks the HNB has to carry out 
as integral part of the European System of Central 
Banks pursuant to the rules of the TFEU and the 
ESCB/ECB Statute. No incompatibilities exist 
with regard to these tasks. 
4.1.5. Assessment of compatibility 
The Constitution and the Act on the Croatian 
National Bank are fully compatible with Articles 
130 and 131 of the TFEU. 
4.2. PRICE STABILITY 
4.2.1. Respect of the reference value 
The 12-month average inflation rate, which is used 
for the convergence assessment, was below the 
reference value at the time of the 2020 
convergence assessment of Croatia. From then, it 
decreased to reach to -0.2 % in February 2021 
before shifting again to an upward trend. In April 
2022, the reference value was 4.9%, calculated as 
the average of the 12-month average inflation rates 
in France, Finland and Greece, plus 1.5 percentage 
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88 
points. The corresponding inflation rate in Croatia 
was 4.7%, i.e. 0.2 percentage points below the 
reference value. The 12-month average inflation 
rate is projected to remain below the reference 
value in the months ahead. 
4.2.2. Recent inflation developments 
In 2021, the annual HICP inflation rate averaged 
2.7%, significantly higher than in 2020, when it 
averaged 0%. The increase was mostly due to 
rising energy prices, which grew by 8.8% in 2021, 
after falling by 6.5% in 2020 in average yearly 
terms. Price increases in the services sector also 
contributed to the higher headline inflation, with 
service inflation averaging 2% in 2021 after 0.8% 
2020. Processed food (including alcohol and 
tobacco) inflation averaged 3% in 2021, rising 
from a 2.1% average recorded in 2020. The 
inflation rate of unprocessed food and non-energy 
industrial goods remained subdued, below 1% in 
2021. In April 2022, the inflation rate accelerated 
to 9.6% year-on-year, with the strongest 
contributions coming from energy and processed 
food prices, which increased by 23.1% and 22.9% 
and contributed by 3.0 and 2.3 percentage points to 
headline inflation, respectively. The April inflation 
rate in Croatia was above euro area average, where 
prices increased by 7.4%. This puts the average 
inflation rate in the trailing twelve months through 
April 2022 at 4.7% in Croatia, just above the EA 
average of 4.4%. 
In 2021, the average core inflation rate (measured 
as the growth of HICP excluding energy and 
unprocessed food) accelerated to 1.8%, from 0.8% 
in 2020. In April 2022, core inflation rate stood at 
7.3%, further accelerating compared to previous 
months. This figure was higher than the euro area 
average (3.9%), due to a stronger recovery from 
the COVID-19 crisis in Croatia together with the 
stronger growth of processed food prices, which 
also have a stronger weight in Croatia compared to 
euro area. The overall contribution of processed 
food prices to the core inflation rate stood at 2.8 
percentage points.  
4.2.3. Underlying factors and sustainability of 
inflation 
Macroeconomic policy mix and growth 
developments 
Economic developments in 2021 point to a V-
shaped recovery of the Croatian economy. After a 
drop of 8.1% in 2020, real GDP recorded a yearly 
growth of 10.2% in 2021, bringing output above its 
pre-pandemic level. Looking at the GDP 
components, the recovery in 2021 was supported 
by exports of goods and services – with tourism 
playing a key role – and by private consumption. 
Strong growth of final demand spurred imports 
growth, but the overall growth contribution of net 
exports was positive. 
According to the Commission’s Spring 2022 
Economic Forecast, GDP growth in 2022 is 
forecast at 3.4%, due to rising inflationary 
pressures and other indirect effects of Russia’s 
invasion of Ukraine. Private consumption is 
expected to grow by 2.4%, driven by the expected 
implementation of the RRP and the acceleration of 
earthquake-related-reconstruction investment 
should remain strong, rising by 6.5%, in spite of 
the rising costs of materials, potential supply 
bottlenecks and rising uncertainty, Government 
consumption should continue to contribute 
positively to growth. On the external side, weaker 
demand in main trading partners is expected to 
affect goods exports, but the growth rate should 
remain solid 5.3%. Growth rate of exports of 
services should be mostly driven by tourist 
-2
0
2
4
6
8
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Croatia Reference value
Graph 4.1: Croatia - Inflation criterion
(percent, 12-month moving average)
Note: The dots at the right end of the chart show the projected reference 
value and 12-month average inflation rate of the country in December 2022.
The reference values for 2016, 2018 and 2020 refer to the reference values 
calculated in the previous Convergence Reports.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
-4
-2
0
2
4
6
8
10
12
2016 2017 2018 2019 2020 2021
Croatia Euro area
Graph 4.2: Croatia - HICP inflation
(y-o-y percentage change)
Source: Eurostat.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 104 –
Convergence Report 2022 - Technical annex 
Chapter 4 - Croatia 
89 
activity, which is expected to converge towards 
pre-crisis levels in spite of current global 
developments. Import dynamics should follow 
developments of final demand and overall 
contribution of net exports to growth in 2022 is 
expected to be mildly positive. 
In 2020-2021, the government’s policy response to 
the COVID-19 crisis provided significant support 
to the healthcare sector, households and companies 
hit by the pandemic, including incentives to retain 
the workforce. This response was facilitated by 
new European instruments like loans from SURE 
(Support to mitigate Unemployment Risks in an 
Emergency) and grants from Next Generation 
EU/RRF. In 2021, the fiscal stance (65) remained 
supportive (-0.2 percentage point of GDP, after -
2.3 percentage points of GDP in 2020), based on 
the Commission’s Spring 2022 Economic 
Forecast. The fiscal stance is expected to remain 
supportive in 2022 (-1.8 percentage points of 
GDP) partly due to the expenditure financed 
through the RRF and other EU grants and 
temporary support to mitigate the impact of high 
energy prices on vulnerable households and firms. 
Net nationally-financed primary current 
expenditure in 2022 is projected to provide an 
expansionary contribution of 1.0 percentage point 
of GDP to the overall fiscal stance. The budgetary 
costs related to refugees from Ukraine is assumed 
at 0.1 percentage point of GDP. The forecast for 
(65) The fiscal stance is measured as the change in primary
expenditure (net of discretionary revenue measures),
excluding Covid-19 crisis-related temporary emergency 
measures but including expenditure financed by
nonrepayable support (grants) from the Recovery and
Resilience Facility and other EU funds, relative to
mediumterm potential growth. A negative (positive) sign of the
indicator corresponds to an excess (shortfall) of primary
expenditure growth compared with medium-term economic
growth, indicating an expansionary (contractionary) fiscal
policy.
2023 shows a further supportive stance (-0.7 
percentage point of GDP) due to the increasing 
expenditure financed by RRF and other EU grants 
and despite the assumed phasing out of energy 
crisis measures. Net nationally-financed primary 
current expenditure is projected to have a broadly 
neutral contribution to the fiscal stance of -0.2 
percentage point of GDP. 
In 2020, the HNB took a range of measures to 
ensure the stability of the financial sector in the 
aftermath of COVID-19 pandemic. The Croatian 
central bank used various standard and
nonstandard measures, including purchases of 
government bonds on the secondary market, direct 
purchases of foreign currency from the Ministry of 
finance, sales of foreign currency on the FX 
market and a cut in reserve requirement ratio (66). 
The HNB also agreed upon establishing a 
precautionary currency swap line with the ECB in 
April 2020. The currency swap line allows for the 
exchange of the kuna for up to EUR 2bn that could 
be used to provide additional euro liquidity to 
Croatian financial institutions without using the 
HNB own international reserves, if needed. While 
the swap line was initially set to expire on 31 
December 2020, it had been extended thereafter to 
31 March 2022. The HNB continued to pursue 
accommodative monetary policy throughout 2021, 
ensuring high levels of liquidity in the banking 
system and simultaneously maintaining a broadly 
stable exchange rate of the kuna against the euro. 
(66) Croatian National Bank (2021). Tri desetljeća izazova, 
brochure prepared for the celebration of the 30th
anniversary of CNB.
Table 4.1: weights  
Croatia - Components of inflation (percentage change)1) in total   
2016 2017 2018 2019 2020 2021 Apr-22 2022
HICP -0.6 1.3 1.6 0.8 0.0 2.7 4.7 1000
Non-energy industrial goods 0.6 0.7 0.3 -0.2 -0.2 0.6 2.4 266
Energy -5.7 -0.1 5.6 0.9 -6.5 8.8 13.5 132
Unprocessed food -0.9 2.9 0.2 -4.0 3.1 1.0 5.3 59
Processed food 0.2 2.6 1.4 2.0 2.1 3.0 5.3 229
Services 0.0 1.2 1.4 1.5 0.8 2.0 2.6 315
HICP excl. energy and unproc. food 0.2 1.4 1.1 1.1 0.8 1.8 3.3 809
HICP at constant tax rates -0.8 1.2 1.5 1.4 0.3 2.4 4.6 1000
Administered prices HICP -1.0 -0.3 1.2 1.4 0.1 1.9 2.3 123
1) Measured by the arithmetic average of the latest 12 monthly indices relative to the arithmetic average of the 12 monthly indices
in the previous period.
Source: Eurostat, European Commission calculations.
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Wages and labour costs 
After a sharp economic downturn caused by the 
COVID-19 pandemic in 2020, the labour market 
recovered in 2021. Thanks in part to the 
government labour support schemes and liquidity 
measures, employment levels in 2021 were the 
same as those registered in 2019. Meanwhile, 
changes in the active population brought about by 
more accurate population statistics led to a 1.5 
percentage points increase in the employment rate. 
However, the employment dynamics varied across 
sectors. Due to the measures put in place to curb 
COVID-19 transmission, activities characterised 
by close social contact were the most affected, e.g. 
accommodation and food services. The 
unemployment rate stood at 7.6% in 2021, 1 
percentage point above the all-time low reached in 
2019. Continued employment growth and 
demographic trends in 2022 and 2023 are expected 
to bring the unemployment rate to 6.0% by the end 
of 2023. 
Relatively strong wage growth in 2020-2021 can 
largely be attributed to the employment support 
measures and personal income tax cuts. Subdued 
nominal unit labour costs (ULC) dynamics in 2021 
partially offset the increase registered in 2020, as 
productivity growth outpaced nominal 
compensation per employee growth (8.9% vs. 
5.6%) (67). However, a tighter labour market and 
continued wage growth will result in a slight rise 
in ULC in 2022 and 2023. As a result, risks of 
second-round effects of wages on inflation are 
expected to be limited. 
          
External factors 
After falling mildly by 0.3% in 2020, import price 
inflation (measured by the deflator of imports of 
goods) accelerated to 7.4% in 2021. This change 
mainly reflected increasing energy price 
                                                          
(67) However, it is important to emphasize that unlike many 
other countries Croatia recorded a strong fall of 
productivity based on hours of work in 2020, as employers 
in Croatia recorded full time hours despite the fact that 
workers were not working or they were working less hours. 
-8
-4
0
4
8
12
2016 2017 2018 2019 2020 2021 2022 2023
Productivity (real GDP per person employed)
Nominal compensation per employee
Nominal unit labour costs
HICP inflation
Graph 4.3: Croatia - Inflation, productivity and wage trends
(y-o-y % change)
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
 
 
           
 
 
Table 4.2:
Croatia - Other inflation and cost indicators (annual percentage change)
2016 2017 2018 2019 2020 2021 20221) 20231)
HICP inflation
Croatia -0.6 1.3 1.6 0.8 0.0 2.7 6.1 2.8
Euro area 0.2 1.5 1.8 1.2 0.3 2.6 6.1 2.7
Private consumption deflator
Croatia -1.1 0.9 1.4 1.1 0.3 2.7 6.0 2.5
Euro area 0.4 1.3 1.5 1.1 0.5 2.3 5.8 2.7
Nominal compensation per employee
Croatia 0.3 0.2 3.9 0.4 2.1 5.6 3.0 2.7
Euro area 1.2 1.7 2.1 2.1 -0.7 4.1 3.6 3.5
Labour productivity
Croatia 3.3 0.9 0.3 0.4 -7.0 8.9 1.8 1.1
Euro area 0.4 1.0 0.2 0.3 -4.9 4.2 1.4 1.5
Nominal unit labour costs
Croatia -2.8 -0.7 3.6 0.0 9.8 -3.1 1.1 1.5
Euro area 0.8 0.7 2.0 1.9 4.4 0.0 2.2 2.0
Imports of goods deflator
Croatia -2.5 2.6 1.1 0.2 -0.3 7.4 8.0 4.0
Euro area -3.3 3.3 2.6 -0.5 -3.8 9.6 13.2 0.8
1) Commission Spring 2022 Economic Forecast.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 106 – 
Convergence Report 2022 - Technical annex 
Chapter 4 - Croatia 
91 
developments. Pressures on import prices were 
somewhat offset by a mild appreciation of the 
kuna, which had a dampening effect on domestic 
prices. 
Administered prices and taxes 
The weight of administered prices in the Croatian 
HICP basket increased from 20% in 2020 to 28% 
in 2021. This change can be partially explained by 
the government decision to put a cap on gasoline 
prices at the end of 2021. In 2021, administered 
prices grew at 1.9% compared to a 2.7% rise in the 
overall price level. 
As of 1 April 2022, administered prices of gas and 
electricity for households increased, following a 
surge of international energy prices since the 
summer of the previous year. Consequently, the 
average price of electricity for households 
increased by around 10% and that of gas by around 
16%. In April 2022 administered prices 
accelerated to 3.6% on yearly basis, up from 
average 1.9% in Jan-Mar period. 
Medium-term prospects 
After reaching 2.7% in 2021, HICP inflation is 
expected to accelerate to 6.1% in 2022. Thus, 
inflation in Croatia is expected to be in line with 
the expected inflation in the euro area in 2022, in 
some parts reflecting the various measures taken 
by the Croatian government since the end of 2021 
to tame the inflationary pressures coming from 
rising energy and food prices. These measures 
include cuts in the VAT rate for gas and various 
non-energy products, reduction of fees of
stateowned electrical distributer (HEP) and direct 
transfers to vulnerable households and SMEs. In 
2023, inflation should decelerate to around 2.7%, 
mostly supported by expected decline on 
international commodity prices. 
Risks to the inflation outlook are skewed to the 
upside, due to uncertainties related to 
developments on international commodity 
markets, supply chain bottlenecks and to the 
increases of administered prices mentioned above. 
The price level in Croatia stood at 67% of the 
euro-area average in 2020. There is a potential for 
gradual price level convergence in the long term. 
However, it should be noted that Croatia has 
already achieved the highest level of price 
convergence with the euro area compared to other 
member states at the moment of their euro 
accession. 
Medium-term inflation prospects are largely 
expected to depend on price developments on 
global commodity and food markets. In particular, 
in line with Croatia’s deepening integration in EU 
value chains, domestic price developments should 
primarily be affected by price developments in its 
main trading partners (Austria, Slovenia, Italy and 
Germany). Inflation cycles in Croatia are already 
highly synchronised with the inflation cycle of the 
euro area and wage developments are expected to 
continue to underpin this synchronisation. As for 
idiosyncratic factors, RRP-related investments and 
reforms could also be important driver of price 
developments but are expected to have a muted if 
not disinflationary effect on the Croatian economy 
in the long run. On the one hand, RRP investments 
will boost aggregate demand in the economy, 
which could put some upside pressures on prices in 
the short term. On the other hand, many reforms 
(e.g. reduction of administrative burden and
parafiscal charges, deregulation of services etc.) could 
enhance competition on the market and reduce 
costs for companies, thus putting some downward 
pressures on prices of final products in the long 
run. 
4.3. PUBLIC FINANCES 
4.3.1. Recent fiscal developments 
After a surplus in 2019, the general government 
balance turned into a deficit in 2020 (7.3% of 
GDP) due to the COVID-19 crisis. The deficit in 
2020 was directly impacted by the COVID-19 job 
preservation support, different measures for 
companies and expenditure on medical supplies. 
These measures amounted overall to around 3.3% 
of GDP. After a strong increase in 2020 (8.7%), 
total expenditures further increased by 2.8% in 
2021. Most notably, subsidies to companies and 
social expenditures grew on account of the 
COVID-19 support measures. Despite a substantial 
accumulation of new debt during the crisis, interest 
expenditure decreased in 2020 and 2021 as 
maturing debt was refinanced at lower interest 
rates. Total revenues remained stable as a share of 
GDP between 2019 and 2021, supported by the 
increase in EU grants (from 1.5% to 2.7% of 
GDP). 
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The 2021 general government deficit was 2.9% of 
GDP. The improvement relative to 2020 is mainly 
explained by the strong economic recovery and the 
decreasing impact of the COVID-19 temporary 
emergency measures, which are estimated to have 
amounted to 2.1% of GDP. The 2021 deficit 
outturn was significantly lower than the 3.8% of 
GDP estimated in the 2021 Convergence 
programme, mainly on account of a lower than 
expected investment spending. 
After increasing by more than 16 percentage points 
to over 87% of GDP in 2020, the public debt-to-
GDP ratio decreased to slightly below 80% in 
2021. Debt dynamics in 2021 was driven by the 
solid GDP recovery, which largely offset the
debtincreasing impact of interest expenditure and the 
primary deficit, with an overall debt-decreasing 
snow-ball effect of more than 9% of GDP (after 
+8.4% in 2020). The stock-flow adjustment
provided a marginal debt-increasing impact in
2021 (after +2.5% in 2020).
4.3.2. Medium-term prospects 
The 2022 budget was adopted by the Parliament on 
8 December 2021. Based on the expectation of a 
general government deficit of 4.5% of GDP in 
2021, the budget foresaw a deficit of 2.6% of GDP 
in 2022. The 2022 budget envisaged a withdrawal 
of temporary emergency measures. However, 
considering the effects of the COVID-19 Omicron 
variant, some measures to retain jobs have been 
kept in place for the first part of the year. In light 
of the rising prices in energy products, the 
Government adopted measures to help the 
households and companies to cope with the 
economic and social impact of rising prices. After 
freezing the petrol and diesel prices already at the 
end of 2021, authorities temporarily cut excise 
duties on petrol and diesel in March 2022 until end 
of May. On the top of these measures, the 
authorities adopted on 9 March 2022 a 
comprehensive set of measures, effective as of 1 
April amounting to 1% of GDP. This package 
includes a temporary reduction of VAT on gas 
from 25% to 5% (from April 1st 2022 to March 31st 
2023) and a permanent reduction of the VAT rate 
on electricity, gas (after March 2023 VAT rate on 
gas will remain at 13% versus previous 25%), 
heating, pellet, wood chippings and firewood, and 
support measures designed for population and 
companies. The package also includes a permanent 
cut of VAT rates on non-energy products, 
including food, hygienic products and tickets for 
sport and cultural events. There are also temporary 
support measures (until end of March 2022) for 
households and companies to help alleviate part of 
the increase in energy prices. 
On 29 April 2022, Croatia submitted its 2022 
Convergence Programme, in line with Article 4 of 
Regulation (EC) No 1466/97. The government 
projects real GDP to grow by 3% in 2022 and 
4.4% in 2023. By comparison, the Commission’s 
Spring 2022 Economic Forecast projects a higher 
real GDP growth of 3.4% in 2022 and a lower 
growth of 3.0% in 2023. The difference between 
Table 4.3:
Croatia - Budgetary developments and projections (as % of GDP unless indicated otherwise)
Outturn and forecast 1) 2016 2017 2018 2019 2020 2021 20221) 20231)
General government balance -0.9 0.8 0.0 0.2 -7.3 -2.9 -2.3 -1.8
- Total revenue 45.9 45.5 45.5 46.3 47.2 46.4 46.4 46.7
- Total expenditure 46.9 44.7 45.5 46.1 54.5 49.2 48.6 48.5
of which:
- Interest expenditure 3.1 2.6 2.3 2.2 2.0 1.6 1.4 1.3
p.m.: Tax burden 37.3 37.2 37.5 37.6 37.0 36.2 35.9 35.9
Primary balance 2.1 3.4 2.3 2.4 -5.3 -1.3 -0.9 -0.5
Fiscal stance 2) -1.8 -0.2 -1.8 -0.7
Government gross debt 79.8 76.7 73.3 71.1 87.3 79.8 75.3 73.1
p.m: Real GDP growth (%) 3.5 3.4 2.9 3.5 -8.1 10.2 3.4 3.0
1) Commission’s Spring 2022 Economic Forecast.
2) A negative (positive) sign of the indicator corresponds to an excess (shortfall) of primary expenditure growth
compared with medium-term economic growth, indicating an expansionary (contractionary) fiscal policy.
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 108 –
Convergence Report 2022 - Technical annex 
Chapter 4 - Croatia 
93 
the two forecasts comes from a lower expectation 
by the Croatian authorities concerning growth in 
real household consumption in 2022. The 
Government expects in the Convergence 
Programme that the headline deficit will slightly 
decrease to 2.8 % of GDP in 2022, mainly 
reflecting the growth in economic activity and the 
unwinding of most emergency measures. Due to 
Russia’s invasion of Ukraine, the Croatian 
authorities expect around twenty thousand 
refugees and an increase in expenditure related to 
costs of accommodation, food, education, social 
welfare and health care. Thereafter, the 
government deficit is expected to gradually decline 
to 1.6% of GDP in 2023, 1.6% of GDP in 2024 
and to 1.2% by 2025. Therefore, the general 
government deficit is planned to remain below 3% 
of GDP over the programme horizon. Compared to 
the Commission’s Spring 2022 Economic 
Forecast, these deficit projections are higher in 
2022 and lower in 2023, mainly due to a lower 
level of expenditure expected by the Commission 
in 2022 for gross fixed capital formation and other 
expenditure. Furthermore the Commission’s 
forecast entails somewhat lower level shift in both 
revenues and expenditures compared to the 
Convergence Programme attributed to a difference 
in the inflation outlook, where government’s 
inflation projection is notably higher than that of 
the Commission.  
The Commission’s Spring 2022 Economic 
Forecast expects the headline deficit to narrow 
further to 2.3% of GDP in 2022 and to 1.8% in 
2023 as revenues are expected to grow strongly on 
the back of the economic recovery and the support 
from the RRF for investments, while COVID-19 
temporary emergency measures are expected to be 
completely phased out.  
In 2022, the fiscal stance is projected in the 
Commission’s Spring 2022 Economic Forecast to 
continue to be supportive, at -1.8 percentage points 
of GDP (68). The additional positive contribution 
to economic activity of expenditure financed by 
the Recovery and Resilience Facility grants and 
other EU funds is projected at 0.5 percentage point 
of GDP in 2022, after 0.3 percentage point of GDP 
in 2021. Nationally financed investment is 
projected to provide a expansionary contribution to 
the fiscal stance in 2022 of 0.4 percentage point. 
At the same time, the growth in nationally 
                                                          
(68) For a definition of the fiscal stance used in this report, see 
footnote in Section 4.2.3 on underlying factors and 
sustainability of inflation. 
financed primary current expenditure (net of 
discretionary revenue measures) in 2022 is 
projected to provide an expansionary contribution 
of 1.0 percentage point of GDP to the overall fiscal 
stance, as current expenditure is set to grow at a 
faster pace than medium-term potential growth. 
However, most of this expansion is due to 
measures related to the energy crisis (0.4 
percentage point of GDP) and the assistance to 
those fleeing Ukraine (0.1 percentage point of 
GDP). 
In 2023, the fiscal stance is projected at -0.7 
percentage point of GDP. The additional positive 
contribution to economic activity of expenditure 
financed by Recovery and Resilience Facility 
(RRF) grants and other EU funds is projected at 
0.5 percentage point of GDP in 2023. Nationally 
financed investment is projected to provide a 
slightly expansionary contribution to the fiscal 
stance of 0.1 percentage point of GDP (69). The 
growth in nationally financed primary current 
expenditure (net of discretionary revenue 
measures) is projected to provide a broadly neutral 
contribution of -0.2 percentage point of GDP to the 
overall fiscal stance in 2023 as part of the support 
measures to face the energy crisis in 2022 are 
assumed to be phased out. 
Debt sustainability risks appear medium over the 
medium run. Government debt is projected to 
remain on a downward path until 2026 but increase 
again afterwards, reaching around 69% of GDP in 
2032. This projection assumes that the structural 
primary balance (except for the impact of ageing) 
remains constant at the forecast level for 2023 of - 
1.0% of GDP, hence below the 2019 level.  
The sensitivity to possible macro-fiscal shocks 
contributes to this assessment. In particular, if the 
interest-growth rate differential were permanently 
1 percentage point higher than in the baseline, this 
would lead to a higher debt ratio by about 5 
percentage points of GDP by 2032 compared with 
the baseline and put debt on a steeper increasing 
path.  
Some factors mitigate risks, including the 
lengthening of debt maturity in recent years and 
relatively stable financing sources (with a 
diversified and large investor base) and the 
expected positive impact on long-term growth of 
reforms under the recovery and resilience plan. 
                                                          
(69) Other nationally financed capital expenditure is projected 
to provide a neutral contribution. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 109 – 
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94 
Risk-increasing factors include Croatia’s negative 
net international investment position and the 
recently evidenced decline in population (70). 
The Croatian fiscal framework has been 
significantly strengthened recently, largely thanks 
to the transposition of outstanding requirements of 
the Council Directive on Budgetary Frameworks 
(2011/85/EU). The New Budget Act adopted in 
December 2021 brought, inter alia, significant 
improvements with regard to the forecasting 
process and the consistency and level of detail of 
the medium-term fiscal plans. Requirements for 
the publication of forecast methodologies and 
assumptions, comparisons with independent 
forecasts (i.e., the European Commission’s 
forecast) and sensitivity analysis contribute to 
making the forecasting process more transparent 
and robust. Likewise, multi-annual budgetary 
objectives that are specified in more detail and 
with a clearer link to the annual budget process are 
bound to strengthen the medium-term orientation 
of fiscal policy. In particular, a new dedicated 
document (i.e. a Government Decision) will 
translate the multiannual objectives set in the 
Convergence Programme into specific limits for 
budgetary users that can be used in the annual 
budget process. Finally, the chair of the Fiscal 
Policy Commission – the independent fiscal 
council set-up since 2018 – was eventually 
nominated in late 2021, following several failed 
attempts. 
4.4. EXCHANGE RATE STABILITY 
The HNB operates de jure a managed floating 
exchange rate regime, using the exchange rate 
against the euro as the main nominal anchor to 
(70) For further details see the 2021 Fiscal Sustainability
Report. 
achieve its primary objective of price stability. The 
HNB does not target a specific level or band for 
the kuna exchange rate against the euro but, 
through its foreign exchange transactions, it aims 
to prevent excessive exchange rate fluctuations. 
The Croatian kuna joined ERM II on 10 July 2020 
and observes a central rate of 7.53450 to the euro 
with a standard fluctuation band of ±15%. Upon its 
ERM II entry, Croatia committed to implement a 
set of policy measures, the so-called post-entry 
commitments, with the aim of achieving a high 
degree of sustainable economic convergence ahead 
of the euro adoption. The commitments cover four 
policy areas: the anti-money laundering 
framework, the business environment, state-owned 
enterprises (SOEs) and the insolvency framework. 
The kuna depreciated against the euro by up to 2% 
in the first two months of the pandemic in March 
and April 2020. Since joining the ERMII, the kuna 
has fluctuated in a narrow band of less than +/-1% 
against its central rate against the euro. The kuna's 
exchange against the euro has continued to exhibit 
a seasonal pattern of temporary appreciation in the 
summer thanks to foreign currency inflows related 
to the tourism sector. In the last two years, it 
usually went below the central rate against the euro 
in the summer months and moved just above it in 
the remaining months of each year. 
International reserves held by the HNB stood at 
EUR 25 billion (or 44% of GDP) at the end of 
2021. After declining by about EUR 2 billion in 
the first quarter of 2020 due to the foreign 
exchange interventions conducted by the NHB to 
maintain the stability of kuna exchange rate 
against the euro in midst of the pandemic-induced 
crisis, international reserves increased to close to 
EUR 19 billion at the end of the year. The HNB’ 
international reserves rose by about EUR 6 billion 
in 2021. This increase was due to larger inflows of 
-3
-2
-1
0
1
2
2020 2021 2022 2023
Net nationally financed  primary current expenditure Nationally financed investment
Other capital expenditure Expenditure financed by RRF grants and EU funds
Fiscal stance
Expansionary
Contractionary
Graph 4.4: Croatia - Fiscal stance and its components
Source: Commission's Spring 2022 Economic Forecast. 
(percent of GDP)
7.0
7.2
7.4
7.6
7.8
8.0
2016 2017 2018 2019 2020 2021
Graph 4.5: Croatia - HRK/EUR exchange rate
(monthly averages)
Source: ECB.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 110 –
Convergence Report 2022 - Technical annex 
Chapter 4 - Croatia 
95 
foreign currency to the government account from 
EU funds and RRP pre-financing an increased 
volume of repo transactions, and a new allocation 
of special drawing rights with the International 
Monetary Fund (IMF). 
      
As foreign exchange interventions are the main 
monetary policy instrument, the HNB does not 
frequently change interest rates on its lending and 
deposit facilities and developments in the
shortterm rates mainly reflects changes in kuna liquidity 
in the banking system. Following the decision of 
the Croatian Banking Association to discontinue 
the calculation of the Zagreb Interbank Offered 
Rate (Zibor) benchmarks at the end of December 
2019, the HNB has started to publish a new 3-
month national reference rate (NRR) on a quarterly 
basis since the end of the first quarter of 2020. The 
NRR is a rate representing the average funding 
expenses of the Croatian banking sector (banks, 
savings banks and branches of foreign banks). The 
3-month NRR stood at 0.20% in the first quarter of 
2020 and declined very gradually thereafter 
throughout 2020 and 2021, mostly in line with 
developments in the 3-month Euribor rate. As a 
result, the interest rate differential of the 3-month 
NRR against the 3-month Euribor rate was broadly 
flat, averaging about 60 basis points over the 2020-
2021 period. 
4.5. LONG-TERM INTEREST RATES 
The long-term interest rates in Croatia used for the 
convergence assessment reflect the secondary 
market yield on a single benchmark government 
bond with a residual maturity of about 7.5 years. 
The Croatian 12-month average long-term interest 
rate relevant for the assessment of the Treaty 
criterion was below the reference value at the time 
of the 2020 convergence assessment of Croatia. 
After having stabilised around those levels in the 
remaining months of 2020, it declined very 
gradually throughout 2021, standing just below 
0.5% in December, before starting to rise gradually 
in the first months of 2022. In April 2022, the 
reference value, given by the average of long-term 
interest rates in France, Finland and Greece, plus 2 
percentage points, stood at 2.6%. In that month, 
the 12-month moving average of the yield on the 
Croatian benchmark bond stood at 0.8%, i.e. 1.8 
percentage points below the reference value. 
         
Following the first two months of the pandemic, 
the long-term interest rate of Croatia rose by over 
60 basis points to stand at 1.2% in April 2020. It 
declined then very gradually, falling to as low as 
0.3% in October 2021. The long-term interest rate 
of Croatia picked up slightly in December 2021 
and moved higher in the first months of 2022 amid 
increasing geopolitical risks at the global level and 
a deterioration of the inflation outlook in the 
context of an already high inflation in most 
advanced economies. The spread relative to the 
German long-term benchmark bond widened to 
around 170 basis points in the first months of the 
COVID-19 pandemic, it narrowed gradually 
subsequently, falling to as low as 50 basis points in 
October 2021 against the backdrop of a strong 
economic recovery of the Croatian economy. Since 
November 2021, the spread has widened again to 
some extent in the context of a deterioration in the 
Croatian economic outlook related to the spread of 
the Omicron variant and of an increased risk 
aversion due to heightened geopolitical risks and 
the beginning of the Russia’s invasion of Ukraine 
in February 2022. In April 2022, the spread to the 
German long-term benchmark bond stood at 168 
basis points, declining slightly from a recent years’ 
peak of 180 basis points reached in the previous 
month. 
0
100
200
2016 2017 2018 2019 2020 2021
Graph 4.6: Croatia - 3-M Zibor(1) and 3-M NRR(2) spread to 3-M Euribor
(1) The production of the previously used ZIBOR reference rate was 
discontinued by the national central bank as of 1 January 2020.
(2) NRR is the national reference rate of average finacing expenses of the
banking sector
Source: Eurostat, Thomson Reuters and Croatian National Bank
(basis points, monthly values until Dec.2019, quarterly values since Q1 2020)
0
2
4
6
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Croatia Reference Value
Graph 4.7: Croatia - Long-term interest rate criterion
(percent, 12-month moving average)
Source: European Commission.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 111 – 
European Commission 
Convergence Report 2022 
96 
4.6. ADDITIONAL FACTORS 
The Treaty (Article 140 TFEU) calls for an 
examination of other factors relevant to economic 
integration and convergence to be taken into 
account in the assessment. The assessment of the 
additional factors – including balance of payments 
developments, as well as product, labour and 
financial market integration – gives an important 
indication of a Member State's ability to integrate 
into the euro area without difficulties. 
In November 2021, the Commission published its 
ninth Alert Mechanism Report (AMR 2022) under 
the Macroeconomic Imbalance Procedure (MIP 
see also Box 1.7), which concluded that an In-
Depth Review (IDR) was warranted for Croatia. In 
the updated scoreboard including figures until 
2020, the net international investment position 
(NIIP), unit labour cost (ULC) growth, house price 
growth and general government gross debt 
indicators are above their indicative thresholds. 
However, the findings of the Commission’s 2022 
In-Depth Review (IDR) indicate that the 
unwinding of macroeconomic imbalances resumed 
in 2021, following a relatively contained 
deterioration in 2020. The public debt ratio 
decreased owing to strong economic recovery and 
partial phasing out of pandemic-related fiscal 
measures. The recovery also reduced the private 
debt ratio, which returned close to the
prepandemic level. Both household and corporate 
debt are below prudential thresholds, although still 
above the levels suggested by fundamentals. 
External balances improved, with the current 
account balance returning to positive territory and 
the net international investment position (NIIP) 
returning to an upward trajectory. Croatia’s RRP 
should facilitate reforms in different areas and thus 
support the unwinding of macroeconomic 
imbalances in the medium term. A range of RRP 
reforms should help improve the fiscal framework, 
the cost effectiveness in the public sector, access to 
financing and the business environment. They are 
also expected to increase the export potential of the 
economy, participation on the labour market and 
boost long-term productivity. 
After a strong increase of 7.3% in 2020, the 
growth of real house prices decelerated to 4.6% in 
2021, thus moving below the prudential threshold. 
At the same time, lending for house purchases 
continued to grow at a robust pace in 2021, 
supported by the government subsidy program for 
first-time home owners (among other factors). Due 
to signs of house price overvaluation, elevated 
house price growth, high mortgage credit growth 
and signs of loosening of lending standards, the 
ESRB issued a warning to Croatia in February 
2022, indicating risks as medium and policy as 
only partially appropriate and partially sufficient. 
Although the ESRB recognised and supported 
current CNB macro-prudential measures, it 
emphasised that borrower-based measures should 
be activated. However, on the basis of the 2022
indepth review undertaken under Regulation (EU) 
No 1176/2011 on the prevention and correction of 
macroeconomic imbalances, the Commission 
considered in its Communication COM(2022) 600 
that Croatia is no longer experiencing 
macroeconomic imbalances. Important progress 
has been made in reducing private indebtedness 
and net external liabilities. General government 
debt remains high but has resumed the downward 
trajectory that delivered marked improvements 
before the pandemic. The banking sector remains 
stable and liquid, with a decreasing
nonperforming loans ratio. Potential output growth has 
increased, building on strong policy action, and a 
further strengthening based on a strong 
implementation of Croatia’s recovery and 
resilience plan can address remaining 
vulnerabilities. On current forecasts, both private 
and government indebtedness are expected to 
continue falling with the external position 
strengthening further benefiting also from the RRF 
funds. 
Croatia submitted its recovery and resilience plan 
(RRP) on 14 May 2021. The Commission’s 
positive assessment on 8 July 2021 and Council’s 
approval on 28 July 2021 paved the way for the 
implementation of the RRP and the disbursement 
-2
0
2
4
6
2016 2017 2018 2019 2020 2021
Croatia Germany
Graph 4.8: Croatia - Long-term interest rates
(percent, monthly values)
Source: Eurostat.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 112 –
Convergence Report 2022 - Technical annex 
Chapter 4 - Croatia 
97 
of EUR 6.3 billion in grants over the period 2021-
2026, which is equivalent to 11.5 % of 2019 GDP. 
Croatia’s plan includes an extensive set of 
mutually reinforcing reforms and investments (146 
investments and 76 reforms) that should contribute 
to effectively addressing all or a significant subset 
of the economic and social challenges outlined in 
the country-specific recommendations (CSRs) 
addressed to Croatia by the Council in the 
European Semester in 2019 and 2020.  
The plan will address among others key
macroeconomic challenges such as low employment and 
activity rates, a burdensome and complex business 
environment and the low quality of education. Key 
investments are included on energy efficiency and 
post-earthquake reconstruction of buildings, 
sustainable transport, the digital transition of the 
public administration and 5G infrastructure. 
Reforms include early childhood education and 
care, healthcare system, anti-corruption and
antimoney laundering, judiciary, and the business 
environment, by reducing administrative barriers.  
The plan devotes 40.3% of its total allocation to 
measures supporting climate objectives, 20.4% to 
the digital transition and 23% on social 
expenditure, all while respecting the do no 
significant harm principle.  
The implementation of the investments in the 
Croatian plan, along with other investments under 
Next Generation EU (NGEU), is estimated to raise 
Croatia’s GDP by 2.9% by 2026, of which 0.5% 
due to the positive spillover effects of the 
coordinated implementation of NGEU across 
Member States (71). This does not take into 
account the positive impact of structural reforms 
on growth. 
4.6.1. Developments of the balance of 
payments 
Croatia’s current account balance was deeply 
affected by the COVID-19 pandemic in 2020, but 
it recovered swiftly during 2021. After registering 
a surplus of 3% of GDP in 2019, the current 
(71) Pfeiffer P., Varga J. and in ’t Veld J. (2021), “Quantifying
Spillovers of NGEU investment”, European Economy
Discussion Papers, No. 144 and Afman et al. (2021), “An
overview of the economics of the Recovery and Resilience
Facility”, Quarterly Report on the Euro Area (QREA), Vol.
20, No. 3 pp. 7-16. 
Table 4.4:
Croatia - Balance of payments (percentage of GDP)
2016 2017 2018 2019 2020 2021
Current account 2.2 3.5 1.8 3.0 -0.1 3.1
of which: Balance of trade in goods -16.1 -16.9 -18.3 -18.8 -17.3 -18.3
Balance of trade in services 17.2 17.5 17.5 18.5 10.5 17.1
Primary income balance -1.9 -0.4 -0.5 -0.1 2.3 0.3
Secondary income balance 3.0 3.3 3.2 3.4 4.4 4.0
Capital account 1.4 0.9 1.3 1.6 2.1 2.3
External balance 1) 3.6 4.4 3.1 4.6 2.1 5.5
Financial account 3.1 4.6 3.4 4.4 1.3 4.9
of which: Direct investment -4.2 -2.3 -1.6 -6.1 -1.3 -3.9
Portfolio investment 2.9 0.8 1.9 2.4 -0.2 -0.1
                Other investment 2) 4.9 0.9 0.1 6.3 1.6 -1.5
Change in reserves -0.6 5.2 2.9 1.8 1.2 10.5
Financial account without reserves 3.7 -0.6 0.4 2.6 0.1 -5.6
Errors and omissions -0.5 0.2 0.3 -0.2 -0.8 -0.5
Gross capital formation 20.7 21.7 23.2 22.8 23.9 20.0
Gross saving 23.0 25.1 25.0 25.6 23.0 23.4
Net international investment position -72.4 -64.2 -55.7 -46.7 -47.8 -33.9
1) The combined current and capital account.
2) Including financial derivatives.
Sources: Eurostat, European Commission calculations, Croatian National Bank.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 113 –
European Commission 
Convergence Report 2022 
98 
account balance fell into negative territory for the 
first time since 2013, at -0.1% of GDP in 2020. 
However, a strong recovery of tourism export 
services and a robust performance in exports of 
goods, drove the current account balance back to a 
surplus of 3.1% of GDP in 2021. Despite the 
economic fallout of the COVID-19 crisis, the 
capital account continued improving in 2020 and 
2021 amid an increasing inflow of EU funds. 
Thanks to this evolution, the external balance (i.e. 
the combined current and capital account balance) 
reached 5.5% of GDP surplus in 2021. 
During 2020, exports of services fell by more than 
40% compared to 2019, while exports of goods 
were much less affected by the COVID-19 
pandemic as they posted a growth of 0.3%. In 
2021, a better-than-expected tourism season helped 
exports of services to quickly recover, although 
they remained 10% behind pre-pandemic levels. 
As a result, the balance of trade in services 
improved over the year reaching 17.1% of GDP. In 
terms of trade in goods, both exports and imports 
exceeded 2019 levels in 2021, experiencing a 
quick and strong recovery despite supply chain 
disruptions. However, the trade balance of goods 
deteriorated by 1 percentage points in 2021, 
reaching -18.3% of GDP. 
In 2020, the financial account balance surplus fell 
to 1.3% of GDP, down from 4.4% recorded in 
2019, mostly due to a reduction in portfolio 
investments, lower reserves and, in particular, to 
changes in other investments. However, in 2021 
the surplus increased to 4.9% of GDP, heavily 
supported by a strong accumulation of reserves. 
Consequently, the financial account balance 
without reserves decreased to -5.6% of GDP. 
Based on national accounts, external cost 
competitiveness, as measured by the ULC-deflated 
real effective exchange rate, has increased since 
the beginning of the pandemic. However, the 
evolution of ULC-deflated REER in 2020 should 
be interpreted with caution due to challenges in 
calculating ULC. (72). On the other hand, the HICP 
based REER indicates a slight deterioration in 
external price competitiveness since 2020. 
According to the Commission’s Spring 2022 
Economic Forecast, the current account is 
expected to record a milder surplus of 1.5% of 
GDP in 2022, with rising energy prices playing an 
important role, and 0.1% of GDP in 2023. Further 
reduction of surplus in 2023 should be mostly 
driven by pressures on imports of goods coming 
from increasing domestic demand, especially 
investments, which have high import component. 
4.6.2. Market integration 
The Croatian economy is well integrated with the 
euro area through trade, financial and investment 
linkages. The degree of openness stood at 58% in 
2021 increasing significantly after having declined 
to as low as 51% in 2020 as international trade and 
Croatia’s exports of tourism and travel services 
were particularly hit by the pandemic. Trade with 
the euro area amounted to 31.7% of GDP in 2021, 
with Germany, Italy, Slovenia, Hungary and 
Austria, Croatia's largest trade partners, accounting 
for half of total trade. 
FDI has so far been mainly directed to the banking, 
real estate and retail sectors. Croatia has so far 
failed to attract significant FDI inflows into the 
tradable goods sector and it is thus weakly 
integrated into global supply chains. The 
unfavourable business environment appears to be 
the main obstacle to attracting more FDI in the 
tradable goods sector. 
With regard to the business environment, Croatia 
performs worse than most euro-area Member 
States according to several commonly used 
indicators (e.g. the World Bank's Ease of Doing 
Business Index or the IMD World Competitiveness 
Index). In the World Bank's Ease of Doing 
Business, Croatia's worst rankings concern dealing 
with construction permits and starting a 
business (73). According to the World Bank's 
(72) The ULC-deflated REER should be interpreted with
prudence as unit labour costs were distorted by the uneven
approach to recording working hours in the presence of
labour retention schemes. 
(73) The World Bank Doing Business (DB) program was
paused in 2021. The programme will continue with a new
90
100
110
2016 2017 2018 2019 2020 2021
Graph 4.9: Croatia - Effective exchange rates
NEER REER, HICP deflated REER, ULC deflated
(vs. 36 trading partners;  monthly averages;
index numbers, 2016 = 100)
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 114 –
Convergence Report 2022 - Technical annex 
Chapter 4 - Croatia 
99 
Worldwide Governance Indicators (2020), Croatia 
ranks low in voice and accountability, regulatory 
quality and rule of law compared with the average 
of the five euro area Member States with the 
lowest scores. Croatia ranks higher than the 
average five lowest euro area Member States for 
political stability and absence of violence. (74) On 
the other hand, Croatia stepped up its transposition 
of EU internal market directives. In addition, there 
has been renewed effort to improve the business 
environment, in particular to reduce the 
administrative burden and regulatory restrictions, 
especially supported by RRP funds and post-entry 
ERM II commitments. 
    
Corruption represents an important issue in 
Croatia, which is reflected in the poor performance 
in the perception of corruption index. This points 
to a need to strengthen the framework to prevent, 
detect and correct corruption. Related, Croatia 
faces challenges in addressing Sustainable 
Development Goal 16 – Peace, justice and strong 
institutions. The proportion of people who 
perceive their justice system to be very or fairly 
independent has been decreasing in recent years 
and is the lowest in the EU. The Recovery and 
Resilience Plan includes reforms and investments 
in the justice system, for a combined total of EUR 
100 million, which is expected to significantly 
improve the efficiency of the justice and
anticorruption systems, shorten the length of court 
proceedings and reduce the backlog of court cases, 
enhancing the transparency and efficiency of 
public procurement system and put in place a 
reliable management and control of the EU funds. 
                                                                                   
governance and improved accountability and transparency 
under the name Business Enabling Environment (BEE). 
The first edition of the BEE is expected in 2023. 
(74) A Member State is considered to have a ‘low’ (‘high’) 
ranking compared with the average of the five euro area 
Member States with the lowest scores for each indicator if 
its score is at least 0.3 percentage points lower (higher) 
than that of the average of this euro area group. 
The 4th Anti-money Laundering Directive 
imposed transposition by 26 June 2017 and during 
2017-2018 Croatia communicated to the 
Commission the adoption of several transposition 
measures. The Commission’s analysis of the 
communicated measures concluded that the 
Directive had been fully transposed. An 
assessment of the concrete implementation and 
effective application of the 4th Anti-money 
Laundering Directive in Croatia is at present 
ongoing. 
As regards the 5th Anti-money Laundering 
Directive, whose transposition deadline elapsed on 
10 January 2020, Croatia has notified national 
transposition measures and declared the 
transposition to be complete. The Commission is 
at present completing its analysis of whether there 
are any potential completeness or conformity 
issues in the transposition or implementation of the 
Directive. 
The economic expansion in Croatia prior to the 
pandemic supported a steady increase in the 
employment rate (20-64), which reached 66.7% in 
2019. Unscathed during the crisis, the employment 
rate increased to 68.2% in 2021, but remained well 
below the EA average of 72.5% (age class from 20 
to 64 years). Although the job preservation 
schemes, also supported by SURE, ESF and 
REACT-EU, helped cushion the impact on 
employment levels, the COVID-19 crisis strongly 
affected the youth (16-24 year olds). This is shown 
by the particularly high levels of involuntary 
temporary employment in this age group (30.9% in 
2020 compared to 12.2% in 15-64) indicating low 
levels of job security. However, several RRP 
reforms and investments related to active labour 
market policies aim to support the labour market in 
Croatia, reduce skills gaps and increase activity 
and employment rates, which should help Croatia 
speed up convergence to the EU averages. 
0.0
0.4
0.7
1.1
1.4
Voice and Accountability
Political Stability and Absence
of Violence/Terrorism
Government Effectiveness
Regulatory Quality
Rule of Law
Control of Corruption
Croatia Euro area average five lowest Euro area average
Graph 4.10: Croatia - 2020 World Bank's Worldwide Governance Indicators
Note: Estimate of governance ranges from -2.5 (weak) to 2.5 (strong). 
Source: World Bank.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 115 – 
European Commission 
Convergence Report 2022 
100 
Although the size of the financial sector in Croatia 
reached 229% of its GDP in 2020, it was smaller 
than that of the euro area. At the same time, its size 
was comparable to that of the five euro area 
Member States with the smallest financial sector. 
As in the euro area, the banking sector dominates 
the Croatian financial sector but its share was 
much larger than in the euro area, representing 
about 56% of the financial sector’s assets against 
just 40% in the euro area in 2020. The central bank 
and the sector of insurance and pension funds were 
the second and the third largest holders of financial 
assets with a share of 20% and 19% respectively. 
As a result, these three sectors (i.e. monetary 
financial institutions, central bank and insurance 
companies and pension funds) concentrated about 
95% of financial sector assets, indicating a higher 
concentration of financial assets than in the euro 
area but also than in the five smallest euro area 
financial sectors. Reflecting on one hand the 
impact of the pandemic on the financial sector 
stability and on the other hand the measures taken 
by the central bank in response to the crisis, the 
importance of the central bank in the financial 
sector increased to 20% of GDP in 2020 from 15% 
of GDP in 2016. At the same time, the importance 
of the banking system declined to 56% of GDP 
from 62% in 2016, reflecting a subdued credit 
growth to the real economy and in particular to the 
non-financial sector. The importance of the 
insurance and pension funds appears to have been 
more stable, standing to 19% of the total assets of 
the financial sector in 2020, which broadly 
compares to its importance of 17% in 2016. 
 
 
      
 
 
As for the funding structure of the Croatian 
economy, this is dominated by bank loans and 
trade credits to a larger extent than in the euro 
area. The outstanding bank loans and trade credits 
amounted to over 164% of Croatia’s GDP and the 
majority of bank loans was denominated in euro. 
Possibly reflecting the large use of limited liability 
companies and the importance of SOEs in Croatia, 
other equity (75) represented the second most 
important source of funding of the Croatian 
economy, amounting to 124% of GDP. At the 
same time, the listed and unlisted shares 
represented about 64% of GDP, broadly in line 
with the importance of government debt market in 
terms of GDP. However, the importance of listed 
shares amounted to just 36% of GDP in 2020, 
declining somewhat compared to 2016 when it 
stood at 41% and being thus just half of its 
                                                          
(75) Other equity refers to equity claims such as equity in 
incorporated partnerships, equity in limited liability 
companies whose owners are partners, capital invested in 
cooperative societies or investment by the government in 
the capital of public corporations whose capital is not 
divided into shares. 
Table 4.6:
Croatia - Allocation of assets by financial sub-sector
Ratio to GDP (%)
HR EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Financial corporations (total) 196 229 722 796 177 215
Central bank 30 45 45 78 37 61
Monetary financial institutions 122 128 286 311 97 98
Other financial intermediaries 9 7 202 179 20 28
Non-MMF investment funds1) 3 6 100 127 4 5
Insurance co. and Pension Funds 33 43 90 102 18 23
Share of total (%)
HR EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Central bank 15 20 6 10 21 29
Monetary financial institutions 62 56 40 39 55 46
Other financial intermediaries 5 3 28 22 11 12
Non-MMF investment funds 1 3 14 16 2 2
Insurance co. and Pension Funds 17 19 12 13 10 11
1) MMF stands for money market funds.
Source: Eurostat.
 
 
  
 
 
Table 4.5:
Croatia - Market integration
2016 2017 2018 2019 2020 2021
Trade openness 1) (%) 50.3 53.3 54.3 54.9 51.0 58.0
Trade with EA in goods &amp; services 2)+3) (%) 28.6 29.6 30.4 30.7 28.1 31.7
World Bank's Ease of Doing Business Index rankings 4) 43 51 58 51 51 -
IMD World Competitiveness Ranking 5) 58 59 61 60 60 59
Internal Market Transposition Deficit 6) (%) 2.2 1.3 0.3 0.2 1.2 -
Real house price index 7) 102.0 105.0 109.8 118.4 127.0 132.8
 1) (Imports + Exports of goods and services / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics, Balance of Payments).
 2) (Imports + Exports of goods with EA-19 / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics).
 3) Trade in services with EA-19 (average credit and debit in % of GDP at current prices) (Balance of Payments).
 4) Data not available for 2021. The Ease of Doing Business report by the World Bank was discontinued in September 2021. 
 5) International Institute for Management Development (IMD).
 6) Percentage of internal market directives not yet communicated as having been transposed, relative to the total.
    (November data, as of 2016 date refers to the year of publication).
 7) Deflated house price index (2015=100) (Eurostat). 
Sources: Eurostat, World Bank, International Institute for Management Development, European Commission calculations.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 116 – 
Convergence Report 2022 - Technical annex
Chapter 4 - Croatia 
101 
importance in the euro area. Overall, Croatia has 
less developed equity and debt markets in terms of 
GDP than the euro area average. Although these 
markets appear relatively larger in terms of GDP 
than the five smallest national capital markets in 
euro area, their relative importance as a funding 
source remained limited and broadly in line with 
the euro area average. 
The banking sector in Croatia is highly integrated 
into the EU financial sector, in particular through 
foreign ownership of the banking sector, as around 
90% of its assets are held by subsidiaries of 
foreign banks. Concentration in the banking sector 
is much higher than in the euro area, with the 
largest five banking institutions reaching 80% of 
sector’s total assets in 2020, against 50% in the 
euro-area. In parallel with the inclusion of the 
Croatian kuna in the ERM II, the Croatian 
National Bank entered into a close cooperation 
with the ECB, effectively joining the Banking 
Union. As of 1 October 2020, Croatia also joined 
the Single Resolution Mechanism, and the ECB 
has become responsible of the direct supervision of 
the significant banking institutions in Croatia as 
well as the oversight of less significant institutions. 
Measures of intra-EU integration in equity and 
debt markets, as based on the home bias in 
portfolio investments, (76) indicate that the level of 
integration of Croatia is very low in both segments 
and in particular in equity markets. Although intra-
EU financial integration, by the same measure, is 
in general relatively low across EU Member 
States, Croatia’s integration is well below that of 
the euro-area Member States exhibiting low 
integration. The very large home bias indicates that 
almost all investments in financial markets takes 
place domestically. 
4.7. SUSTAINABILITY OF CONVERGENCE 
This concluding section draws together elements 
that are key for gauging the sustainability of 
Croatia’s convergence vis-à-vis the euro area. The 
analysis reviews sustainability from a number of 
angles.  
(76) Home bias in portfolio investments measures the average
propensity of investors in a Member State to invest
domestically as compared with investing in other EU
countries. The indicator ranges between 0 and 1, with a
value of 0 indicating that investors prefer domestic over
foreign assets. The inverse of the home bias can be
interpreted as one measure of financial integration among
EU countries.
Table 4.7:
Croatia - Financing of the economy1)
Ratio to GDP (%)
HR EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Liabilities (total) 441 461 743 770 324 335
Loans 163 164 238 236 115 112
Non-financial co. debt securities 5 4 12 15 3 4
Financial co. debt securities 0 0 74 68 11 12
Government debt securities 57 65 83 95 51 57
Listed shares 41 36 65 73 17 18
Unlisted shares 28 28 186 193 55 56
Other equity 109 124 51 56 42 48
Trade credits and advances 38 39 33 35 29 29
Share of total (%)
HR EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Loans 37 36 32 31 35 33
Non-financial co. debt securities 1 1 2 2 1 1
Financial co. debt securities 0 0 10 9 3 3
Government debt securities 13 14 11 12 16 17
Listed shares 9 8 9 9 5 5
Unlisted shares 6 6 25 25 18 18
Other equity 25 27 7 7 13 14
Trade credits and advances 9 8 4 5 9 9
1) The table focuses on the financing needs of a country and how these are met by the financial system.
 The table is constructed from the liabilities of all economic sectors, but only considers loans, debt securities, 
equity and trade credits. The sum of liabilities in the table only reflects the total for the liabilities considered.
Source: Eurostat.
0
20
40
60
80
100
HR, 2016 HR, 2020 EA, 2016 EA, 2020
Concentration in the banking sector (CR5 ratio)
Share of foreign institutions as % of total assets
Graph 4.11: Croatia - Foreign ownership and concentration
in the banking sector
(in percent, weighted averages)
Source: ECB, Structural financial indicators  and HNB Banks Bulletin.
0.0
0.2
0.4
HR, 2016 HR, 2020 EA, 2016 EA, 2020 EA Low,
2016
EA Low,
2020
Debt Equity
Graph 4.12: Croatia - Intra-EU integration in equity and debt portfolio 
investment
Note: The chart shows the extent of home bias in debt and equity markets. A value index 
of 1 implies ‘full integration’ with the financial markets of other Member States, while 0 
denotes ‘no integration’.
Source: FinFlows database: European Commission, Joint Research Centre (JRC). 
(index)
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First, the sustainability dimension is inherent in the 
individual convergence criteria themselves. This 
holds most explicitly for the price stability 
criterion, which includes the requirement of a 
’sustainable price performance’. In principle, the 
fiscal criterion (EDP) also involves a
forwardlooking aspect, providing a view on the durability 
of the correction of fiscal imbalances. While the 
exchange and interest rate criteria are, by 
construction, backward-looking, they aim at 
capturing an economy’s ability to operate durably 
under conditions of macroeconomic stability, 
hence indicating whether the conditions for 
sustainable convergence following euro adoption 
are in place.  
Second, the assessment of additional factors 
(balance of payments, product and financial 
market integration) required by the Treaty 
broadens the view on sustainability of convergence 
and allows for a more complete picture, 
complementing the quantitative criteria. In 
particular, a sound external competitiveness 
position, effectively functioning markets for goods 
and services and a robust financial system are key 
ingredients to ensure that the convergence process 
remains smooth and sustainable.  
Third, the convergence assessment should be 
informed by the results and findings of enhanced 
policy co-ordination and surveillance procedures 
(MIP, fiscal governance) put in place after the 
Global Financial Crisis. The aim is not to add to 
the existing requirements for euro adoption, but to 
make full use of the comprehensive economic and 
financial analysis undertaken under the so-called 
European Semester. While some elements drawn 
from the European Semester (e.g., related to AMR 
scoreboard indicators) are included in the relevant 
chapters on convergence above, this section uses 
this framework more systematically to provide an 
integrated view of the sustainability dimension. 
Any assessment of the sustainability of 
convergence has limits and must be based on a 
judgement of the likely future evolution of the 
economy. In particular, as experience has shown, 
the sustainability and robustness of the 
convergence process after euro adoption is to a 
significant extent endogenous, i.e., it depends on a 
Member State’s domestic policy orientations after 
it has joined the euro area. Therefore, while the 
assessment of sustainability is an essential element 
in determining a Member State’s readiness to 
adopt the euro based on initial conditions and 
existing policy frameworks, the outcome of such 
an assessment should be seen as a snapshot at a 
specific point in time, whereas the long-term 
sustainability of the convergence process will also 
depend on the adoption of appropriate policies 
over time. In this respect, the on-going 
surveillance carried out in the context of the 
European Semester will play a major part in 
ensuring that such policies are implemented by the 
Member State after euro adoption. 
The analysis below looks at sustainability from 
four different perspectives: price stability; fiscal 
performance and governance; structural resilience 
and growth sustainability; and financial resilience. 
Price stability 
While inflation has increased significantly in 
Croatia since the beginning of 2021, the upward 
trend has been broadly comparable to what has 
been observed in the euro area. As a result, 
Croatia’s present 12-month inflation rate is below 
the reference value. Looking ahead, the 12-month 
inflation rate is expected to remain below the 
reference value in the next few months and close 
to the euro area average in both 2022 and 2023. 
Beyond the outlook for headline inflation, 
assessing the sustainability of price stability also 
requires looking at underlying price and cost 
fundamentals. The analysis presented in Section 
4.2.3 does not point to any source of concern 
related to the sustainability of price stability when 
examining labour costs, imported prices, the 
macroeconomic policy mix or risks related to price 
level convergence. 
Furthermore, it is important to stress that inflation 
developments in Croatia have been closely aligned 
with those of the euro area over the decade 
preceding the COVID-19 crisis. On average, both 
headline and core inflation have been very close to 
the euro area average over this period, with annual 
deviations never exceeding 1 percentage point. 
This reflects a number of interrelated factors, 
including the kuna’s exchange rate regime, high 
trade and financial integration with the euro area 
and a business cycle that is generally broadly 
aligned with that of the euro area. 
Nevertheless, in view of the high uncertainty 
currently surrounding the inflation outlook in the 
EU, Croatia’s successful integration in the euro 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 118 –
Convergence Report 2022 - Technical annex 
Chapter 4 - Croatia 
103 
area will require the continued monitoring of a 
number of upside risks in terms of inflation. 
First, underlying inflation has accelerated more 
strongly in Croatia than in the euro area in recent 
months, reflecting the stronger recovery from the 
COVID-19 crisis and a surge in the price of 
processed food. Despite currently stronger core 
inflation relative to the euro area there are no 
indications that the drivers would be of a structural 
nature, given its historic alignment with the euro 
area trends. Thus, current deviation of core 
inflation rate compared to the euro area is expected 
to be transitory with the inflation gap fading in the 
upcoming period. However, underlying inflation 
pressures will need to be monitored closely 
looking ahead. 
Second, longer-term inflation prospects will hinge 
in particular on wages growing in line with 
productivity. Although the 2013 and 2014 labour 
market reforms have substantially increased the 
level of flexibility in the labour market,
wagesetting in Croatia remains imperfectly aligned with 
productivity developments, which is partly linked 
to the role of the public sector as the wage leader. 
While this represents a risk, the issue could be 
alleviated by the reforms envisaged in the context 
of the RRP (see also next paragraph).  
RRP-related investments and reforms could also be 
important drivers of price developments looking 
ahead. On the one hand, RRP investments will 
boost aggregate demand in the economy, which 
could put upside pressures on prices in the short 
term. On the other hand, many reforms (e.g. 
reduction of administrative burden and para-fiscal 
charges, deregulation of services etc.) should 
enhance competition on the market and reduce 
costs for companies, thus putting downward 
pressures on prices of final products in the long 
run. Moreover, two RRP reforms could contribute 
to a better productivity-wage relation in the 
medium-term. The first one is the new wage and 
work models in civil and public service, which 
should introduce a fair, transparent and sustainable 
wage system in the state administration and public 
services. The second one is the Amendment to the 
Labour Act, tackling unjustified temporary 
employment and incentivising workers to remain 
active, among others. On balance, the RRP-related 
investments and reforms are expected to have a 
muted if not disinflationary effect on the Croatian 
economy in the long run. 
Fiscal sustainability 
After a timely abrogation of the excessive deficit 
procedure in 2016, Croatia’s public finances 
performed well in the preventive arm of the 
Stability and Growth Pact until 2020, when they 
took a hit as a result of the pandemic. A decline in 
economic activity adversely affected revenues, 
which coincided with substantial expenditure 
measures needed to protect employment and
jumpstart the recovery. As a result, Croatia’s headline 
general government balance went from a surplus 
of 0.2% of GDP in 2019 to a deficit of 7.3% of 
GDP in 2020. At the same time, the public debt 
ratio rise by more than 16 percentage points. 
However, already in 2021, the deficit was brought 
below 3%, driven by a full economic recovery and 
a progressive but substantial phasing-out of the 
expenditure measures. 
Croatia’s 2022 Convergence Programme was 
adopted on 27 April and submitted to the 
Commission on 29 April. The programme projects 
the general government deficit to narrow from 
2.9% of GDP in 2021 to 2.8% of GDP in 2022 and 
1.6% of GDP in 2023. This is expected to bring 
general government public debt down to 71.7% of 
GDP in 2023, very close to its pre-COVID level 
recorded in 2019. The macroeconomic outlook 
underpinning the Convergence programme differs 
from the Commission’s Spring 2022 Economic 
Forecast. The main difference is related to the 
inflation figures in 2022 and 2023, which are 
notably higher compared to Commission’s 
forecast. The targets in the Convergence 
programme appear prudent and achievable. 
At the same time, Croatia is classified at medium 
fiscal sustainability risk over the medium term, 
according to the Commission Debt Sustainability 
Analysis. (77). The debt ratio is projected to decline 
from its 2021 level of 79.8% of GDP until the mid-
2020s, assuming a favourable interest-growth rate 
differential, but it will increase again as from 2027 
unless measures are taken to correct the projected 
structural primary deficit, especially given the 
projected increase in the cost of ageing in coming 
years. Under less favourable macro-financial 
assumptions, debt could revert close to its 2021 
level by 2032. Additional factors may aggravate 
sustainability risks, including the large share of 
debt held in foreign currency, the impact of the 
                                                          
(77) The classification based on the Commission DSA takes 
into account in particular the projected debt level and 
trajectory under the baseline, stress test scenarios and 
stochastic simulations. 
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104 
recent decline in population and the country’s 
negative net international investment position. 
On the positive side, however, the structure of 
Croatia’s debt mitigates the risks, notably as the 
debt maturity has been lengthened in recent years. 
Furthermore, reforms under the recovery and 
resilience plan should have a positive impact on 
long-term growth, contributing to improving debt 
sustainability. 
Structural resilience and growth sustainability 
The last report by the Commission on Croatia’s 
macroeconomic imbalances (78) noted that the 
country was still experiencing imbalances related 
to elevated private and public debt levels in the 
context of low potential growth. However, in 
recent years indebtedness of private and public 
sector has declined notably. Public debt declined 
from the peak of around 84% of GDP in 2014 to 
slightly above 71% in 2019, while private sector 
debt decreased from a peak of 120% of GDP to 
around 88% of GDP in 2019. This deleveraging 
has come against the backdrop of years of solid 
economic growth and prudent fiscal policy. The 
COVID-19 crisis in 2020 temporarily halted the 
downward trajectory of debt, which resumed 
already in 2021 in both private and public sector. 
Despite the current uncertainties surrounding the 
economic situation, debt ratios should continue to 
decline steadily, supported by solid economic 
growth but also by some MIP-relevant policies 
included in Croatia’s recovery and resilience plan, 
such as changes in bankruptcy and solvency 
framework and new equity-based financial 
instruments which should reduce the dependence 
of firms on bank loans. 
External balances have also improved notably in 
recent years. After six consecutive years of current 
account surpluses, the COVID-19 shock pushed 
the balance slightly into negative territory, but 
Croatia managed to record again a surplus of 3.2% 
of GDP in 2021. At the same time, the net 
international investment position (NIIP) improved 
from –87% of GDP to -34% of GDP, which 
brought it in conformity with the indicative -35% 
of GDP threshold in the scoreboard of the 
Macroeconomic Imbalance Procedure. Moreover, 
Croatia’s NIIP excluding non-defaultable 
(78) European Commission (2021), Alert Mechanism Report
2022. Available at: 
https://ec.europa.eu/info/sites/default/files/economy-
finance/2022_european_semester_alert_mechanism_report.
pdf 
instruments (NENDI) was virtually balanced in 
2021 and foreign exchange reserves reached 44% 
of GDP, thus mitigating exchange-rate risks. 
Current commodity price shocks are expected to 
negatively affect Croatia’s goods trade balance, 
but stable tourism inflows, remittances and 
accelerating inflows of EU funds should keep the 
current account balance in surplus. A strong inflow 
of EU funds on the capital account should also 
support continued improvement of NIIP. 
All these developments make the Croatian 
economy more resilient to shocks. This increase in 
resilience was already visible during the COVID-
19 crisis, after which the Croatian economy 
strongly recovered, with GDP reaching
prepandemic level already in 2021. Despite the 
progress made in recent years, the Croatian 
economy is still facing various structural 
deficiencies on labour and product markets. 
Various reports (such as World Bank’s Doing 
Business Report or IMD’s World Competitiveness 
Report, OECD’s Product Market Regulation) still 
point to a relatively unfavourable business 
environment, rigidities on the labour and product 
markets and high administrative burden. In 
addition, the public sector’s strong role in the 
economy weighs on the allocative efficiency on 
the market. Worldwide Governance Indicators 
suggest that the quality of institutions has 
increased in recent years, but Croatia still ranks 
below most euro area countries for indicators such 
as the Rule of Law, Control of Corruption, 
Regulatory Quality and Government Effectiveness. 
Similar conclusions can be drawn from the 
Transparency International’s Corruption 
Perception Index. 
Measures aimed at addressing these rigidities and 
improving the quality of institutions have featured 
in Croatia’s prior and post-entry ERM II 
commitments as well as its Recovery and 
Resilience Plan. These measures include cutting 
the administrative and fiscal burden, improving 
SOEs governance and the anti-money-laundering 
framework (AML), increasing the efficiency of the 
judiciary and liberalising regulated professions. 
In July 2019, Croatia committed to implementing 
policy measures prior to joining the ERM II in the 
following six areas: i) banking supervision (close 
cooperation with the ECB), ii) the macroprudential 
framework, iii) the anti-money laundering 
framework, iv) statistics, v) public sector 
governance and vi) business environment. In June 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 120 –
Convergence Report 2022 - Technical annex 
Chapter 4 - Croatia 
105 
2020, the Croatian authorities notified the ERM II 
parties of the fulfilment of these commitments, 
which the ECB and the Commission assessed as 
effectively implemented. (79) 
At the time of its ERM II entry in July 2020, 
Croatia committed to implementing further 
measures in the following four areas: i) anti-money 
laundering, ii) business environment, iii) SOEs and 
iv) insolvency framework.
As regards AML, the implemented measures 
consisted of awareness raising among stakeholders 
through regular education, improved cooperation 
between the Anti-Money Laundering Office and 
the supervisory authorities and the implementation 
of the Action Plan to reduce the risk of money 
laundering and financing of terrorism based on the 
updated National risk assessment. In the area of 
Business environment, Croatia followed through 
on its commitments to simplify and digitalise 
administrative procedures as specified in the 
Action Plan for Administrative Burden Reduction 
2020 and further reduce parafiscal charges. With a 
view to improving public sector governance, 
Croatia proceeded to revise and align regulation 
and practices in accordance with the OECD 
Guidelines on Corporate Governance of SOEs. 
Finally, commitments to improve the insolvency 
framework took the form of amendments to key 
legislation governing corporate and personal 
insolvency procedures and the operationalisation 
of an interim data collection system for 
restructuring and insolvency procedures. 
Notwithstanding the AML measures implemented 
by Croatia in the context of its prior and post-entry 
commitments, the Mutual Evaluation Report 
assessing Croatia’s framework for combatting 
money laundering and terrorist financing (80) 
identified a number of remaining shortcomings 
with regard to the effective implementation of 
Croatia’s AML framework. The Croatian 
authorities are currently focusing their efforts in 
swiftly addressing the recommended actions listed 
in the report with a view to achieve a satisfactory 
level of progress within the next year.  
(79) https://ec.europa.eu/info/business-economy-euro/euro-
area/introducing-euro/adoption-fixed-euro-
conversionrate/erm-ii-eus-exchange-rate-mechanism_en 
(80) The report was adopted in December 2021 by the Council
of Europe’s Committee of Experts on the Evaluation of
Anti-Money Laundering Measures and the Financing of
Terrorism (MONEYVAL).
The aforementioned structural deficiencies are 
weighing on the long-term potential growth by 
stifling competitiveness and business activity, 
which in turn hampers investment and discourages 
employment growth. The numerous reforms in the 
RRP are expected to address the structural 
weaknesses of the economy, increase the 
efficiency of the public sector and the 
competitiveness and productivity of the Croatian 
economy. Governance in SOEs is envisaged to be 
enhanced by implementing OECD standards. At 
the same time, divestments of government-owned 
shares in companies should reduce the level of 
government intervention in the market and 
facilitate the administration of remaining shares. 
Private sector productivity and investment activity 
are expected to benefit from the planned 
continuation of the reduction of administrative 
burden, reform of the R&amp;D incentive system, 
measures aimed at strengthening the R&amp;D 
capacity, funds aimed at digitalisation of 
companies, export promotion activities and new 
financial instruments based on grants and interest 
rate subsidies but also equity-funding aimed at 
SMEs. Croatia’s RRP also contains various active 
labour market policies that should increase labour 
market participation and measures aimed at 
improving workers’ skills that should additionally 
increase productivity. All these measures should 
boost the productive potential of the economy and 
contribute to the acceleration of potential growth 
rate in the mid run. 
Financial resilience 
Although the resilience of Croatia’s financial 
sector has been tested by the outbreak of the 
pandemic, prompt policy support and regulatory 
measures (81) have so far alleviated the impact of 
the crisis on the financial sector. Overall banking 
system capital adequacy ratio actually increased in 
2020 and reached a record high in the second 
quarter of 2021. 
The Croatian banking sector entered the COVID-
19 pandemic in an already strong position as 
shown by the positive results of the comprehensive 
assessment of major Croatian banks conducted by 
the ECB ahead of its decision to establish close 
cooperation in the field of banking supervision 
(81) The measures of support during the pandemic included an 
expansionary monetary policy, fiscal support to companies
and favourable regulatory treatment of the moratoriums to
mitigate to an extent the problem of non-performing loans,
coupled with other regulatory reliefs and the temporary
restriction of banks’ profit distribution. 
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106 
with the Croatian National Bank (HNB). 
Following Croatia’s request for close cooperation 
with the ECB in May 2019, the ECB adopted a 
favourable decision in July 2020 after conducting a 
comprehensive assessment of five Croatian 
banks (82), which comprised an asset quality 
review (AQR) and a stress test. (83) The 
comprehensive assessment showed that the five 
banks did not face any capital shortfalls as they did 
not fall below the relevant thresholds used in the 
AQR and the stress test. However, the assumptions 
used for the stress test scenarios could not take into 
account the COVID-19 crisis given that this 
exercise started well before the outbreak of the 
pandemic. 
A more recent stress test exercise conducted by the 
HNB and published in May 2021, uses as a starting 
point the situation of Croatian banks’ balance 
sheets at the end of 2020 (84). It concludes that the 
overall banking system is resilient and ready to 
bear increased credit losses even under an adverse 
scenario (85), which envisaged further 
unfavourable developments in the pandemic from 
the second quarter of 2021. Moreover, the 
observed economic developments in 2021 turned 
out to be much more favourable than envisaged in 
the stress test exercise scenario, with the economy 
expanding by over 10% as opposed to a 
hypothetical cumulative contraction of about 6.6% 
over the 2021-2023 period in the adverse scenario. 
However, Croatia’s strong economic recovery in 
2021 and the increased loss-absorption capacity of 
the overall banking system compared to the pre-
(82) The comprehensive assessment covered Zagrebačka banka, 
Privredna banka Zagreb, Erste &amp; Steiermärkische Bank,
OTP banka Hrvatska and Hrvatska poštanska banka, all of
which consented to the disclosure of the exercise’s
findings. 
(83) Such assessment is required as part of the process of
establishing close cooperation between the ECB and the
national competent authority of an EU Member State
whose currency is not the euro. For more details please see
https://www.bankingsupervision.europa.eu/press/pr/date/20
20/html/ssm.pr200605~ca8b62e58f.it.html 
(84) See Croatian National Bank (2021), Financial Stability,
No. 22: https://www.hnb.hr/documents/20182/3899508/e-
fs-22.pdf/c82deec6-2de6-1d35-d4fb-849d8a5c15d9
(85) The adverse scenario envisages further unfavourable
developments in the pandemic from the second quarter of
2021 and a hypothetical fall in economic activity of 1.2%
in 2021, 4.0% in 2022 and 1.4% in 2023 as well as a high
unemployment rate throughout the observed adverse
scenario horizon. In addition to the assumption of
difficulties and delays in global response to the pandemic,
the adverse scenario also includes a materialisation of
additional sources of systemic risks such as a sharp fall in
residential real estate prices and depreciation of the
exchange rate that would rise to HRK 8.0/EUR following
the escalation of the pandemic (CNB, 2021). 
COVID situation mask a considerable 
heterogeneity across Croatian banks. While 
systemically important banks should be able to 
continue to operate even under very unfavourable 
conditions, the results of HNB’s stress tests for 
other credit institutions show that the latter are 
much more vulnerable to adverse economic 
conditions, with the aggregate capital surplus 
being all but fully exhausted in the first year of the 
adverse scenario. However, these credit 
institutions account for less than 5% of the total 
banking system assets (HNB, 2021). 
In addition to the more bank-specific 
vulnerabilities discussed above, a number of 
pandemic-induced developments and policy 
measures are likely to have increased some
preexisting vulnerabilities of the Croatian banking 
system. Thus, its exposure to the government and 
the real estate market has risen. With over 20% of 
total bank assets placed on Croatian government 
bonds, Croatia is among the EU countries with the 
largest government exposures of credit institutions. 
While the overall banking system can be 
considered resilient in light of the results of recent 
stress tests, this strong sovereign-bank-nexus could 
pose risks to its resilience as Croatia stands out in 
terms of the level of public debt in GDP. Even 
before the outbreak of the pandemic, Croatia had 
the highest level of public debt in GDP of all 
Central and Eastern European countries. The 
growing imbalances in the real estate sector is also 
a risk factor for the Croatian banking system. (86) 
Thus, around 45% of loans to the private sector are 
covered by real estate collateral and a possible 
decrease in real estate prices may raise credit risk 
costs (HNB, 2021). Finally, the banking sector in 
Croatia remains also highly exposed to a
currencyinduced credit risk but the risks themselves are 
contained given the historical stability of the kuna 
exchange rate vis-à-vis the euro and the sizeable 
foreign exchange reserves of the CNB. Overall, the 
above-mentioned high exposures of the Croatian 
banking system could represent a risk for its 
resilience to the extent they continue to weigh on 
its profitability looking ahead. 
(86) As a result of the continued accumulation of cyclical
systemic risks amid economic recovery following the crisis 
caused by the pandemic, the growth in the prices of
residential real estate and the pickup in lending activity, the 
CNB adopted on 28 March 2022 the decision to increase
the countercyclical buffer rate to 0.5% as of 31 March
2023. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 122 –
Convergence Report 2022 - Technical annex 
Chapter 4 - Croatia 
107 
Conclusion 
The broad-based analysis of underlying factors 
relevant for the sustainability of Croatia’s 
convergence suggests that sufficiently robust 
conditions are in place for the country to be able to 
maintain a sustainable convergence path in the 
medium term, thus supporting a positive 
assessment. However, significant challenges 
remain, and policy discipline will need to be 
maintained in a determined manner to fully exploit 
the benefits of participation in the euro area and 
minimise risks to the convergence path going 
forward. Recent measures and policy orientations 
included in Croatia’s RRP should contribute to 
ensure that it remains on a sustainable convergence 
path in the medium term. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 123 –

5. HUNGARY
109 
5.1. LEGAL COMPATIBILITY 
5.1.1. Introduction 
The main rules governing the Magyar Nemzeti 
Bank (MNB – Hungarian national bank, hereafter 
MNB) are laid down in Article 41 of the 
Hungarian Fundamental Law and Act CXXXIX 
2013 on the MNB (hereafter: MNB Act).  No 
amendments to these legal acts were passed with 
regard to the incompatibilities and imperfections 
mentioned in the Commission’s 2020 Convergence 
Report. Therefore, the comments provided in the 
Commission’s 2020 Convergence Report are 
repeated also in this year's assessment. 
5.1.2. Central Bank independence 
Frequent amendments to the Central Bank Act of a 
Member State can create instability in the Central 
Bank's operations. Therefore, a stable legal 
framework that provides a solid basis for a Central 
Bank to function is essential for ensuring central 
bank independence. Pursuant to Article 176 of the 
MNB Act, the MNB has become the legal 
successor of the liabilities of the former Hungarian 
Financial Supervisory Authority (HFSA), which 
ceased to exist on 1 October 2013. This legal 
succession also implies the transfer of all 
employees from the HFSA to the MNB pursuant to 
Article 183 of the MNB Act. The principle of 
central bank independence pursuant to Article 130 
of the TFEU implies that the MNB must have 
sufficient financial resources to perform its ESCB 
and ECB-related tasks, in addition to its national 
tasks. The tasks transferred from the HFSA to the 
MNB must not affect its ability to carry out these 
tasks from an operational and financial point of 
view. 
Further to this principle, the MNB should be fully 
insulated from all financial obligations resulting 
from any HFSA activities. Contractual 
relationships in the period prior to 1 October 2013 
including, amongst others, all employment 
relations between any new MNB staff member and 
the former HFSA can be continued only with the 
proviso that the continuation does not impinge on 
the MNB's independence and its power to fully 
carry out its duties under the Treaties. Against this 
background, Article 176 and 183 of the MNB Act 
have to be aligned to the principle of central bank 
independence as enshrined in Article 130 of the 
TFEU. 
According to Article 9(7) of the MNB Act, the 
Governor and the Deputy Governors shall take an 
oath before the President of the Republic and other 
members of the Monetary Council before the 
Parliament upon taking office with the words 
required by Law XXVII of 2008 as amended on 
the oath and solemn promise of certain public 
officials. The Law requires making an oath with 
words ’I, (name of the person taking the oath), 
hereby make an oath to be faithful to Hungary and 
to its Fundamental Law, to comply with its laws, 
and make sure others citizens comply with them 
too; I will fulfil the duties arising from my position 
as a (name of the position) for the benefit of the 
Hungarian nation […]’. The oath does not contain 
a reference to the principle of central bank 
independence enshrined in Article 130 TFEU. 
What is more, the Fundamental Law contains only 
an indirect reference to EU law. Since the 
Governor and the Deputy Governors as members 
of the Monetary Council are involved in the 
performance of ESCB related tasks, any oath 
should make a clear reference to the central bank 
independence under Article 130 of the TFEU. 
Therefore, the oath is an imperfection as regards 
the institutional independence of the MNB and the 
wording of the oath should be adapted to be fully 
in line with Article 130 of the TFEU.  
Article 153(6) of the MNB Act provides for the 
possibility for members of the Monetary Council 
(including the Governor) and MNB employees to 
take on roles in the management, boards of trustees 
or supervisory boards of foundations and business 
associations under majority ownership of the MNB 
established by the MNB under Article 162(2) of 
the MNB Act without being subject to the conflict 
of interest rules provided for in Article 152(1) to 
(5) of the MNB Act, including any formal
disclosure requirement. Hence, for those activities
the MNB officials involved, including the
Governor, are fully shielded from any scrutiny.
Moreover, Article 153(6) of the MNB Act also
provides for an explicit exemption to the rule of
Article 156(1) of the MNB Act, which determines
that members of the Monetary Council (including
the Governor) may only perform other activities,
which are compatible with their central bank
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decision-making duties. Hence, under national law 
such members may undertake activities in the 
MNB's foundations and business associations that 
are incompatible with their central bank
decisionmaking duties. The provision conflicts with Article 
162(2) of the MNB Act, which provides that the 
MNB may only establish foundations and business 
associations in line with its tasks and primary 
objective of ensuring price stability. Moreover, 
central bank decision-making duties always have 
to be performed in compliance with Article 130 of 
the TFEU. The exemption therefore seems to 
imply that the latter principles of primary Union 
law may be disregarded by members of the 
Monetary Council when acting in the context of 
the foundations and business associations under 
MNB ownership. Therefore, the incompatibility 
needs to be removed.  
In addition, Article 156(7) read in conjunction with 
Article 152(1) of the MNB Act, extends the 
application of conflict of interests provisions to 
Monetary Council members to six months 
following termination of their employment 
relationship with the MNB. However, an 
exemption is granted as regards organisations 
covered by acts enumerated in Article 39 in which 
the Hungarian State or the MNB has a majority 
stake. Such an exemption could create situations 
where the privileged position of Monetary Council 
members could give them an unfair advantage in 
obtaining nominations or posts in other 
organisations, putting them in a position of conflict 
of interest while still in employment at the MNB.   
Moreover, Article 157 of the MNB Act provides 
for an obligation for members of the Monetary 
Council, including the Governor and the Deputy 
Governors, to file declarations of wealth in the 
same manner as Members of Parliament, pursuant 
to the provisions of Article 90 of the Law XXXVI 
of 2012 on the Parliament. According to Article 
157(1) of the MNB Act and Article 90(2) of the 
Law XXXVI of 2012, the obligation to submit a 
wealth declaration extends to close family 
members (spouse, domestic partner, and children). 
Pursuant to Article 90(3) of the Law XXXVI of 
2012, members of the Monetary Council who fail 
to submit a wealth declaration will not be allowed 
to exercise their functions and will receive no 
remuneration until compliance with the obligation. 
This provision allows for the temporary removal 
from office of inter alia the Governor which seems 
to automatically fall into place once the failure to 
submit a wealth declaration as required by the 
above provisions is established by the Parliament. 
Such an automatism may lead to situations where 
the removal from office would result from an 
unintentional action that could not be qualified as a 
serious misconduct under Article 14.2 of the 
ESCB/ECB Statute. In order to preserve fully the 
principle of central bank independence, this 
incompatibility should be removed by an 
amendment of Article 157 of the MNB Act, which 
would provide for an exception for such kind of 
unintentional omission. 
5.1.3. Prohibition of monetary financing and 
privileged access 
Pursuant to Article 36 of the MNB Act and subject 
to the prohibition of monetary financing set out 
under Article 146 of the MNB Act, the MNB can 
provide an emergency loan to credit institutions in 
the event of any circumstance arising in which the 
operation of a credit institution jeopardises the 
stability of the financial system. In order to comply 
with the prohibition on monetary financing of 
Article 123 of the TFEU, it should be clearly 
specified that the loan is granted against adequate 
collateral to ensure that the MNB would not suffer 
any loss in case of debtor's default. 
Pursuant to Article 37 the MNB may grant loans to 
the National Deposit Insurance Fund and Investor 
Protection Fund in emergency cases, subject to 
prohibition of monetary financing under Article 
146 of the Act. Though the Act adequately reflects 
conditions for central bank financing provided to a 
deposit guarantee scheme a specific requirement 
should be included to ensure that the loans granted 
to the National Deposit Insurance Fund are 
provided against adequate collateral (e.g. a claim 
on future cash contributions, government 
securities, etc.) to secure the repayment of the 
loan. Therefore, Article 37 is incompatible with 
the prohibition on monetary financing as laid down 
in Article 123 of the TFEU. 
Article 177(6) of the MNB Act provides for state 
compensation to the MNB of all expenses resulting 
from obligations, which exceed the assets the 
MNB has taken over from the HFSA. The law 
does not contain any provisions on the procedure 
and deadlines on how the state shall reimburse the 
MNB of the expenses. Therefore, the 
reimbursement under Article 177(6) of the MNB 
Act is not accompanied by measures that would 
fully insulate the bank from all financial 
obligations resulting from any activities and 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 126 –
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111 
contractual relationships of the HFSA originating 
from prior to the transfer of tasks. In case of a 
substantial time gap between the costs arising to 
the MNB and the reimbursement by the state 
pursuant to Article 177(6) of the MNB Act, the 
reimbursement would result in an ex-post 
financing scheme. Should the expenses incurred at 
the MNB exceed the value of assets taken over 
from the HFSA, such a scenario would constitute a 
breach of the prohibition of monetary financing 
laid down in Article 123 of the TFEU. In order to 
comply with the prohibition of monetary 
financing, Articles 176 and 183 of the MNB Act 
should be amended in order to insulate the MNB 
by appropriate means from all financial obligations 
resulting from the HFSA's prior activities or legal 
relationships and obligations including those 
deriving from the automatic further employment of 
HFSA staff by the MNB. 
Article 162(3) and (4) of the MNB Act lay down 
the conditions of disclosure of data by a company 
related to the MNB. Furthermore, Article 162(5) 
provides for supervision of the State Audit Office 
of the operations of foundations established by the 
MNB. Notwithstanding the limitations regarding 
access to data of MNB companies, it is noted that 
pursuant to the principle of sincere cooperation 
(Article 4 TEU) a Member State is required, in full 
mutual respect, to assist the Commission and the 
European Central Bank in carrying out tasks which 
flow from the Treaties, such as providing the 
information necessary for monitoring the 
application of EU law. 
Pursuant to Article 162(2) of the MNB Act, the 
MNB may establish business associations under 
majority of MNB ownership, or foundations. In 
order to dispel any concerns from the perspective 
of Article 123 of the TFEU, the provision should 
be amended by providing for a clear framework 
delimiting the operations of such foundations and 
the volumes or resources which the MNB could 
endow them with, enabling them to purchase large 
volumes of Hungarian government securities. 
Moreover, the exemption provided under Article 
153(6) of the MNB Act to the rule of Article 
156(1) of the MNB Act which determines that 
members of the Monetary Council (including the 
Governor) may only perform other activities which 
are compatible with their central bank
decisionmaking duties is incompatible with Article 123 of 
the TFEU. The exemption provided for in national 
law seems to imply that the prohibition of 
monetary financing enshrined in Article 123 of the 
TFEU may be disregarded by members of the 
Monetary Council (including the Governor) when 
acting in the context of the foundations and 
business associations under MNB ownership. This 
incompatibility needs to be removed. 
5.1.4. Integration in the ESCB 
Objectives 
Article 3(2) of the MNB Act determines that, 
without prejudice to the primary objective of price 
stability, the MNB shall uphold to maintain the 
stability of the financial intermediary system, to 
increase its resilience, to ensure its sustainable 
contribution to economic growth and support the 
economic policy of the government. The objective 
laid down in Article 3(2) of the MNB Act is 
reduced to supporting the economic policy in 
Hungary. The provision has to be aligned to the 
secondary objective of the ESCB enshrined in 
Article 127(1) of the TFEU and Article 2 of the 
ESCB/ECB Statute in order to embrace the support 
of the general economic policies in the entire EU 
rather than in Hungary only. 
Tasks 
The MNB Act contains a series of 
incompatibilities with regard to the following 
ESCB/ECB tasks: 
• definition of monetary policy and the monetary 
functions, operations and instruments of the 
ESCB (Articles 1 (2), 4(1), 9, 16 – 21, 159 and 
171 of the MNB Act); 
• conduct of foreign exchange operations 
(Articles 1(2), 4(3), (4) and (12), 9 and 159(2) 
of the MNB Act) and the definition of foreign 
exchange policy (Articles 1(2), 4(4) and (12), 
9, 22 and 147 of the MNB Act); 
• competences of the ECB and of the Council for 
banknotes and coins (Article K of the 
Fundamental Law and Articles 1(2), 4(2) and 
(12), 9, 23, 26 and 171(1) of the MNB Act). 
There are also some imperfections in the MNB Act 
regarding the: 
• non-accurate reflection of the principle of 
central bank independence in the MNB Act 
(Article 1(2) and (3) of the MNB Act);  
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 127 – 
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Convergence Report 2022 
112 
• non-recognition of the role of the ECB in the
functioning of the payment systems (Articles
1(2), 4(5) and (12), 9, 27-28, and 159(2), 171
(2) of the MNB Act);
• non-recognition of the role of the ECB and of
the EU in the collection of statistics (Article
1(2), 30(1) and 171(1) of the MNB Act);
• non-recognition of the role of the ECB in the
field of international cooperation (Article
135(5) of the MNB Act));
• absence of an obligation to comply with the
Eurosystem's regime for the financial reporting
of NCB operations (Article 12(4)(b) and Law C
of 2000/95 (IX.21.) in conjunction with
Government Decree 221/2000 (XII.19.));
• non-recognition of the role of the ECB and the
Council in the appointment of external auditors
(Articles 6(1) (b), 15 and 144 of the MNB Act).
5.1.5. Assessment of compatibility 
As regards central bank independence of the MNB, 
the prohibition on monetary financing and the 
integration of the MNB into the ESCB at the time 
of euro adoption, existing Hungarian legislation is 
not fully compatible with the Treaties and the 
Statute of the ESCB and the ECB pursuant to 
Article 131 of the TFEU. The Hungarian 
authorities are invited to remedy the 
abovementioned incompatibilities. 
5.2. PRICE STABILITY 
5.2.1. Respect of the reference value 
The 12-month average inflation rate, which is used 
for the convergence assessment, has been above 
the reference value since the convergence 
assessment of Hungary in 2018. It has remained 
above 3% since early 2019 and started moving 
further up in spring 2021, surpassing the 5% 
threshold in December. In April 2022, the 
reference value was 4.9%, calculated as the 
average of the 12-month average inflation rates in 
France, Finland and Greece, plus 1.5 percentage 
points. The corresponding inflation rate in 
Hungary was 6.8%, i.e. 2.9 percentage points 
above the reference value. The 12-month average 
inflation rate is projected to remain well above the 
reference value in the months ahead. 
5.2.2. Recent inflation developments 
Over the last two years, HICP inflation was on an 
upward path in Hungary, with unprocessed food 
and energy prices adding volatility to the headline 
figure. Annual HICP inflation accelerated from 
3.4% in 2020 to 5.2% on average for 2021, and 
was as high as 9.6% in April 2022. During the last 
two years, annual HICP inflation in Hungary 
remained above that of the euro area with the 
differential narrowing somewhat in 2021. 
Energy price inflation, which was negative for 
much of 2020, reached double digits in 2021, due 
to rising crude oil prices. The government 
introduced a temporary price cap on motor fuel 
between November 2021 and July 2022. Since 
residential energy is supplied at regulated prices to 
households and these remained unchanged in 2020 
and 2021, the recent higher prices on European 
wholesale gas and electricity markets have had no 
direct effect on consumer prices yet. Instead, the 
higher wholesale price have been absorbed by the 
(mostly state-owned) utility sector, creating a 
fiscal burden. However, the wholesale energy price 
increases have had an indirect impact on consumer 
prices, through the rising costs of companies. 
Processed food price inflation accelerated in 2021, 
reflecting adverse commodity price developments. 
The price of processed food was also affected by 
successive increases of the excise duty on tobacco. 
As of 1 February 2022, the government introduced 
a temporary price cap on some basic food items in 
effect until July 1, 2022. 
Core inflation (measured as HICP inflation 
excluding energy and unprocessed food) eased 
slightly to 3.2% in March 2021 due to the COVID-
19 crisis, but then increased to 9.2% in April 2022, 
signalling broad-based price increases in the wake 
0
2
4
6
8
10
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Hungary Reference value
Graph 5.1: Hungary - Inflation criterion
(percent, 12-month moving average)
Note: The dots at the right end of the chart show the projected reference 
value and 12-month average inflation rate of the country in December 2022.
The reference values for 2016, 2018 and 2020 refer to the reference values 
calculated in the previous Convergence Reports.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 128 –
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Chapter 5 - Hungary 
113 
of the reopening of the economy after the 
pandemic, and also related to the indirect effects of 
the energy price increases. Rising excise duties on 
tobacco added to inflation in 2020 and 2021. 
The prices of non-energy industrial goods have 
been on the rise following the currency 
depreciation that has taken place since early 2020. 
More recently, supply chain disruptions and rising 
commodity prices further exacerbated these trends 
leading to increases in producer and consumer 
prices of industrial goods.  
Overall, service inflation increased in 2020-2021 
due to the rapid recovery of consumer demand, 
fast wage growth and rising energy costs. 
However, this figure has to be taken with some 
caution. The measurement of service prices was 
temporarily disrupted by the pandemic-related 
restrictions on economic activity in spring 2020, 
because the prices of several services could not be 
observed. Service inflation was also affected by 
various government measures (87).  
5.2.3. Underlying factors and sustainability of 
inflation 
Macroeconomic policy mix and growth 
developments 
Hungary’s economy rebounded swiftly after the 
pandemic-induced recession. After contracting by 
4.7% in 2020, real GDP rose by 7.1% in 2021. The 
strong recovery was partly due to the limited 
restrictions related to the COVID-19 crisis after 
spring 2020, and strongly accommodating fiscal 
and monetary policies in 2021. Private 
consumption was boosted by strong wage and 
employment growth. Fiscal stimulus measures 
included the refund of 2021 personal income tax 
payments to families with children children in 
February 2022, the reintroduction of the 13th 
month’s pension in 2021-2022 and wage increases 
in the public sector. Business investment was 
spurred by strong demand, low financing costs and 
investment subsidies from the budget. Public 
investment also remained high. Exports recovered 
after their sharp contraction in spring 2020, but 
they were hampered by supply chain disruptions 
from the second half of 2021. 
Hungary’s economic prospects are strongly 
affected by Russia’s war of aggression against 
Ukraine, due to Hungary’s geographical proximity, 
its high dependence on energy imports from 
Russia, and its relatively strong trade links to both 
countries. High inflation erodes consumers’ 
purchasing power, while investments are hindered 
(87) Examples are the temporary introduction of free parking in
Budapest during the pandemic, and the extension of free
school textbooks to secondary education. 
-2
0
2
4
6
8
10
12
2016 2017 2018 2019 2020 2021
Hungary Euro area
Graph 5.2: Hungary - HICP inflation
(y-o-y percentage change)
Source: Eurostat.
Table 5.1: weights  
Hungary - Components of inflation (percentage change)1) in total   
2016 2017 2018 2019 2020 2021 Apr-22 2022
HICP 0.4 2.4 2.9 3.4 3.4 5.2 6.8 1000
Non-energy industrial goods 1.0 0.4 0.4 1.1 1.2 3.2 5.0 255
Energy -3.7 4.2 4.8 0.5 -3.2 12.4 13.2 113
Unprocessed food 0.0 1.4 6.4 7.0 12.9 2.1 5.7 55
Processed food 1.0 4.0 4.1 5.7 5.9 6.6 8.2 265
Services 1.8 1.9 2.4 4.0 3.8 3.8 5.2 312
HICP excl. energy and unproc. food 1.4 2.1 2.3 3.7 3.7 4.5 6.0 832
HICP at constant tax rates 0.6 2.9 3.4 3.2 3.3 4.7 6.5 1000
Administered prices HICP 0.3 0.3 0.3 1.0 0.3 0.9 2.0 119
1) Measured by the arithmetic average of the latest 12 monthly indices relative to the arithmetic average of the 12 monthly indices
in the previous period.
Source: Eurostat, European Commission calculations.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 129 –
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by weaker demand, uncertainty and tighter 
financing conditions. Exports face headwinds from 
weaker global growth, sanctions against Russia, 
and recurring supply chain bottlenecks. According 
to the Commission’s Spring 2022 Economic 
Forecast, GDP growth is projected slow down to 
3.6% in 2022 and by 2.6% in 2023. 
In 2020-2021, the government provided a large 
fiscal stimulus that helped to mitigate the health 
consequences of the COVID-19 pandemic, 
supported households’ incomes, provided support 
to companies and increased public investment 
activity. The fiscal stance was strongly 
expansionary in 2021, at -3.4% of GDP (88). 
According to the Commission’s Spring 2022 
Economic Forecast, which is based on a no policy 
change assumption, the fiscal stance will continue 
to be broadly neutral in 2022 (at -0.1% of GDP). 
The positive contribution to economic activity of 
expenditure financed by Recovery and Resilience 
Facility grants and other EU funds is projected to 
decrease by 1.0 percentage point of GDP 
compared to 2021 due to expected slowdown in 
the EU funds absorption (89). At the same time, the 
growth in nationally-financed primary current 
expenditure (net of new revenue measures) in 2022 
is projected to provide an expansionary 
contribution of 0.4 percentage points to the overall 
fiscal stance. This includes the additional impact of 
the measures to address the economic and social 
impact of the increase in energy prices (0.1% of 
GDP) as well as the costs to offer temporary 
protection to displaced persons from Ukraine 
(0.2% of GDP).  The no policy-change forecast for 
2023 shows a contractionary stance (1.9%). 
Monetary policy, conducted within an inflation 
targeting framework (90), began tightening in 
summer 2021 in response to rising inflation after 
the use of many policy instruments had ensured 
abundant liquidity in response to the COVID-19 
(88) The fiscal stance is measured as the change in primary
expenditure (net of discretionary revenue measures),
excluding COVID-19 crisis-related temporary emergency
measures but including expenditure financed by
nonrepayable support (grants) from the Recovery and
Resilience Facility and other EU funds, relative to
mediumterm potential growth. A negative (positive) sign of the
indicator corresponds to an excess (shortfall) of primary
expenditure growth compared with medium-term economic
growth, indicating an expansionary (contractionary) fiscal
policy.
(89) The Commission has not yet assessed the Recovery and
Resilience Plan for Hungary. The figures in the text are
based on the projections by the European Commission. 
(90) As explained below, the Hungarian central bank set a target 
inflation of 3% with a symmetric tolerance band of 1%. 
crisis, in particular via FX liquidity swaps (91) and 
long-term collateralised loans, asset purchase 
programs and funding schemes. The base rate (92), 
which had been cut by 30 basis points in the first 
half of 2020, increased from 0.6% to 5.4% 
between June and April 2022. Since this 
instrument is limited in size, monetary conditions 
are rather influenced by the interest rate on the 
one-week deposit rate, which is available without 
limit. The one- week deposit rate was raised from 
0.75% to 6.45% between June 2021 and April 
2022.  
The central bank also took steps to reduce the 
excess liquidity in the financial sector, particularly 
to improve the transmission of higher interest rates 
to the currency market. The FX swap tenders that 
boosted forint liquidity were discontinued from 
November 2021. On the other hand, on March 28, 
in relation to the Russia’s invasion of Ukraine, the 
ECB has decided to extend its temporary bilateral 
repo line to the central bank of Hungary, which 
was due to expire at the end of March 2022, even 
if the size of the agreement will remain unchanged. 
By the end of 2021, the central bank also phased 
out its unconventional monetary policy 
instruments, such as government and corporate 
bond purchases and subsidised lending to small 
and medium sized enterprises.  
Wages and labour costs 
Domestic employment declined by 4.7% in the 
second quarter of 2020, but recovered quickly in 
line with the rebound of output. The employment 
rate rose to a historically high 78.8% in 2021, 
(91) Given the limited effectiveness of the base rate explained
in the next footnote, the MNB, in order to loosen monetary
conditions by boosting liquidity, offered to banks the
possibility to use swaps to buy forint in exchange for
foreign currency from 2016 until 2021. The forints then
entered the money market providing liquidity and lowering
market rates. Indeed market rates were well below the base
rate until March 2020. Moreover, to support the liquidity in
euros where needed, the MNB offered to banks the
possibility to use swaps to buy foreign currency for forint
on short maturities, to help them meet the regulatory
requirements on FX position and liquidity at the end of
each quarter. It should be noted that the MNB, in order to
support FX liquidity for the companies and bank in need of
foreign currency, has also established repo agreements with
the ECB and they function in a similar manner to FX
support in many countries. 
(92) The main policy instrument used by MNB is the 3-month 
deposit, a liability of the central bank, and the base policy
rate is the rate on 3-month central bank deposits. The size
of the deposit is limited. Therefore, this instrument has
limited effectiveness in controlling market liquidity and
other instruments become necessary, among which the FX
liquidity swaps discussed above.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 130 –
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115 
while the unemployment rate remained at 4.1%. 
After a temporary decrease in 2020, the number of 
vacancies returned to earlier levels by the end of 
2021.  
The growth of labour costs slowed down sharply in 
2020 partly reflecting the lower number of hours 
worked. They rose again in 2021 as these 
temporary factors were reversed and labour 
shortages began to re-emerge. Wage growth is 
projected to remain strong in 2022 on the back of a 
20% minimum wage rise, and salary increases in 
the public sector. Wage growth in manufacturing 
and services could diverge, with manufacturing 
wages held back by trade and supply chain 
disruptions, while service sector wages lifted to a 
larger extent by the minimum wage increase and 
also boosted by strong domestic demand in 2022. 
Employers’ social contributions were cut by 2 
percentage points in 2020, and by another 4 
percentage points in 2022. However, the economic 
slowdown is forecast to lead to lower employment 
and wage growth in 2023. 
Labour productivity, measured in terms of GDP 
per worker, declined temporarily in 2020 because 
of labour hoarding during the economic downturn, 
but this trend was reversed in 2021 as the recovery 
gathered steam. These trends led to a fast growth 
of unit labour cost in 2020 (despite slowing wage 
growth), followed by a slowdown in 2021. Large 
wage increases are expected to boost unit labour 
cost again in 2022, but the cooling of the labour 
market is projected to moderate ULC growth again 
in 2023. 
External factors 
Due to the high degree of openness of the 
Hungarian economy, developments in import 
prices play an important role in domestic price 
formation. Import prices contributed to inflation in 
2020 and 2021, first due to the pass-through of 
currency depreciation, and later reflecting the rise 
of global commodity prices. The forint’s nominal 
effective exchange rate (measured against a group 
of 36 trading partners) depreciated by 6.3% in 
2020, and by a further 1.3% in 2021. 
Administered prices and taxes 
The share of administered prices in the Hungarian 
HICP basket (12.4%) is somewhat below the euro 
area average. The share has decreased over past 
years because many administered prices, notably 
for residential energy and other utilities, have 
remained unchanged for several years. 
Administered prices increased by 0.3% in 2020 
and 0.9% in 2021. Overall, administered prices had 
a minor effect on headline inflation, contributing 
between 0-0.1 percentage point in 2020 and 2021. 
Changes in indirect taxation increased headline 
inflation by 0.1 percentage point in 2020 and by 
0.5 percentage point in 2021. This is mainly due to 
rising on excise duty on tobacco. 
Furthermore, the excise duty on motor fuel 
temporarily rose in 2020 when the crude oil price 
fell persistently below 50 USD/barrel. This 
increase was reversed in 2021, in line with the 
legislated formula for the excise duty. The excise 
duty on motor fuel was reduced further in two 
steps in February and March 2022. This measure is 
set to remain in effect until the expiration of the 
price cap on motor fuel currently foreseen on 1 
July 2022. 
Medium-term prospects 
According the Commission’s Spring 2022 
Economic Forecast, inflation is forecast to remain 
high in 2022, reaching 9.0% on average. It is then 
projected to ease to 4.1% in 2023, once the pass 
though of commodity price increases to consumer 
prices is completed and slowing demand begins to 
weigh on core inflation. Inflation is projected to 
return to the central bank’s target towards the end 
of 2023. 
Energy-related policy measures have a significant 
impact on inflation in 2022. In April 2022, the 
price cap on petrol and gasoline was estimated to 
be on average 22% below the levels warranted by 
market conditions, reducing inflation by 
approximately 1.5 percentage point in April. The 
-4
0
4
8
12
2016 2017 2018 2019 2020 2021 2022 2023
Productivity (real GDP per person employed)
Nominal compensation per employee
Nominal unit labour costs
HICP inflation
Graph 5.3: Hungary - Inflation, productivity and wage trends
(y-o-y % change)
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 131 –
European Commission 
Convergence Report 2022 
116 
price cap on certain food items lowered inflation 
further, although the weight of the affected 
products is smaller in the HICP basket. 
There are upside risks to the inflation outlook. The 
current level of administered residential energy 
prices creates significant losses in the largely
stateowned utility sector. If wholesale energy prices 
remain persistently high, the pressure to raise 
consumer prices could also increase significantly. 
The tight labour market and high inflation 
expectations are further sources of inflationary risk 
even if this was not visible yet. 
The level of consumer prices in Hungary stood at 
about 63% of the euro area average in 2020, with 
the relative price gap larger for services than for 
goods. This suggests that there is significant 
potential for price level convergence in the long 
term, as GDP per capita in PPS (72.4% of the euro 
area average in 2021) increases towards the euro 
area average. 
Medium-term inflation prospects will depend 
strongly on wage and productivity developments, 
notably in the non-traded sector and on the success 
with anchoring inflation expectations at the central 
bank’s 3% target. 
5.3. PUBLIC FINANCES 
5.3.1. Recent fiscal developments 
The general government deficit remained high 
over the 2020-2021 period, reaching 7.8% of GDP 
in 2020 up from 2.1 in 2019, before declining 
somewhat to 6.8% of GDP in 2021.  
Revenues as a share of GDP remained broadly 
stable in 2020 at 43.4% but dropped to 41.1% in 
2021. The considerable decline in the revenue ratio 
in 2021 reflects largely the impact of
deficitincreasing recovery measures, such as a permanent 
cut in employers’ social contribution rate, a
oneoff refund of income tax to families in early 2022, 
a lowering of the VAT rate for newly built houses 
and a cut in business tax. The expenditure-to-GDP 
ratio surged to 51.2% in 2020, from 46% in 2019, 
due to increased discretionary spending and lower 
GDP (denominator effect). The nominal growth of 
expenditure moderated in 2021 but the ratio 
remained at 47.9%, significantly above the
precrisis level. The increase in expenditure in 2020 
reflected the introduction of temporary emergency 
measures in response to COVID-19 crisis (4.5% of 
GDP) and additional spending from the Country 
Protection Fund. In 2021, spending was gradually 
directed away from the COVID-related measures 
(only 0.6% of GDP in 2021) and towards recovery 
measures (0.4% of GDP).   
Table 5.2:
Hungary - Other inflation and cost indicators (annual percentage change)
2016 2017 2018 2019 2020 2021 20221) 20231)
HICP inflation
Hungary 0.4 2.4 2.9 3.4 3.4 5.2 9.0 4.1
Euro area 0.2 1.5 1.8 1.2 0.3 2.6 6.1 2.7
Private consumption deflator
Hungary 1.0 3.3 3.3 4.6 3.3 6.3 9.0 4.1
Euro area 0.4 1.3 1.5 1.1 0.5 2.3 5.8 2.7
Nominal compensation per employee
Hungary 2.4 7.0 6.4 6.9 3.0 9.2 8.7 6.5
Euro area 1.2 1.7 2.1 2.1 -0.7 4.1 3.6 3.5
Labour productivity
Hungary -1.5 2.3 3.0 3.4 -3.4 5.0 1.9 1.9
Euro area 0.4 1.0 0.2 0.3 -4.9 4.2 1.4 1.5
Nominal unit labour costs
Hungary 4.0 4.6 3.3 3.4 6.6 4.0 6.7 4.5
Euro area 0.8 0.7 2.0 1.9 4.4 0.0 2.2 2.0
Imports of goods deflator
Hungary -2.5 1.9 4.0 1.2 2.7 11.7 10.4 -1.7
Euro area -3.3 3.3 2.6 -0.5 -3.8 9.6 13.2 0.8
1) Commission Spring 2022 Economic Forecast.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 132 –
Convergence Report 2022 - Technical annex 
Chapter 5 - Hungary 
117 
The 2021 budgetary outturn was below the 7.5% 
GDP deficit target set in the 2021 Convergence 
Programme essentially due to stronger-than 
expected growth, and this despite significantly 
higher expenditure. The real GDP growth of 7.1% 
was well above 4.3% expected in the Convergence 
Programme. The stronger-than-expected rebound 
in economic activity was broad-based, with 
investments and exports considerably exceeding 
expectations. However, the additional fiscal space 
generated by higher revenues and higher 
denominator were offset by higher-than-projected 
expenditure, especially on social benefits, 
intermediate consumption and compensation of 
employees. Additionally, following the submission 
of the Convergence Programme, the authorities 
also extended some of the temporary tax relief 
measures and introduced new expansionary 
measures such as a refund of income tax to 
families in early 2022 and a one-off income 
support for self-employed. 
The government debt-to-GDP ratio rose from 
65.5% in 2019 to 79.8% in 2020 and stabilised at 
76.8% by the end of 2021. The increase in 2020 
was driven mainly by the high primary balance and 
debt-increasing stock-flow adjustment due to 
growing fiscal reserves in the form of government 
deposits held by the central bank. In 2021, the 
debt-decreasing impact of high GDP growth and 
inflation was largely offset by the high budget 
deficit. 
5.3.2. Medium-term prospects 
The 2022 budget was adopted by the Hungarian 
Parliament on 15 June 2021. It targeted a headline 
deficit of 5.9% of GDP, and included emergency 
reserves of 0.4% of GDP to cover potential 
slippages based on risk scenarios. As in 2021, the 
2022 budget included large budgetary reserves to 
finance additional investment activity and support 
the economic recovery, notably appropriations for 
the Investment Fund and Economic Restart 
programmes. The budget allowed for the 
continuation of several debt-increasing spending 
measures such as subsidies for housing renovation 
for families (0.3% of GDP), partial reinstatement 
of the 13th month’s pension and increase in 
doctors’ wages (0.8% of GDP). It also envisaged 
new tax measures, notably further cuts to 
employers’ social contributions (0.3% of GDP) 
and exemption from personal income tax for those 
under 25 years old (0.2% of GDP).  
Since the adoption of the budget, several new 
measures have been introduced by government 
decrees on the back of better-than expected 
growth. Those include further cuts to social 
security contributions and the abolition of the 
training levy (0.9% of GDP), a full reinstatement 
of the 13th month’s pension already in 2022 (0.6% 
of GDP), and a service benefit for military and law 
enforcement employees brought forward to 2022 
(0.4% of GDP). In late 2021, amid rising 
macroeconomic uncertainty, the government 
revised the deficit target from 5.9% to 4.9%. The 
 
 
   
 
 
Table 5.3:
Hungary - Budgetary developments and projections (as % of GDP unless indicated otherwise)
Outturn and forecast 1) 2016 2017 2018 2019 2020 2021 20221) 20231)
General government balance -1.8 -2.5 -2.1 -2.1 -7.8 -6.8 -6.0 -4.9
- Total revenue 45.0 44.3 44.0 43.9 43.4 41.1 41.3 41.4
- Total expenditure 46.8 46.7 46.1 46.0 51.2 47.9 47.3 46.4
   of which: 
- Interest expenditure 3.1 2.6 2.3 2.2 2.3 2.3 2.7 3.0
p.m.: Tax burden 39.2 38.0 36.9 36.5 36.2 33.8 35.0 34.9
Primary balance 1.3 0.2 0.2 0.1 -5.5 -4.4 -3.3 -1.9
Fiscal stance 2) 1.4 -3.4 -0.1 1.9
Government gross debt 74.8 72.1 69.1 65.5 79.6 76.8 76.4 76.1
p.m: Real GDP growth (%) 2.2 4.3 5.4 4.6 -4.5 7.1 3.6 2.6
1) Commission’s Spring 2022 Economic Forecast. 
2) A negative (positive) sign of the indicator corresponds to an excess (shortfall) of primary expenditure growth 
compared with medium-term economic growth, indicating an expansionary (contractionary) fiscal policy.
Source: European Commission.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 133 – 
European Commission 
Convergence Report 2022 
118 
achievement of the lower deficit target was 
supported by the decision to postpone investment 
projects in the size of 1.3% GDP, notably those 
funded by the Investment Fund. 
The government deficit in 2022 is also impacted 
by the fiscal costs of the measures taken by the 
government to counter the social and economic 
impact of the increase in energy prices, as well as 
the provision of humanitarian assistance to 
refugees from Ukraine. These measures mainly 
consist of permanent price caps on retail gas and 
electricity prices, a temporary cut in excise duties 
on fuels, a temporary cap on fuel prices and 
compensations for independent petrol stations.      
On 29 April 2022, Hungary submitted its 2022 
Convergence Programme. According to the 
Programme, the headline deficit is projected to 
decline steadily to 4.9% of GDP in 2022 and 3.5% 
in 2023. The government deficit in 2022 is 
impacted by the introduction of several 
expansionary measures, notably the full
reintroduction of the 13th monthly pension, a one-off 
service benefit for military and law enforcement 
employees, cuts to social security contributions 
and abolition of the training levy.  
Based on the Commission's Spring 2022 Economic 
Forecast, the deficit is projected to decrease to 
6.0% of GDP in 2022, above the official target set 
out in the 2022 Convergence Programme reflecting 
the introduction of several expansionary 
measures and additional spending related to high 
energy prices. According to the Commission’s 
Spring 2022 Economic Forecast, the fiscal stance 
is projected to be broadly neutral in 2022 at -0.1% 
of GDP (93).  The contribution to economic 
activity of expenditure financed by Recovery and 
Resilience Facility grants and other EU funds is 
projected to be contractionary at 1.0% percentage 
point of GDP in 2022, compared to the 
contribution of -0.4% in 2021. Nationally financed 
investments are projected to provide a slightly 
expansionary contribution to the fiscal stance of -
0.2 percentage point of GDP in 2022.  At the same 
time, the growth in nationally financed primary 
current expenditure (net of new revenue measures) 
in 2022 is projected to provide an expansionary 
contribution of -0.4 percentage point of GDP to the 
overall fiscal stance, as current expenditure is set 
to grow at a faster pace than medium-term 
(93) For a definition of the fiscal stance used in this report, see
footnote in in Section 5.2.3 on underlying factors and
sustainability of inflation. 
potential growth. However, most of this expansion 
is due to measures related to the energy crisis 
(1.2% of GDP) and the humanitarian aid for 
people fleeing Ukraine (0.2% of GDP). The 
measures in response to rising energy prices 
mainly consist of permanent price caps on retail 
gas introduced in and electricity prices introduced 
in 2013, a temporary cut in excise duties on fuels, 
a temporary cap on fuel prices and compensations 
for independent petrol stations. The large fiscal 
impact of the energy measures in the 
Commission’s Spring 2022 Economic Forecast 
stems from the assumption that the losses of the 
utility companies resulting from the regulated 
energy prices are compensated by the government 
with capital transfers at the end of the year. All 
measures other than the permanent price caps on 
retail gas and electricity prices have been 
announced as temporary. Some of these 
measures are not targeted in nature, notably the 
general price cap on retail prices of energy and 
cuts in excise duties. 
The phasing out of several temporary measures 
and an expected overall decrease in nationally 
financed current expenditure in 2023 will 
contribute to a strongly contractionary fiscal stance 
of 1.9% of GDP in 2023.   
The contribution to economic activity of 
expenditure financed by Recovery and Resilience 
Facility grants and other EU funds is projected to 
be expansionary at -0.3 percentage point of GDP 
in 2023. Nationally financed investment is 
projected to provide an expansionary contribution 
to the fiscal stance of -0.4 percentage point of 
GDP, whereas the growth in nationally financed 
primary current expenditure is projected to provide 
a contractionary contribution of 1.9 percentage 
point of GDP to the overall fiscal stance in 2023. 
-5
-4
-3
-2
-1
0
1
2
3
2020 2021 2022 2023
Net nationally financed  primary current expenditure Nationally financed investment
Other capital expenditure Expenditure financed by RRF grants and EU funds
Fiscal stance
Expansionary
Contractionary
Graph 5.4: Hungary - Fiscal stance and its components
(percent of GDP)
Source: Commission's Spring 2022 Economic Forecast. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 134 –
Convergence Report 2022 - Technical annex 
Chapter 5 - Hungary 
119 
Based on the Commission’s Spring 2022 
Economic Forecast, the general government debt is 
set to decrease gradually from 79.2% of GDP in 
2021 to 76.4% in 2022 and 76.1% in 2023. The 
2022 Convergence Programme projects a more 
rapid decline in the debt-to-GDP ratio to 76.1% in 
2022 and 73.8% in 2023. The difference is driven 
by higher primary deficit in 2023 in the 
Commission’s forecast.  
Debt sustainability risks appear medium over the 
medium run. Government debt is projected to 
decrease reaching around 73% of GDP in 2032. 
This projection assumes that the structural primary 
balance (except for the impact of ageing) remains 
constant at the forecast level for 2023 of -1.4% of 
GDP, which is close to its 2019 level. 
The sensitivity to possible macro-fiscal shocks also 
contributes to this assessment. In particular, if only 
half of the projected improvement in the structural 
primary balance in 2022-2023 were to occur, the 
projected debt ratio in 2032 would be close to 13 
percentage points of GDP higher than in the 
baseline, and would not be on a decreasing path 
anymore.  
Some factors mitigate risks, including the 
lengthening of debt maturity in recent years 
(although it remains relatively low), relatively 
stable financing sources (with a diversified and 
large investor base) a stable and moderate share of 
government debt denominated in foreign currency 
and the expected positive impact on long-term 
growth of reforms under the Recovery and 
Resilience Plan. Risk-increasing factors include 
the possible materialisation of state guarantees 
granted to firms and self-employed during the 
COVID-19 crisis (94). 
In recent years, the Hungarian fiscal framework 
has seen certain improvements. With reforms 
starting after 2011, the national fiscal rules were 
brought more in line with EU requirements, for 
example on the way the public debt ratio is 
calculated. The national Hungarian debt rule was 
later reformed in order to include a stronger role 
for the Fiscal Council (Hungary’s independent 
fiscal institution) in ensuring compliance with the 
debt rule. In some cases however, the role of the 
Fiscal Council in shaping fiscal policies could be 
reinforced, in particular when it comes to ex-post 
evaluations and endorsement of the budgetary 
                                                          
(94) For further details see the 2021 Fiscal Sustainability 
Report. 
forecasts. The medium-term budgetary framework 
has been further developed since 2011, but could 
still be improved in order to reduce the volatility of 
the medium-term plans. The link between the 
targets in annual budgets and the medium-term 
framework can be strengthened, as well as the 
involvement of the independent fiscal institution 
and national parliament in the preparation of this 
medium-term framework. 
5.4. EXCHANGE RATE STABILITY 
The Hungarian forint does not participate in 
ERM II. Between mid-2001 and early 2008, the 
MNB operated a mixed framework that combined 
an inflation target with a unilateral peg of the 
forint to the euro, with a fluctuation band of  
+/-15%. On 26 February 2008, the exchange rate 
band was abolished and a free-floating exchange 
rate regime was adopted that however allows for 
foreign exchange interventions by MNB. In March 
2015, a +/-1 percentage point ex ante tolerance 
band was designated around the continuous 
medium-term inflation target of 3 percent (that is 
in place since 2005). 
  
The long-term depreciation tendency of the last 
years continued in 2020 and 2021. In particular, a 
steep depreciation movement of the forint against 
the euro started in spring 2019, when the forint 
traded below 320 HUF/EUR, following the MNB 
signal to keep loose monetary conditions longer 
than other regional central banks. As a result of the 
COVID-19 crisis, it continued until October 2020 
when the forint surpassed the 360 HUF/EUR. 
Afterwards, the forint oscillated around this value 
until Russia’s invasion of Ukraine in February 
2022. After the invasion, the forint initially 
depreciated strongly to near 400 HUF/EUR but it 
then returned to the range of 370-380 HUF/EUR 
after the central bank raised interest rates further. 
260
280
300
320
340
360
380
400
2016 2017 2018 2019 2020 2021
Graph 5.5: Hungary - HUF/EUR exchange rate
(monthly averages)
Source: ECB.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 135 – 
European Commission 
Convergence Report 2022 
120 
In April 2022 it traded against the euro on average 
at about 375 HUF/EUR. 
International reserves held by the MNB that had 
already reached around EUR 28bn end-2019, 
moved above EUR 30bn mid-2020 and above 
EUR 38bn in September 2021. International 
reserves were lifted by successive foreign currency 
bond issuances, EU fund inflows and an increase 
in special drawing rights by some EUR 2.3 bn in 
August 2021. At the same time, the outstanding 
stocks of liquidity-providing FX swaps in euros 
are gradually unwinding, which reduces the 
international reserves at the central bank (95). 
International reserves, decreased to EUR 34bn in 
April 2022, which corresponded to about 22% of 
GDP. 
Short-term interest rate differentials vis-à-vis the 
euro area increased substantially after the 
beginning of the COVID-19 crisis, when the 
previous upward movement was strongly 
accentuated. The spread trespassed the 100 basis 
points in March 2020, to reach the 130 basis points 
two months later. After a temporary decrease in 
summer 2020, the spread started increasing again 
and it came back to 130 basis point in January 
2021. There it stabilised until June 2021 when it 
started increasing steeply, with euro area 3-months 
rates remaining at around -0.55% while the 3-
months Bubor was increasing very fast, reflecting 
the rapid tightening of monetary policy and later 
the interventions following Russia’s invasion of 
Ukraine. The spread continued reached 705 basis 
points in April 2022.  
(95) The reduction concerns the swaps used by banks to buy
forint in exchange for foreign currency from 2016 until
2021.
5.5. LONG-TERM INTEREST RATES 
The long-term interest rate in Hungary used for the 
convergence assessment reflects the secondary 
market yields on a single benchmark bond with a 
residual maturity of about 10 years.  
The Hungarian 12-month moving average
longterm interest rate relevant for the assessment of the 
Treaty criterion was below the reference value at 
the time of the 2020 convergence assessment of 
Hungary. It decreased from the 3.3% of May 2019 
to reach 2.1% in July 2020 and then started to 
increase again. In April 2022, the latest month for 
which data are available, the reference value, given 
by the average of long-term interest rates in 
France, Finland and Greece, plus 2 percentage 
points, stood at 2.6%. In April, the 12-month 
moving average of the yield on the Hungarian 
benchmark bond stood at 4.1%, i.e. 1.5 percentage 
points above the reference value. 
The long-term interest rate of Hungary, which 
stood just around 2.0% in January 2020, peaked in 
April at 2.5% and has been oscillating below this 
level until January 2021, reflecting also the 
monetary easing conducted by major central 
banks. Hungary's long-term interest rate started 
increasing again in 2021, in particular since 
September 2021, reflecting the tightening of 
monetary policy, to surpass 4% in November. This 
mirrored the rapid tightening of monetary policy 
and accelerating inflation pressures in Hungary. 
0
100
200
300
400
500
600
700
800
2016 2017 2018 2019 2020 2021
Graph 5.6: Hungary - 3-M Bubor spread to 3-M Euribor
(basis points, monthly values)
Source: National Bank of Hungary, Eurostat and Thomson Reuters.
0
2
4
6
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Hungary Reference value
Graph 5.7: Hungary - Long-term interest rate criterion
(percent, 12-month moving average)
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 136 –
Convergence Report 2022 - Technical annex 
Chapter 5 - Hungary 
121 
          
The increase in long-term rates continued, and 
accelerated further since March 2022, on the back 
of Russia’s invasion of Ukraine. The long-term 
rate reached 6.6% in April 2022. Despite the slight 
increase of rates on the German benchmark bond 
over the same period, the long-term spread vis-
àvis the German benchmark bond increased over 
the last two years and reached 584 basis points in 
April 2022. 
5.6. ADDITIONAL FACTORS 
The Treaty (Article 140 TFEU) calls for an 
examination of other factors relevant to economic 
integration and convergence to be taken into 
account in the assessment. The assessment of the 
additional factors – including balance of payments 
developments, as well as product, labour and 
financial market integration – gives an important 
indication of a Member State's ability to integrate 
into the euro area without difficulties.  
In November 2021, the Commission published its 
latest Alert Mechanism Report (AMR 2022) under 
the Macroeconomic Imbalance Procedure (MIP - 
see also Box 1.7), which highlighted issues related 
to unit labour costs, government debt financing 
and the housing market in Hungary. Unit labour 
cost growth is projected to pick up after the 
pandemic, as productivity growth continues to lag 
behind substantial wage rises that are driven by the 
tightening labour market and administrative 
measures. Although the maturity of government 
debt increased, the gross financing need remains 
high, which could create risks if global financing 
conditions deteriorate. Real house prices continued 
to grow after the pandemic, supported by various 
government subsidies for home buying. A debt 
moratorium was introduced during the pandemic 
and a temporary cap on mortgage rates in the first 
half of 2022. They both expire on 1 July 2022. The 
-2
0
2
4
6
8
2016 2017 2018 2019 2020 2021
Hungary Germany
Graph 5.8: Hungary - Long-term interest rates
(percent, monthly values)
Source: Eurostat.
 
 
    
 
 
Table 5.4:
Hungary - Balance of payments (percentage of GDP)
2016 2017 2018 2019 2020 2021
Current account 4.5 2.0 0.2 -0.7 -1.0 -2.9
of which: Balance of trade in goods 3.4 1.4 -1.7 -2.5 -0.9 -2.5
                 Balance of trade in services 5.3 5.5 5.9 4.9 2.9 3.2
                 Primary income balance -2.6 -3.9 -3.7 -2.5 -2.5 -3.0
                 Secondary income balance -1.5 -0.9 -0.4 -0.5 -0.6 -0.7
Capital account 0.0 0.8 2.3 1.9 2.0 2.5
External balance 1) 4.5 2.8 2.5 1.2 1.0 -0.4
Financial account 3.0 1.4 0.8 0.2 -1.7 -3.1
of which: Direct investment -2.3 -1.6 -2.2 -0.2 -1.9 -1.3
                Portfolio investment 4.2 3.0 -0.1 1.0 -1.9 0.2
                Other investment 2) 6.4 0.0 0.5 -0.8 -2.4 -4.4
                Change in reserves -5.3 0.0 2.7 0.2 4.5 2.4
Financial account without reserves 8.3 1.4 -1.9 0.0 -6.2 -5.5
Errors and omissions -1.5 -1.4 -1.7 -0.9 -2.7 -2.7
Gross capital formation 21.5 23.1 26.8 28.5 27.3 30.6
Gross saving 25.7 24.7 26.8 27.6 26.2 27.7
Net international investment position -59.0 -54.4 -50.7 -49.1 -48.9 -44.8
1) The combined current and capital account.
2) Including financial derivatives.
Sources: Eurostat, European Commission calculations, Magyar Nemzeti Bank.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 137 – 
European Commission 
Convergence Report 2022 
122 
phase-out of these measures could pose challenges 
for some borrowers and thus for the banking sector 
whose tier-1 capital ratio is lower than the EU 
average. The profitability of banks is also affected 
by increasing funding costs and losses on their 
government bond holdings due to the rise in yields. 
Some Hungarian banks have Russian and 
Ukrainian exposures either directly or through 
their parent companies, and this might also weigh 
on the banking sector’s profitability and capital 
situation. However, since overall risks remained 
limited, no In-Depth Review (IDR) was warranted. 
Hungary submitted its Recovery and Resilience 
plan on 11/05/2021. The submitted plan has a total 
allocation of EUR 7.175bn and contains proposed 
investments and reforms to strengthen primary 
care and hospitals, increase the capacity of 
suburban rail and increase renewable energy 
production at residential level. The plan is 
currently being assessed by the Commission to 
make sure that all assessment criteria are being 
fulfilled. 
5.6.1. Developments of the balance of 
payments 
According to balance of payments data, the surplus 
of Hungary’s external balance (i.e. the combined 
current and capital account) turned negative in 
2020. It decreased from a surplus 0.2% of GDP in 
2018 to a deficit of 2.9% of GDP in 2021. Exports 
fell in 2020 due to the pandemic. Goods exports 
then staged a robust recovery until mid-2021, but 
they were held back by growing supply chain 
disruptions (e.g. semiconductor shortages) in the 
second half of 2021. Service exports declined more 
than goods exports in 2020. Their rebound in 2021 
also proved slower as the pandemic hindered the 
recovery of international tourism. Imports 
decreased in 2020 but robust domestic demand led 
to their strong recovery in 2021. Following global 
energy prices, the terms of trade improved in 2020 
but worsened in 2021. The primary income 
balance deteriorated especially in 2021, as the 
inward investment income flows recovered slower 
than outward flows. The capital account remained 
in surplus due to the absorption of EU funds. 
Price and cost competitiveness indicators 
improved in early 2020 due to a nominal currency 
depreciation at the outbreak of the COVID-19 
pandemic. Apart from some fluctuations, real 
effective exchange rates remained stable in the 
remainder of 2020 and in 2021. While the growth 
of ULC and consumer prices was higher in 
Hungary than in its trade partners, this was mostly 
offset by nominal depreciation over the course of 
2020 and 2021 (96).  Hungary’s export market 
share increased in 2020 and 2021. 
According to the Commission’s Spring 2022 
Economic Forecast, which is based on national 
accounts data, the external balance is expected to 
deteriorate in 2022 and 2023. This is mainly driven 
by rising commodity prices, which worsen 
Hungary’s terms of trade and swell its net energy 
imports that amounted to 4.4% of GDP in 2021. 
The current account deficit is projected to peak at 
5.5% of GDP in 2022 before improving to 3.6% in 
2023 due to somewhat lower energy import prices. 
As the deteriorating external balance was due to 
higher budget deficits, it was mostly financed by 
the external borrowing of the government sector. 
The government also used freshly raised funds to 
bolster foreign currency reserves. Consequently, 
the inflows of portfolio and other investments rose 
in 2020 and 2021, and gross external debt rose. 
Meanwhile, direct investments continued to 
register net inflows in 2020 and 2021. The net 
international investment position posted slight 
improvements in 2020 and 2021. 
(96) REER based on unit labour costs should be interpreted with 
prudence as unit labour costs were distorted by labour
retention schemes. 
80
90
100
110
2016 2017 2018 2019 2020 2021
Graph 5.9: Hungary - Effective exchange rates
NEER REER, HICP deflated REER, ULC deflated
(vs. 36 trading partners;  monthly averages;
index numbers, 2016 = 100)
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 138 –
Convergence Report 2022 - Technical annex 
Chapter 5 - Hungary 
123 
5.6.2. Market integration 
Hungary’s economy is highly integrated with the 
euro area through trade and investment linkages. 
The economy is strongly embedded into 
continental and global value chains. Trade 
openness increased somewhat in 2021 to 89.5%, 
after the strong decrease of 2020 when 
international trade and Hungary’s exports of 
tourism and travel services were temporarily hit by 
the pandemic. Flows with the euro area dominate 
trade, accounting for more half of the total trade in 
goods and services in 2021. Hungary’s main euro 
area goods trading partners in 2021 were Germany, 
Austria, Slovakia and Italy. Outside the euro area, 
the main trading partners were China and Poland.   
The stock of FDI in Hungary amounted to about 
63% of GDP in 2020 (excluding special purpose 
entities, ‘SPEs’ (97) ), with FDI mainly originating 
from Germany, the Netherlands and Austria. 
Manufacturing and services each accounted for 
about 45% of inward FDI, suggesting that FDI 
plays an important role in enhancing Hungary’s 
export capacity and contributes significantly to 
economic integration with the euro area. 
Concerning the business environment, Hungary 
performs in general worse than many euro-area 
Member States in international rankings, even if 
certain features of Hungary’s business 
environment, such as low corporate taxes, flexible 
labour market regulations and the authorities’ 
supportive attitude towards export-oriented FDI, 
make the country attractive for the more
labourintensive and cost-sensitive tasks within global 
value chains. However, Hungary scores poorly 
according to the World Bank's Ease of Doing 
Business and the Global Competitiveness Index 
rankings by the International Institute for 
Management Development (98). According to the 
World Bank's Worldwide Governance Indicators 
(2020), Hungary ranks low in voice and 
accountability, and control of corruption compared 
with the average of the five euro area Member 
                                                          
(97) The Hungarian statistics introduced the notion of special 
purpose enterprise (SPE) for those passive financial 
intermediaries that have financial relations only with
nonresidents, and allocated them to the financial corporations 
sector as private financial intermediaries (S.127).” They are 
typically related to tax optimization by holdings. See a-
nem-penzugyi-vallalatok-penzugyi-szamlai-en.PDF 
(mnb.hu), page 8. 
(98) The World Bank Doing Business (DB) program was 
paused in 2021. The programme will continue with a new 
governance and improved accountability and transparency 
under the name Business Enabling Environment (BEE). 
The first edition of the BEE is expected in 2023. 
States with the lowest scores. Hungary ranks 
higher than the average five lowest euro area 
Member States for political stability and absence 
of violence (99).  The Commission’s 2021 Rule of 
Law Report, elaborated on the challenges that 
Hungary faces in areas such as the control of 
corruption, judicial independence and the quality 
of decision-making. Shortcomings in the
anticorruption framework include the unaddressed 
links between businesses and political actors, such 
as the lack of effective checks and oversight of 
asset and interest declarations. Concerns remain 
over cases of high-level corruption. In December 
2021, the government postponed the 
implementation of most measures in its
anticorruption strategy for 2020-22, which would have 
helped to more effectively detect and prosecute of 
corruption in public institutions and state-owned 
enterprises. Access to public information, which is 
essential for the independent oversight of
decisionmaking and anti-corruption framework, was made 
more difficult by special rules introduced by 
Hungary during the state of danger.  These issues 
can be particularly detrimental to innovative 
companies. In addition, several barriers hamper 
competition in services, including the large 
number of regulated occupations, untransparent 
state interventions and inefficient insolvency 
procedures. According to the latest data, 
Hungary’s transposition deficit of EU Directives 
was at 1.0%, similar to the EU average but above 
the target (0.5%) proposed by the European 
Commission in the Single Market Act (2011). 
    
 
                                                          
(99) A Member State is considered to have a ‘low’ (‘high’) 
ranking compared with the average five euro area Member 
States with the lowest scores for each indicator if its score 
is at least 0.3 percentage points lower (higher) than that of 
the average of this euro area group. 
0.0
0.4
0.7
1.1
1.4
Voice and Accountability
Political Stability and Absence
of Violence/Terrorism
Government Effectiveness
Regulatory Quality
Rule of Law
Control of Corruption
Hungary Euro area average five lowest Euro area average
Graph 5.10: Hungary - 2020 World Bank's Worldwide Governance Indicators
Note: Estimate of governance ranges from -2.5 (weak) to 2.5 (strong). 
Source: World Bank.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 139 – 
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The 4th Anti-Money Laundering Directive 
imposed transposition by 26 June 2017, and 
Hungary notified the Commission of the adopted 
measures within that deadline. New measures were 
notified during 2019 and 2020. The Commission 
has analysed the communicated measures and 
concluded that the directive has been fully 
transposed. As regards the 5th Anti-Money 
Laundering Directive, whose transposition 
deadline elapsed on 10 January 2020, Hungary has 
notified national transposition measures and 
declared a partial transposition. In view of some 
missing transposition measures the Commission 
has addressed a letter of formal notice (“LFN”) to 
Hungary on 13/02/2020 and a Reasoned Opinion 
on 09/06/2021 as the reply to the LFN was not 
satisfactory. At the same time, new transposition 
measures were notified in June 2021 and the 
Commission is currently assessing whether they 
address the gaps in transposition. 
The size of the financial sector, measured as the 
ratio of assets managed by the financial sector to 
GDP, is in Hungary slightly more than half of the 
comparable euro area average, while being less 
than half in 2016, indicating a faster growth than in 
the euro area in recent years. However, when 
excluding SPEs that perform no financial 
intermediation in the domestic economy, the size 
of the total financial sector grew from 162% of 
GDP in 2016 to 193% in 2020, indicating both a 
much lower level of financial development and 
convergence with the euro area. Taking into 
account this correction, Hungary can be considered 
similar in terms of financial sector size to the euro 
area members with the least developed financial 
sectors. 
Due to the presence of SPEs, the structure of the 
financial sector is different from the euro area 
average, where the banking sector is the largest 
sub-sector in the financial sector. In Hungary 
banking accounts for a quarter of the financial 
sector’s assets (109% of GDP), decreasing from 
almost 30% (98% of GDP) in 2016, against a 39% 
(311% of GDP) in the euro area. Other financial 
intermediaries, which cover SPEs, make up for 
60% of total financial assets and 259% of 
GDP (100). Without SPEs, the banking sector 
shows a large and relatively stable weight, with 
around 60% of total assets in 2016 (around 160% 
of GDP) and 58% in 2020 (around 190% of GDP). 
With this correction, the financial system can be 
assessed as even more bank-based than the EU 
average. The weight of the central bank is also 
higher than the EU average if SPEs are excluded, 
as it accounted for 16% (27% of GDP) of total 
(100) As indicated above, this likely reflects the large presence of
foreign holdings in Hungary for tax optimization purposes. 
Table 5.6:
Hungary - Allocation of assets by financial sub-sector
Ratio to GDP (%)
HU EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Financial corporations (total) 335 435 722 796 177 215
Central bank 27 41 45 78 37 61
Monetary financial institutions 98 109 286 311 97 98
Other financial intermediaries 185 259 202 179 20 28
Non-MMF investment funds1) 14 14 100 127 4 5
Insurance co. and Pension Funds 12 11 90 102 18 23
Share of total (%)
HU EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Central bank 8 9 6 10 21 29
Monetary financial institutions 29 25 40 39 55 46
Other financial intermediaries 55 60 28 22 11 12
Non-MMF investment funds 4 3 14 16 2 2
Insurance co. and Pension Funds 4 3 12 13 10 11
1) MMF stands for money market funds.
Source: Eurostat.
Table 5.5:
Hungary - Market integration
2016 2017 2018 2019 2020 2021
Trade openness 1) (%) 91.9 93.3 92.5 91.1 87.9 89.6
Trade with EA in goods &amp; services 2)+3) (%) 53.1 53.2 52.3 51.7 49.8 50.5
World Bank's Ease of Doing Business Index rankings 4) 41 48 53 52 52 -
IMD World Competitiveness Ranking 5) 46 52 47 47 47 42
Internal Market Transposition Deficit 6) (%) 0.8 0.3 0.9 0.5 1.0 -
Real house price index 7) 112.3 121.9 135.0 150.9 153.4 166.5
 1) (Imports + Exports of goods and services / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics, Balance of Payments).
 2) (Imports + Exports of goods with EA-19 / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics).
 3) Trade in services with EA-19 (average credit and debit in % of GDP at current prices) (Balance of Payments).
 4) Data not available for 2021. The Ease of Doing Business report by the World Bank was discontinued in September 2021. 
 5) International Institute for Management Development (IMD).
 6) Percentage of internal market directives not yet communicated as having been transposed, relative to the total.
(November data, as of 2016 date refers to the year of publication).
 7) Deflated house price index (2015=100) (Eurostat). 
Sources: Eurostat, World Bank, International Institute for Management Development, European Commission calculations.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 140 –
Convergence Report 2022 - Technical annex 
Chapter 5 - Hungary 
125 
non-consolidated assets in 2016, which rose to 
21% by 2020 (40% of GDP).  
Insurance companies and pension funds are clearly 
underdeveloped compared to the euro area, with 
assets representing 3% of total assets of the 
financial sector, for an amount of 11% of GDP. 
This is very small also compared to the countries 
with the smallest shares in the euro area. Since 
end-2016, the Hungarian sector has decreased its 
holdings of financial assets by 1 percentage point 
of GDP, while in the euro area it increased by 
more than 12 percentage points of GDP to reach 
13% of total assets. 
This structure of the financial sector is reflected in 
the financing of the economy, which traditionally 
shows relatively low intermediated and market 
credit to households and non-financial 
corporations. Funding via other equity, possibly 
reflecting the relevant presence of foreign holdings 
and SPEs in Hungary, remained at 40% of total 
liabilities in 2020, representing 261% of GDP. 
This compares to an average of 7% for the euro 
area (56% of GDP). Considering also the role of 
unlisted shares, one almost reaches 50% of total 
liabilities, which are not allocated via the banking 
sector. This is still much higher than the average 
euro area and compares with countries like Estonia 
or Cyprus. 
For the rest, loans are the dominant source of 
funding and made up 29% of total liabilities, 
which represented almost 190% of GDP in 2020, 
posting a very large increase compared to the 25% 
of 2016. This figure is inflated by the presence of 
SPEs, and is not only reflecting loans to Hungarian 
households and non-financial companies. Even so, 
this compares to 31% in the euro area, where it 
represents more than 235% of GDP. Debt and 
equity markets relative to GDP are smaller than the 
respective average in the euro area and market 
financing (debt securities and listed shares) is 
relatively underdeveloped, with the market for 
private debt smaller than in the smallest euro area 
members. Equity and private-sector debt markets 
represent 3% and 1% of total liabilities 
respectively. This compares to 9% of total 
liabilities for both listed stocks and private-sector 
debt in the euro area. Government debt is also 
significantly lower than in the euro area. 
 
 
  
 
 
The Hungarian banking sector is well integrated 
into the euro area financial sector, posting a level 
of foreign ownership in its banking system that is 
well above the one of the euro area. The share of 
foreign-owned institutions in total bank assets was 
around 40% both in 2016 and in 2020, with the 
corresponding figure for the euro area being at 
around 16%. Bank concentration, as measured by 
the market share of the five largest credit 
institutions in total assets, was stable at around 
50% since 2016, and in 2020, a value comparable 
to the euro area average (53% in 2020).  
  
In 2020, the banking sector in Hungary posted a 
Core tier 1 ratio just above 16%, one point below 
the average of the euro area. This ratio has been 
decreasing after 2018 and has been accompanied 
in 2020 by lower profitability. Nonetheless, it 
remains well above the lows of the 2010s. The 
ratio of non-performing loans to total loans is 
slightly above the euro area average but continued 
to decrease. For these reasons, the unfolding of the 
COVID-19 crisis and of the consequences of 
Russia’s invasion of Ukraine could have a 
Table 5.7:
Hungary - Financing of the economy1)
Ratio to GDP (%)
HU EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Liabilities (total) 550 647 743 770 324 335
Loans 136 189 238 236 115 112
Non-financial co. debt securities 2 3 12 15 3 4
Financial co. debt securities 5 8 74 68 11 12
Government debt securities 74 75 83 95 51 57
Listed shares 18 17 65 73 17 18
Unlisted shares 52 58 186 193 55 56
Other equity 229 261 51 56 42 48
Trade credits and advances 34 35 33 35 29 29
Share of total (%)
HU EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Loans 25 29 32 31 35 33
Non-financial co. debt securities 0 0 2 2 1 1
Financial co. debt securities 1 1 10 9 3 3
Government debt securities 13 12 11 12 16 17
Listed shares 3 3 9 9 5 5
Unlisted shares 10 9 25 25 18 18
Other equity 42 40 7 7 13 14
Trade credits and advances 6 5 4 5 9 9
1) The table focuses on the financing needs of a country and how these are met by the financial system.
 The table is constructed from the liabilities of all economic sectors, but only considers loans, debt securities, 
equity and trade credits. The sum of liabilities in the table only reflects the total for the liabilities considered.
Source: Eurostat.
0
10
20
30
40
50
60
HU, 2016 HU, 2020 EA, 2016 EA, 2020
Concentration in the banking sector (CR5 ratio)
Share of foreign institutions as % of total assets
Graph 5.11: Hungary - Foreign ownership and concentration 
in the banking sector
(in percent, weighted averages)
Source: ECB, Structural financial indicators.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 141 – 
European Commission 
Convergence Report 2022 
126 
significant impact on the financial stability and 
profitability indicators over the coming months. 
Measures of intra-EU integration in equity and 
debt markets, as based on the home bias in 
portfolio investments, indicate that the level of 
integration of Hungary is very low in both 
segments and in particular in debt markets. (101) 
Although intra-EU financial integration, by the 
same measure, is in general relatively low across 
EU Member States, Hungary’s integration is well 
below also the countries where the home bias is 
the largest in the euro area. The very large home 
bias indicates that almost all investments in 
financial markets takes place domestically. 
(101) Home bias in portfolio investments measures the average
propensity of investors in a Member State to invest 
domestically as compared with investing in other EU
countries. The indicator ranges between 0 and 1, with a
value of 0 indicating that investors prefer domestic over
foreign assets. The inverse of the home bias can be
interpreted as one measure of financial integration among
EU countries.
0.0
0.2
0.4
HU, 2016 HU, 2020 EA, 2016 EA, 2020 EA Low,
2016
EA Low,
2020
Debt Equity
Graph 5.12: Hungary - Intra-EU integration in equity and debt portfolio 
investment
Note: The chart shows the extent of home bias in debt and equity markets. A value index 
of 1 implies ‘full integration’ with the financial markets of other Member States, while 0 
denotes ‘no integration’.
Source: FinFlows database: European Commission, Joint Research Centre (JRC). 
(index)
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 142 –
6. POLAND 
127 
6.1. LEGAL COMPATIBILITY 
6.1.1. Introduction 
The main rules governing the Narodowy Bank 
Polski (NBP – Polish national bank, hereafter 
NBP) are laid down in the Act on the Narodowy 
Bank Polski (the NBP Act) which was adopted on 
29 August 1997. The consolidated version of the 
NBP Act was published in Dziennik Ustaw of 
2020, item 2027. The NBP Act has been slightly 
amended since the Commission’s 2020 
Convergence Report (102). In absence of any 
legislative action regarding the issues mentioned in 
the Commission’s 2020 Convergence Report, the 
comments provided in the latter report are repeated 
also in the 2022 assessment. 
6.1.2. Central Bank independence 
The Polish Constitution and the NBP Act do not 
explicitly prohibit the NBP and members of its 
decision-making bodies from seeking or taking 
outside instructions; they also do not expressly 
prohibit the Government from seeking to influence 
members of NBP decision-making bodies in 
situations where this may have an impact on NBP's 
fulfilment of its ESCB related tasks. The absence 
of such an explicit reference to Article 130 of the 
TFEU and Article 7 of the ESCB/ECB Statute or 
its content constitutes an incompatibility. 
However, the Polish Constitutional Court has 
recognised that the central bank's independence is 
based on Article 227(1) of the Constitution. In this 
respect, it is noted that at the occasion of a future 
amendment to the Polish Constitution the Polish 
authorities should seize the opportunity to clarify 
in the Constitution that the principle of central 
bank independence as enshrined in Article 130 of 
the TFEU and Article 7 of the ESCB/ECB Statute 
applies. Alternatively, or in addition, the NBP Act 
                                                          
(102) The amendments stem from the Act of 31 March 2020 
amending the Act on special arrangements for preventing, 
counteracting and combating COVID-19, other infectious 
diseases and crisis situations caused by them, and other 
laws (Dziennik Ustaw of 2020, item 568), the Act of 8 July 
2021 amending the Act on the Bank Guarantee Fund, 
Deposit Guarantee Scheme and Resolution, and other laws 
(Dziennik Ustaw of 2021, item 1598) and the Act of 17 
December 2021 amending the Act on Narodowy Bank 
Polski and the Executive Penal Code (Dziennik Ustaw of 
2022, item 22). 
could also be amended to ensure full compatibility 
with the principle of central bank independence. 
The Commission recalls the recent rulings of the 
Polish Constitutional Tribunal which considered 
certain provisions of the EU Treaties incompatible 
with the Polish Constitution, expressly challenging 
the primacy of EU law (103). The primacy of EU 
law is instrumental for assessing the compatibility 
between the national legislation, including the 
statute of its national central bank, and Articles 
130 and 131 and the Statute of the ESCB and of 
the ECB. The Commission considers that these 
rulings of the Constitutional Tribunal are in breach 
of the general principles of autonomy, primacy, 
effectiveness and uniform application of Union 
law and the binding effect of rulings of the Court 
of Justice of the European Union. Moreover, the 
Commission considers that the Constitutional 
Tribunal no longer meets the requirements of an 
independent and impartial tribunal previously 
established by law (104). It should be ensured that 
the primacy of Articles 130 and 131 and the 
Statute of the ESCB and of the ECB over national 
law is fully observed by Polish public authorities 
and courts. Article 23(1)(2) of the NBP Act 
provides that the NBP's Governor has, inter alia, to 
provide draft monetary policy guidelines to the 
Council of Ministers and the Minister of Finance. 
This procedure provides for the opportunity for the 
Government to exert influence on the monetary 
and financial policy of the NBP and thus 
constitutes an incompatibility in the area of 
independence with Article 130 of the TFEU and 
Article 7 of the ESCB/ECB Statute.  
Article 9(3) of the NBP Act foresees that the 
Governor of the NBP shall assume his/her duties 
after taking an oath before the Parliament. This 
oath refers to the observation of the provisions of 
the Polish Constitution and other laws, the 
economic development of Poland and the
wellbeing of its citizens. The Governor of the NBP acts 
in dual capacity as a member of NBP’s
decisionmaking bodies and of the relevant decision-making 
                                                          
(103) Polish Constitutional Tribunal, Judgment No. P 7/20 of 14 
July 2021; Polish Constitutional Tribunal, Judgment No. K 
3/21 of 7 October 2021. 
(104) On 22 December 2021, the Commission launched an 
infringement procedure concerning the Constitutional 
Tribunal and its case-law; see Commission press release 
IP/21/7070. The procedure is ongoing. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 143 – 
European Commission 
Convergence Report 2022 
128 
bodies of the ECB. Article 9(3) of the NBP Act 
needs to be adapted to reflect the status and the 
obligations and duties of the Governor of the NBP 
as member of the relevant decision-making bodies 
of the ECB. Moreover, the oath does not contain a 
reference to central bank independence as 
enshrined in Article 130 of the TFEU. The oath as 
it stands now is an imperfection and should be 
adapted to be fully in line with the TFEU and the 
ESCB/ECB Statute. 
The wording of Article 9(5) of the NBP Act 
containing grounds for dismissal of the NBP's 
Governor could lead to interpretative issues and is 
an imperfection. The provision would benefit from 
a clarification that these grounds correspond to a 
lack of fulfilment of conditions required for the 
performance of the Governor’s duties or a serious 
misconduct of which the Governor has been guilty, 
as set out in Article 14.2 of the ESCB/ECB 
Statute.  
The State Tribunal Act (105) provides for the 
suspension of the Governor from his/her duties 
following a procedure, which raises questions 
regarding its compatibility with the principle of 
central bank independence and Article 14.2 of the 
ESCB/ECB Statute. Pursuant to the second 
sentence of Article 11(1) of the State Tribunal Act 
read in conjunction with its Articles 3 and 1.1(3), 
the Governor of the NBP can be suspended as a 
result of an indictment by the Parliament for 
violating the Constitution or an act of law when 
performing his/her duties even before the State 
Tribunal has delivered its judgment on the removal 
from the office. While suspending a Governor for 
the purpose of a (criminal) investigation may be 
necessary, the Governor concerned should be able 
to bring an action for annulment of a temporary 
measure before the Court of Justice of the 
European Union (CJEU) pursuant to Article 14.2 
of the ESCB/ECB Statute. The purpose of such 
action is to enable the CJEU to verify that a 
temporary prohibition of performing a Governor’s 
duties is taken only if there are sufficient 
indications that he/she has engaged in serious 
misconduct capable of justifying such a 
measure (106). Such a guarantee is a reflection of 
(105) State Tribunal Act, Dziennik Ustaw of 2019, item 2122. 
(106) Judgment of the Court of Justice of the EU (Grand
Chamber) of 26 February 2019 Ilmārs Rimšēvičs and
European Central Bank v Republic of Latvia, Joined Cases
C-202/18 and C-238/18, ECLI:EU:C:2019:139. In this
ruling, the CJEU declared it has jurisdiction to hear and
determine an action of annulment brought against a
temporary measure like a suspension of performing duties
the principle of central bank independence and of 
great importance, especially in case of a 
suspension from office on grounds of serious 
misconduct further to an indictment by a 
parliamentary body depriving the Governor of the 
possibility to continue exercising the duties. In the 
absence of any clear reference in the NBP Act or 
Constitution to the principle of central bank 
independence the NBP Act would benefit from an 
explicit clarification that the Governor of the NBP 
has the possibility to seek legal redress against 
his/her dismissal, including suspension before the 
CJEU, as enshrined in Article 14.2 of the 
ESCB/ECB Statute. 
According to Article 203(1) of Poland’s 
Constitution, the Supreme Audit Office 
(Najwyższa Izba Kontroli (NIK)) is entitled to 
examine the NBP's activities as regards its legality, 
economic prudence, efficiency and diligence. The 
NIK controls are not performed in the capacity of 
an independent external auditor, as laid down in 
Article 27.1 of the ESCB/ECB Statute and thus, 
should for legal certainty reasons be clearly 
defined so as to respect Article 130 of the TFEU 
and Article 7 of the ESCB/ECB Statute. 
Furthermore, the provision's relationship with 
Article 69.1 of the NBP Act is also unclear. The 
relevant provision of the Constitution is therefore 
incompatible and needs to be adapted in order to 
comply with Article 130 of the TFEU and Article 
7 of the ESCB/ECB Statute. 
6.1.3. Prohibition of monetary financing and 
privileged access 
Article 42 in conjunction with Article 3(2)(5) of 
the NBP Act allow the NBP to extend refinancing 
loans to banks in order to replenish their funding 
and also extend refinancing to banks for the 
implementation of bank rehabilitation 
programmes, subject to conditionality under 
Article 42(4) of the same Act. Against this 
background, the current wording of Article 42(3) 
and (4) can be interpreted as allowing an extension 
of refinancing loans to banks experiencing 
rehabilitation proceedings which, however, could 
end in insolvency of the banks concerned. 
Effective preventive measures and more explicit 
safeguards should be provided in the NBP Act to 
clarify compatibility with Article 123 of the TFEU. 
as a Governor under Article 14.2 of the ESCB/ECB 
Statute. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 144 –
Convergence Report 2022 - Technical annex 
Chapter 6 - Poland 
129 
Article 43 of the NBP Act in conjunction with 
Articles 270 and 306 of the Act on the Bank 
Guarantee Fund, deposit guarantee system and 
forced restructuring (107) provides for NBP’s 
powers to grant short-term credit to the Bank 
Guarantee Fund related to the financing of its 
deposit guarantee function, if a threat to financial 
stability arises and in view of its urgent needs. The 
Bank Guarantee Fund qualifies as a ’body 
governed by public law’ within the meaning of 
Article 123(1) of the TFEU. The Bank Guarantee 
Fund is closely dependent on public sector entities 
referred to in Article 123(1) of the TFEU, as the 
majority of the members of the Bank Guarantee 
Fund’s Council are appointed by the Minister 
competent for financial institutions and the 
Chairman of the Financial Supervisory Authority 
(Article 7(4) of the Act on the Bank Guarantee 
Fund, deposit guarantee system and forced 
restructuring). Therefore, the provisions laid down 
in the NBP Act and the Act on the Bank Guarantee 
Fund, deposit guarantee system and forced 
restructuring regarding the possibility of NBP 
granting loans to the Bank Guarantee Fund are not 
compatible with the monetary financing 
prohibition and the relevant legal framework 
should be amended accordingly. 
As such, there is also no direct reference to the 
prohibition on monetary financing in the NBP Act. 
While Article 220(2) of the Polish Constitution 
provides that the budget shall not provide for 
covering a budget deficit by way of contracting 
credit obligations to the State’s central bank, and 
this could be interpreted as a reference to the 
rationale of Article 123 of the TFEU, this 
provision is not compatible with Article 123 
TFEU. At the occasion of a future amendment to 
the Polish Constitution the Polish authorities 
should seize the opportunity to clarify in the 
Constitution that the prohibition on monetary 
financing as enshrined in Article 123 of the TFEU 
and Article 21 of the ESCB/ECB Statute applies. 
Alternatively, or in addition, the NBP Act could be 
amended to ensure full compatibility with the 
aforementioned principle. 
                                                          
(107) system and forced restructuring of 10 June 2016. 
Consolidated version published in Dziennik Ustaw of 
2020, item 842, with further amendments. 
6.1.4. Integration in the ESCB 
Objectives 
Article 3(1) of the NBP Act sets the objectives of 
the NBP. It refers to the economic policies of the 
Government while it should make reference to the 
general economic policies in the Union, with the 
latter taking precedence over the former. This 
constitutes an imperfection with respect to Article 
127(1) of the TFEU and Article 2 of the 
ESCB/ECB Statute. 
Tasks 
The incompatibilities in the NBP Act and in the 
Polish Constitution in this area are linked to the 
following ESCB/ECB/EU tasks: 
• limitation of the NPB's activities to the territory 
of the Republic of Poland (Article 2(3) of the 
NBP Act) and absence of a general reference to 
the BNB as an integral part of the ESCB 
(Article 227(1) of the Constitution and Article 
1 of the NBP Act); 
• definition and implementation of monetary 
policy (Articles 227(1) and (6) of the 
Constitution, Articles 3(2)(5), 12, 23, 38-50a, 
and 53 of the NBP Act); 
• holding of foreign reserves; management of 
foreign exchange and the definition of foreign 
exchange policy (Articles 3(2)(2), 3(2)(3), 
17(4)(2), 24 and 52 of the NBP Act); 
• competences of the ECB and of the EU for 
banknotes and coins (Article 227(1), second 
sentence of the Constitution and Articles 4, 31-
37 of the NBP Act). The NBP shall exercise its 
responsibility for issuing currency as part of the 
ESCB/Eurosystem; 
• appointment of independent auditors - Article 
69(1) of the NBP Act foresees that NBP 
accounts are examined by external auditors. 
The NBP Act does not take into account that 
the auditing of a central bank has to be carried 
out by independent external auditors 
recommended by the Governing Council and 
approved by the Council. It is incompatible 
with Article 27.1 of the ESCB/ECB Statute.  
 
 
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European Commission 
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130 
There are also some imperfections regarding: 
• non-recognition of the role of the ECB in the
functioning of the payment systems (Articles
3(2)(1) of the NBP Act);
• incomplete recognition of the role of the ECB
and of the EU in the collection of statistics
(Article 3(2)(7) and 23 of the NBP Act);
• non-recognition of the role of the ECB in the
field of international cooperation (Article 5(1)
and 11(3) of the NBP Act).
6.1.5. Assessment of compatibility 
As regards the independence of the central bank, 
the prohibition on monetary financing and the 
central bank integration into the ESCB at the time 
of euro adoption, the legislation in Poland, in 
particular the NBP Act and the Constitution of the 
Republic of Poland are not fully compatible with 
the compliance duty under Article 131 of the 
TFEU. The Polish authorities are invited to remedy 
the abovementioned incompatibilities. 
6.2. PRICE STABILITY 
6.2.1. Respect of the reference value 
The 12-month average inflation rate, which is used 
for the convergence assessment, was above the 
reference value at the time of the last convergence 
assessment of Poland in 2020. It then increased 
almost uninterruptedly to reach 3.7% by end 2020 
and 5.2% by end-2021. In April 2022, the 
reference value was 4.9%, calculated as the 
average of the 12-month average inflation rates in 
France, Finland and Greece plus 1.5 percentage 
points. The corresponding inflation rate in Poland 
was 7.0%, i.e. 2.1 percentage points above the 
reference value. The 12-month average inflation 
rate is projected to remain well above the reference 
value in the months ahead. 
6.2.2. Recent inflation developments 
Poland recorded a significant and broad-base 
increase in annual HICP inflation over the past two 
years. Annual inflation fell to 2.9% in April 
following the first wave of the pandemic. It picked 
up to 3.8% in June and remained broadly constant 
until February 2021. Annual inflation then 
increased sharply throughout 2021, driven by 
rising energy and food prices as well as 
accelerating core inflation. Overall, headline 
inflation averaged 3.7% in 2020 and 5.2% in 2021. 
During the last two years, annual HICP inflation in 
Poland was consistently higher than in the euro 
area. 
-2
0
2
4
6
8
10
12
14
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Poland Reference value
Graph 6.1: Poland - Inflation criterion
(percent, 12-month moving average)
Note: The dots at the right end of the chart show the projected reference 
value and 12-month average inflation rate of the country in December 2022.
The reference values for 2016, 2018 and 2020 refer to the reference values 
calculated in the previous Convergence Reports.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Table 6.1: weights  
Poland - Components of inflation (percentage change)1) in total   
2016 2017 2018 2019 2020 2021 Apr-22 2022
HICP -0.2 1.6 1.2 2.1 3.7 5.2 7.0 1000
Non-energy industrial goods -1.5 -1.0 -0.3 0.4 0.9 2.4 3.7 332
Energy -3.7 2.9 3.7 0.0 -1.0 12.2 18.2 145
Unprocessed food 1.6 5.6 3.0 5.4 6.9 2.8 7.1 47
Processed food 0.7 2.7 1.8 3.7 3.9 2.7 4.5 200
Services 1.8 2.4 0.8 3.5 7.8 7.3 7.6 276
HICP excl. energy and unproc. food 0.3 1.2 0.6 2.3 4.2 4.2 5.3 808
HICP at constant tax rates -0.2 1.6 1.2 2.1 3.5 5.1 7.8 1000
Administered prices HICP 2.1 1.2 0.8 1.2 6.7 5.9 7.0 124
1) Measured by the arithmetic average of the latest 12 monthly indices relative to the arithmetic average of the 12 monthly indices
in the previous period.
Source: Eurostat, European Commission calculations.
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Chapter 6 - Poland 
131 
     
Core inflation (measured as HICP inflation 
excluding energy and unprocessed food) increased 
significantly in the first half of 2020, reaching 
4.8% in June 2020. It remained significantly above 
headline inflation until February 2021, before 
decreasing until June 2021. Core inflation then 
increased steadily again, albeit staying below 
headline inflation, reaching 5.7% in December 
2021. The upward trend on core inflation in the 
past two years was broadly spread across all HICP 
categories. Demand and supply factors such as 
rising wages, higher input prices and booming 
domestic demand following the end of the 
pandemic were the main contributors to this
broadbase increase. Labour shortages also played a role, 
in particular for service inflation, which increased 
from 5.6% in March 2020 to 7.5% in December 
2021. After several years of low inflation, prices of 
non-energy industrial goods also increased 
significantly, with annual inflation for this 
category reaching 4.2% in 2021, mainly due to 
global supply bottlenecks and rising production 
costs. Processed food inflation decreased steadily 
between March 2020 and May 2021, and then 
increased at a fast pace, reaching 5.7% in 
December 2021, reflecting increasing production 
costs, especially related to higher energy prices. 
6.2.3. Underlying factors and sustainability of 
inflation 
Macroeconomic policy mix and growth 
developments 
Following the start of the COVID-19 pandemic, 
Poland’s real GDP dropped by 2.2% in 2020, the 
first recession in nearly two decades. It then 
rebounded by 5.9% in 2021. The main drivers of 
the recovery were domestic demand, in particular 
private consumption and investment. After a 
significant fall of 2.8% in 2020, private 
consumption recovered swiftly in 2021, growing 
by 6.0%, supported by a high level of accumulated 
savings and a strong recovery in the labour market, 
which weathered the crisis well due to sizeable 
fiscal support. The recovery in investment was 
more gradual, with investment levels still below 
pre-crisis levels by the end of 2021. According to 
the Commission’s Spring 2022 Economic 
Forecast, GDP is projected to increase by 3.7% in 
2022, as the effects of the COVID-19 pandemic 
are expected to ease and economic activity is 
expected to normalise. In 2023, GDP is expected 
to continue decelerating, growing by a projected 
3.0%.  
The fiscal stance was strongly expansionary in 
2020, driven by fiscal measures adopted to contain 
the economic impact of the pandemic, but it 
recovered in 2021 as the expenditure measures 
were partially withdrawn and revenues increased 
on the back of the economic recovery (108). 
According to the Commission’s Spring 2022 
Economic Forecast, the fiscal stance is expected to 
be supportive at -3.4% of GDP in 2022, due to 
growth in nationally-financed primary current 
expenditure, including the impact of measures 
compensating for high energy prices and the cost 
of aid to refugees.  
Monetary policy, conducted within an inflation 
targeting framework (109) remained 
accommodative for most of the past two years, 
before tightening sharply from October 2021. The 
COVID-19 crisis led to a substantial monetary 
easing: after decreasing the policy rate twice by 50 
basis points in March and in April 2020, the 
Monetary Policy Council (MPC) decreased the 
policy rate further to 0.1% in May 2020. In 
addition, the MPC launched the purchase of 
government securities and government-guaranteed 
debt securities on the secondary market. It also 
started the provisioning of additional liquidity to 
the banking sector through repo operations and a 
discount facility. Yet, as inflation accelerated, the 
                                                          
(108) The fiscal stance is measured as the change in primary 
expenditure (net of discretionary revenue measures), 
excluding Covid-19 crisis-related temporary emergency 
measures but including expenditure financed by
nonrepayable support (grants) from the Recovery and 
Resilience Facility and other EU funds, relative to
mediumterm potential growth. A negative (positive) sign of the 
indicator corresponds to an excess (shortfall) of primary 
expenditure growth compared with medium-term economic 
growth, indicating an expansionary (contractionary) fiscal 
policy. 
(109) Since the beginning of 2004, the NBP has pursued a 
continuous inflation target of 2.5% with a permissible 
fluctuation band of +/- 1 percentage point. 
-2
0
2
4
6
8
10
12
2016 2017 2018 2019 2020 2021
Poland Euro area
Graph 6.2: Poland - HICP inflation
(y-o-y percentage change)
Source: Eurostat.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 147 – 
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Convergence Report 2022 
132 
Monetary Policy Council (MPC) increased the 
reference rate from October 2021, reaching 5.25% 
in May 2022, i.e. levels last seen at the end of 
2008.  
Wages and labour costs 
The impact of the crisis on the labour market was 
mostly reflected in declining hours worked, as 
public job retention schemes shielded employment. 
In line with this, the unemployment rate remained 
broadly stable around 3.0-3.5% for most of the 
past two years. As the recovery gathered pace, the 
labour market has been showing signs of 
overheating, with companies reporting significant 
labour shortages and wage growth rising strongly 
at the end of 2021 and beginning of 2022. 
Labour productivity decreased by 2.1% in 2020 
due to the sharp drop in economic activity 
following the COVID-19 crisis. It then increased 
sharply by 4.4% in 2021. Growth in compensation 
per employee decelerated in 2020 to 5.6% and to 
5.0% in 2021. This translated into nominal ULC 
growth of 7.9% in 2020 and 0.6% in 2021. Acute 
labour shortages are expected to lead to a rapid 
increase in compensation per employee over the 
forecast horizon, with a projected increase of 9.5% 
in 2022 and 8.0% in 2023. Labour productivity is 
expected to continue posting strong growth rates, 
increasing by 3.3% in 2022 and 2.7% in 2023. This 
is expected to result in nominal ULC growth of 
6.0% and 5.1% in 2022 and 2023, respectively, 
according to the Commission’s Spring 2022 
Economic Forecast. 
External factors 
Although external trade represents a lower share of 
GDP in Poland than in regional peers like Hungary 
or Czechia, prices of imported goods and services 
play an important role in domestic price formation. 
After a small decrease in 2020, the imports of 
goods deflator raised by 11.5% in 2021, driven 
inter alia by an increase in global commodity 
prices. The zloty’s nominal effective exchange rate 
(measured against a group of 36 trading partners) 
depreciated on average by 2.1% in 2020 and 2.3% 
in 2021 contributing to push up import prices. Low 
-3
0
3
6
9
12
15
2016 2017 2018 2019 2020 2021 2022 2023
Productivity (real GDP per person employed)
Nominal compensation per employee
Nominal unit labour costs
HICP inflation
Graph 6.3: Poland - Inflation, productivity and wage trends
(y-o-y % change)
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Table 6.2:
Poland - Other inflation and cost indicators (annual percentage change)
2016 2017 2018 2019 2020 2021 20221) 20231)
HICP inflation
Poland -0.2 1.6 1.2 2.1 3.7 5.2 11.6 7.3
Euro area 0.2 1.5 1.8 1.2 0.3 2.6 6.1 2.7
Private consumption deflator
Poland -0.4 2.0 1.7 2.4 3.4 5.4 11.8 7.3
Euro area 0.4 1.3 1.5 1.1 0.5 2.3 5.8 2.7
Nominal compensation per employee
Poland 4.8 5.8 8.1 7.3 5.6 5.0 9.5 8.0
Euro area 1.2 1.7 2.1 2.1 -0.7 4.1 3.6 3.5
Labour productivity
Poland 2.3 3.4 4.8 4.8 -2.1 4.4 3.3 2.7
Euro area 0.4 1.0 0.2 0.3 -4.9 4.2 1.4 1.5
Nominal unit labour costs
Poland 2.4 2.3 3.2 2.4 7.9 0.6 6.0 5.1
Euro area 0.8 0.7 2.0 1.9 4.4 0.0 2.2 2.0
Imports of goods deflator
Poland -0.3 1.3 2.9 1.7 -0.4 11.5 15.5 5.0
Euro area -3.3 3.3 2.6 -0.5 -3.8 9.6 13.2 0.8
1) Commission Spring 2022 Economic Forecast.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 148 –
Convergence Report 2022 - Technical annex 
Chapter 6 - Poland 
133 
inflation in Poland’s trade partners in 2020 
weighted on import price increases that year. 
However, as inflation accelerated in Poland’s trade 
partners and the zloty kept depreciating in 2021, 
import prices excluding commodity prices also 
hiked. Imported inflation is forecast to increase 
strongly during 2022-2023. 
Administered prices and taxes 
The increase in administered prices, with a weight 
of around 12% in the HICP basket (similar to that 
of the euro area), was above HICP inflation both in 
2020 and 2021. The average annual increase in 
administered prices was 6.7% in 2020 and 5.9% in 
2021 against 3.7% and 5.2% for headline inflation, 
respectively. The fast growth of administered 
prices was the result of increased waste collection 
fees, sugar tax, capacity fees as well as higher 
regulated energy prices.  
The impact of tax measures on overall price 
developments has been close to zero as constant 
tax inflation was in line with headline inflation in 
both 2020 and 2021. 
Medium-term prospects 
Looking ahead, inflation is expected to accelerate 
significantly in 2022, peaking in the first quarter of 
the year. Energy prices are expected to increase 
strongly amid a hike in regulated energy prices at 
the beginning of 2022, although the increase will 
be somewhat counterbalanced by a policy package 
put in place in November 2021 by the government 
to reduce rates paid in energy and food products. 
Processed and unprocessed food prices are 
projected to increase from mid-2022 onwards, as 
rising prices of fertilisers are set to increase 
production costs, especially for agricultural 
products. Core inflation is set to remain elevated 
on the back of acute labour shortages, which are 
set to put upward pressure on wage growth. The 
Commission’s Spring 2022 Economic Forecast 
projects annual HICP inflation to average 11.6% in 
2022 and 7.3% in 2023.  
Despite a number of policy measures introduced to 
lower tax rates paid on certain goods, strong price 
dynamics are forecast to persist in 2022, mainly 
due to surging energy prices and unit labour costs. 
The inflation outlook remains highly uncertain, 
with risks appearing to be tilted to the upside. 
Wage growth is expected to be elevated over the 
forecast horizon, and risks of a stronger wage-price 
spiral cannot be ruled out, which could put 
significant upward pressure on core inflation. 
More fiscal expansion could further fuel demand 
pressure and the risk of higher energy prices 
stemming from poor meteorological conditions 
could increase energy prices even further. 
The level of consumer prices in Poland was at 
around 56% of the euro-area average in 2020. This 
suggests a significant potential for price level 
convergence in the long term, as GDP per capita in 
PPS (about 73% of the euro-area average in 2021) 
increases towards the euro-area average.  
Medium-term inflation prospects in Poland will 
hinge upon wage and productivity trends as well as 
on the functioning of product markets. Further 
structural measures to increase labour supply, to 
make better use of increased labour immigration 
and to facilitate the effective allocation of labour 
market resources will play an important role in 
limiting wage pressures, resulting inter alia from 
negative demographic developments. As to 
product markets, there is scope to enhance the 
competitive environment, especially in the services 
and energy sectors. At the macro level, an 
appropriate monetary policy response to 
macroeconomic developments and a prudent fiscal 
stance will be essential to contain inflationary 
pressures. 
6.3. PUBLIC FINANCES 
6.3.1. Recent fiscal developments 
The general government deficit increased sharply 
in 2020 to 6.9% of GDP. The economic recession 
triggered by the pandemic had a negative impact 
on public finances via two main channels: it 
slowed down the dynamics of the revenue due to 
lower economic activity, and it led to a sharp 
increase in expenditure. Fiscal measures to contain 
the economic impact of the pandemic played a 
significant role in this increase. They included 
amongst others non-refundable loans to 
companies, short-time work schemes, subsidies for 
businesses and a special allowance for parents. As 
a result, the total government expenditure 
increased from 41.8% of GDP in 2019 to 48.2% of 
GDP in 2020, an increase close to the EU average. 
However, it should be noted that in nominal terms 
Poland recorded a positive GDP growth in 2020, 
thus the increase in expenditure ratio was not 
driven by contracting nominal GDP. In turn, as a 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 149 –
European Commission 
Convergence Report 2022 
134 
share of GDP, the total general government 
revenue increased slightly as compared to 2019, 
despite the pandemic. In 2021, the general 
government headline deficit narrowed to 1.9% of 
GDP. Revenue (mainly from taxes and social 
contributions) increased, driven by the economic 
recovery, a good situation on the labour market 
and cyclical factors. On top of this, new taxes 
implemented in 2021 also contributed to the 
revenue growth. In turn, expenditure decreased. 
While the cost of fiscal measures to contain the 
impact of the pandemic was lower than in 2020, 
this was partly offset by some new expenditure 
items (for instance an additional one-off pension 
benefit payment in 2021). 
The 2021 headline deficit (1.9% of GDP) turned 
out to be lower than forecast in the 2021 edition of 
the Convergence Programme (6.9% of GDP). This 
difference stemmed mainly from a significant 
decrease in public expenditure (by 4.0% of GDP) 
and an increase in revenues (by 1.0% of GDP). 
The general government debt increased 
significantly in 2020, driven by a high deficit 
triggered by the pandemic-driven recession (see 
above). It reached 57.1% of GDP, as compared to 
45.6% of GDP in 2019. It then decreased to 53.8% 
of GDP in 2021. The decrease of the debt-to-GDP 
ratio occurred despite a deficit of 1.9% of GDP in 
2021. This is explained by a strong nominal GDP 
growth in 2021, reaching 12.1%. In terms of 
valuation effects, the falling share of Polish 
government debt denominated in foreign 
currencies was counterbalanced by weakening 
złoty.  
6.3.2. Medium-term prospects 
The 2022 budget was adopted on 17 December 
2021. It targets a general government deficit of 
2.9% of GDP. Following the budget law, the 
support to the economy to cushion the impact of 
the crisis will be substantially lower than in the 
two previous years. At the same time, while the
socalled 14th pension benefit was only a one-off 
expenditure item in 2021, the budget law broadly 
assumes a continuation of major policies carried 
out in previous years, in particular in the area of 
social spending. On the revenue side, an 
implementation of a major tax overhaul is 
expected to lower the revenue from the personal 
income tax. 
On 28 April 2022, Poland submitted its 2022 
Convergence Programme. According to the 
Programme, the headline deficit is projected to 
increase to 4.3% of GDP in 2022 and decrease to 
3.7% in 2023. The government deficit in 2022 is 
impacted by the additional measures taken by 
government to counter the social and economic 
impact of the increase in energy prices, as well as 
the humanitarian and security expenditure 
following the war in Ukraine. Based on the 
Commission’s Spring 2022 Economic Forecast, 
the measures to cushion the impact of the increase 
in energy prices are estimated at 1.0% of GDP in 
2022, most of which are currently expected to be 
Table 6.3:
Poland - Budgetary developments and projections (as % of GDP unless indicated otherwise)
Outturn and forecast 1) 2016 2017 2018 2019 2020 2021 20221) 20231)
General government balance -2.4 -1.5 -0.2 -0.7 -6.9 -1.9 -4.0 -4.4
- Total revenue 38.7 39.8 41.3 41.0 41.3 42.3 39.9 38.6
- Total expenditure 41.1 41.3 41.5 41.8 48.2 44.2 43.9 43.0
of which:
- Interest expenditure 1.7 1.6 1.4 1.4 1.3 1.1 1.5 1.8
p.m.: Tax burden 34.3 35.0 36.0 36.0 36.4 37.7 35.4 34.4
Primary balance -0.7 0.1 1.2 0.6 -5.6 -0.8 -2.5 -2.6
Fiscal stance 2) 0.1 1.7 -3.4 1.7
Government gross debt 54.2 50.6 48.8 45.6 57.1 53.8 50.8 49.8
p.m: Real GDP growth (%) 3.1 4.8 5.4 4.7 -2.2 5.9 3.7 3.0
1) Commission’s Spring 2022 Economic Forecast.
2) A negative (positive) sign of the indicator corresponds to an excess (shortfall) of primary expenditure growth
compared with medium-term economic growth, indicating an expansionary (contractionary) fiscal policy.
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 150 –
Convergence Report 2022 - Technical annex 
Chapter 6 - Poland 
135 
temporary and to be withdrawn in 2023, while the 
annual cost of humanitarian assistance is assumed 
at 0.6% of GDP in 2022 and 0.8% of GDP in 2023. 
The Programme targets a reduction of the 
government deficit to under 3% of GDP by 2025.  
The Commission’s Spring 2022 Economic 
Forecast projects the general government headline 
deficit in 2022 at 4.0% of GDP. The deficit is set 
to increase to 4.4% of GDP in 2023. The ratio of 
general government debt to GDP is set to decrease 
to 49.8% in 2023. However, as above a quarter of 
the sovereign debt is denominated in foreign 
currencies, the debt projections are subject to 
uncertainty due to possible valuation effects. 
In 2022, the fiscal stance is projected in the 
Commission’s Spring 2022 Economic Forecast to 
be supportive, at -3.4% of GDP (110). The positive 
contribution to economic activity of expenditure 
financed by RRF grants and other EU funds is 
projected at 0.1 percentage point of GDP in 2022, 
the first year of expected implementation of the 
Polish Recovery and Resilience Plan. Nationally 
financed investment is projected to provide 
expansionary contribution to the fiscal stance of -
0.3 percentage points of GDP in 2022. At the same 
time, the growth in nationally financed primary 
current expenditure (net of new revenue measures) 
in 2022 is projected to provide an expansionary 
contribution of -2.7 percentage points of GDP to 
the overall fiscal stance, as current expenditure is 
set to grow at a faster pace than medium-term 
potential growth. 
             
In 2023, the fiscal stance is projected to be 
contractionary at +1.7% of GDP. The 
expansionary contribution to economic activity of 
                                                          
(110) The measurement of the fiscal stance is explained in 
section 6.2.3 on underlying factors and sustainability of 
inflation. 
expenditure financed by RRF grants and other EU 
funds is projected to be -0.1 percentage points of 
GDP in 2023. Nationally financed investment is 
projected to provide a contractionary contribution 
to the fiscal stance of 0.3 percentage points of 
GDP (111), whereas the growth in nationally 
financed primary current expenditure is projected 
to provide a contractionary contribution of 1.4 
percentage points of GDP to the overall fiscal 
stance in 2023. 
Debt sustainability risks appear low over the 
medium run. Government debt is projected to 
remain below 60% of GDP, albeit on an increasing 
path as from 2027, reaching around 54% of GDP 
in 2032. This projection assumes that the structural 
primary balance (except for the impact of ageing) 
remains constant at the forecast level for 2023 of -
2.3% of GDP, hence below the 2019 level.  
The limited sensitivity to possible macro-fiscal 
shocks also contributes to this assessment. In 
particular, if only half of the improvement in the 
structural primary balance projected for 2022-2023 
were to occur, the debt ratio would be about 6 
percentage points of GDP higher by 2032 
compared with the baseline, reaching 60% of 
GDP.  
Some factors mitigate risks, including the currency 
denomination of debt and the expected positive 
impact on long-term growth of reforms under the 
Recovery and Resilience Plan. Risk-increasing 
factors include a tightening of financing 
conditions, the share of non-performing loans and 
Poland’s negative net international investment 
position (112). 
The fiscal framework in Poland is overall strong, 
but recently it was slightly relaxed to take into 
account the pressures emerging from the COVID-
19 pandemic. The numerical fiscal rules are at the 
centre of the framework. While the debt ceilings 
anchored in the Constitution cover the central 
government, a separate debt rule concerns local 
government units (LGUs). The latter rule was 
loosened in 2020 by allowing LGUs to exclude 
from their calculations liabilities equivalent to the 
loss of revenue linked to the pandemic; in addition, 
for 2020, the debt limit was lowered to 80% of the 
total revenue. The expenditure rule applied to the 
                                                          
(111) Other nationally financed capital expenditure is projected 
to provide a contractionary contribution of 0.1 percentage 
points of GDP. 
(112) For further details see the 2021 Fiscal Sustainability 
Report. 
-4
-3
-2
-1
0
1
2
3
2020 2021 2022 2023
Net nationally financed  primary current expenditure Nationally financed investment
Other capital expenditure Expenditure financed by RRF grants and EU funds
Fiscal stance
Expansionary
Contractionary
Graph 6.4: Poland - Fiscal stance and its components
(percent of GDP)
Source: Commission's Spring 2022 Economic Forecast. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 151 – 
European Commission 
Convergence Report 2022 
136 
general government, which aims at preventing 
overspending, has been temporarily suspended, 
with a mechanism for an automatic return to the 
conventional rule over two to four years. Similarly, 
the budget balance rule applied to the LGUs has 
also been suspended. The constitutional debt limit 
was circumvented by channelling most of the 
pandemic economy support measures through a 
special off-the-budget fund. In turn, in 2021 the 
stabilising expenditure rule was strengthened by 
covering all special purpose funds but its effective 
implementation for the pandemic-specific fund 
was effectively delayed until 2022 (when a draft 
2023 budget will be prepared). Medium-term 
budgetary planning is based on the four year 
Multiannual State Financial Plan, which serves as 
a basis for the preparation of annual budgets but 
does not provide targets for them. Poland does not 
have a fully-fledged fiscal council and activities 
related to the monitoring of fiscal rules are 
scattered among several bodies, with the Supreme 
Audit Office taking a more central role. 
6.4. EXCHANGE RATE STABILITY 
The Polish zloty does not participate in ERM II. 
Since April 2000, Poland has been operating de 
jure a floating exchange rate regime, with the NBP 
preserving the right to intervene in the foreign 
exchange market, if it deems this necessary, in 
order to achieve the inflation target. 
The zloty depreciated sharply after the onset of 
COVID-19 crisis in early 2020. This was reflected 
in large by the easing of monetary policy as NBP 
started to cut interest rates until levels unseen 
before and substantially enlarged amounts of open 
market operations. Afterwards it went through a 
period of fluctuations but indicated no clear trend. 
Tightening of the NBP’s monetary policy 
strengthened the zloty from October 2021 up to 
February 2022. However, the outbreak of war in 
Ukraine weakened the zloty substantially as in 
some days in March 2022 it reached 5.0 against the 
euro, i.e. the highest level for more than two 
decades. Moreover, at the end of March 2022 NBP 
entered a swap line arrangement with ECB in order 
to address potential euro liquidity needs.  
International reserves held by the NBP increased 
from EUR 114 billion in early 2020 to around 
EUR 147 billion by end-2021. The reserve-to-GDP 
ratio was at around 26% at end-2021. 
Short-term interest rate differential vis-à-vis the 
euro area remained stable at around 210 basis 
points up to early 2020. In March, the NBP began 
to ease monetary policy and cut interest rates three 
consecutive times to levels unseen before. This fed 
into the Polish interbank market and three-month 
rate fell to the lowest levels on record. Changes in 
euro money market were more limited as the
threemonth euro rate picked-up only temporary in April 
and May and further continued its downward path 
to stabilise at historically low levels. 
Consequently, short-term interest rate differential 
shrank to 65 basis points in June and fluctuated at 
around 75 basis points until October 2021 when 
NBP started to tighten monetary policy. After 
seven consecutive increases of interest rates the 
short-term interest rate differential reached 593 
basis points in April 2022. 
6.5. LONG-TERM INTEREST RATES 
Long-term interest rates in Poland used for the 
convergence assessment reflect secondary market 
yields on a single benchmark government bond 
with a residual maturity of around 9 years. 
3.0
3.5
4.0
4.5
5.0
2016 2017 2018 2019 2020 2021
Graph 6.5: Poland - PLN/EUR exchange rate
(monthly averages)
Source: ECB.
0
100
200
300
400
500
600
700
2016 2017 2018 2019 2020 2021
Graph 6.6: Poland - 3-M Wibor spread to 3-M Euribor
(basis points, monthly values)
Source: Polish National Bank, Eurostat and Thomson Reuters.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 152 –
Convergence Report 2022 - Technical annex 
Chapter 6 - Poland 
137 
       
The Polish 12-month average long-term interest 
rate relevant for the assessment of the Treaty 
criterion was below the reference value at the time 
of the last convergence assessment in 2020. It 
gradually decreased from 2.2% at that time to 
about 1.3% by April-2021 and started to increase 
reaching 2.0% by end-2021. In April 2022, the 
latest month for which data are available, the 
reference value, given by the average of long-term 
interest rates in France, Finland and Greece plus 2 
percentage points, stood at 2.6%. In that month, 
the 12-month moving average of the yield on the 
Polish benchmark bond stood at 3.0%, i.e. 0.4 
percentage point above the reference value. 
     
Developments in long-term interest rate in Poland 
since 2020 reflect in large part changes in the 
monetary policy stance of the NBP. The easing of 
monetary policy after the onset of the pandemic in 
2020 contributed to a significant decrease of the 
long-term interest rates, which remained at the 
1.3% level until the end of 2020. In January 2021 
the long-term interest rate reached the lowest level 
on the record (1.2%) before starting to increase 
moderately until the summer. The tightening of 
monetary policy, which started in October 2021, 
then contributed to a considerable increase in the 
long-term interest rate. Poland's long-term interest 
rate was around 6.0% in April 2022. 
The long-term interest rate spread vis-à-vis the 
German benchmark bond narrowed strongly 
during the early months of the COVID-19 crisis 
and fluctuated around 180 basis points between 
April 2020 and April 2021. In mid-2021, it started 
to increase slightly and by October, when NBP 
began its tightening cycle, the spread started to 
widen. By the end-2021 the long-term interest rate 
spread reached around 373 basis points and during 
the first quarter of 2022 continued to widen up-to 
521 basis points in April 2022. 
6.6. ADDITIONAL FACTORS 
The Treaty (Article 140 TFEU) calls for an 
examination of other factors relevant to economic 
integration and convergence to be taken into 
account in the assessment. The assessment of the 
additional factors – including balance of payments 
developments, product, labour and financial 
market integration – gives an important indication 
of a Member State's ability to integrate into the 
euro area without difficulties.  
In November 2021, the Commission published its 
eleventh Alert Mechanism Report (AMR 2021) 
under the Macroeconomic Imbalance Procedure 
(MIP – see also Box 1.7), which highlighted issues 
related to the international investment position 
(NIIP) and house price growth in Poland. 
However, since overall risks remain limited, the 
report concluded that no In-Depth Review (IDR) 
was warranted. External vulnerabilities remained 
contained, given that foreign direct investment 
accounted for a major part of foreign liabilities. 
The growth of house prices was strong in 2021, 
reaching 9.2% in the last quarter of 2021, but risks 
of overheating were seen as limited with price 
indicators suggesting almost no overvaluation. At 
the same time, household debt remains low at 
55.3% of income. Significant labour shortages are 
limiting investment growth and putting upward 
pressure on unit labour costs, which might impact 
the competitiveness of Polish businesses over the 
medium term. 
Poland submitted its recovery and resilience plan 
on 3 May 2021, which is equivalent to 4.5% in 
2019 GDP (113). The plan has a total allocation of 
                                                          
(113) 2019 GDP and RRP total amount in current prices. 
0
2
4
6
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Poland Reference value
Graph 6.7: Poland - Long-term interest rate criterion
(percent, 12-month moving average)
Source: European Commission.
-2
0
2
4
6
8
2016 2017 2018 2019 2020 2021
Poland Germany
Graph 6.8: Poland - Long-term interest rates
(percent, monthly values)
Source: Eurostat.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 153 – 
European Commission 
Convergence Report 2022 
138 
EUR 23.9 billion in grants and contains proposed 
investments and reforms to decarbonise the Polish 
economy, make the transport sector more 
sustainable, address challenges related to the 
investment climate, notably with regard to the 
Polish judicial system as well as decision- and
lawmaking processes, improve IT connectivity and 
improve the resilience of the healthcare system.  
6.6.1. Developments of the balance of 
payments 
Poland’s external balance (i.e. the combined 
current and capital account) stayed positive for 
most of 2020-2021, before turning slightly 
negative at the end of 2021. The current account 
increased visibly throughout 2020 due to a strong 
drop in imports, which boosted the trade balance. 
However, as domestic demand recovered, import 
growth hiked, causing the current account to turn 
negative from May 2021 onwards. The income 
balance turned even more negative over 2020-
2021. The primary income balance stayed negative 
and deteriorated throughout 2021, partly driven by 
an improvement in the profitability of foreign 
companies. The secondary income balance 
remained negative and somewhat deteriorated as 
the high inflow of returning foreign workers, 
mainly Ukrainians, led to significantly higher 
transfers abroad. 
In the financial account of the balance of 
payments, the balance of direct investment 
stabilised in 2020 before rebounding in 2021 with 
a net inflow of 3.8% of GDP. The rebound was 
driven by a recovery of reinvested earnings, which 
has been the main source for new FDI inflows in 
recent years. In 2020, net portfolio investment 
recorded an outflow of 1.2% of GDP, most likely 
driven by non-residents’ investment treasury 
bonds, and in 2021 it reached 1.7% of GDP. 
During the observed period, the other investment 
account switched from net outflow of 1.7% GDP 
in 2020 to a net inflow of 0.6% of GDP in 2021.  
According to the Commission’s Spring 2022 
Economic Forecast, which is based on national 
accounts data, the external balance is expected to 
move into negative territory, with around -0.5% of 
GDP in 2022 and -0.2% in 2023. 
Poland’s external competitiveness has remained 
robust. Poland’s export performance (as measured 
by the growth of its exports relative to its foreign 
Table 6.4:
Poland - Balance of payments (percentage of GDP)
2016 2017 2018 2019 2020 2021
Current account -0.8 -0.3 -1.3 0.5 2.9 -0.6
of which: Balance of trade in goods 0.5 -0.1 -1.2 0.3 2.4 -0.1
Balance of trade in services 3.2 3.8 4.3 4.5 4.3 4.6
Primary income balance -4.1 -4.1 -4.0 -4.0 -3.5 -4.4
Secondary income balance -0.3 0.0 -0.3 -0.3 -0.3 -0.7
Capital account 1.0 1.3 2.1 2.0 2.3 1.6
External balance 1) 0.3 0.9 0.8 2.4 5.2 1.0
Financial account 0.3 -0.5 0.2 1.1 3.8 0.2
of which: Direct investment -0.9 -1.4 -2.6 -2.0 -2.1 -3.6
Portfolio investment -0.8 -0.9 0.8 2.0 1.3 1.7
                Other investment 2) -2.8 3.4 0.8 -0.7 1.6 -0.6
Change in reserves 4.8 -1.5 1.3 1.7 3.1 2.8
Financial account without reserves -4.5 1.1 -1.0 -0.7 0.8 -2.6
Errors and omissions 0.1 -1.4 -0.5 -1.4 -1.4 -0.8
Gross capital formation 19.7 19.9 20.8 19.7 17.5 20.3
Gross saving 19.4 19.6 19.8 20.6 20.3 21.9
Net international investment position -61.5 -61.2 -55.9 -49.8 -44.3 -39.9
1) The combined current and capital account.
2) Including financial derivatives.
Sources: Eurostat, European Commission calculations, National Bank of Poland.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 154 –
Convergence Report 2022 - Technical annex 
Chapter 6 - Poland 
139 
markets) improved in 2020 and 2021, driven by 
Poland’s diversified export structure, which helped 
cushion the impact of the crisis. The nominal 
effective exchange rate depreciated throughout 
2020 and 2021 but the real effective exchange rate 
remained broadly stable over the same period and 
can therefore not explain the good export 
performance (114). 
The net international investment position (NIIP) 
improved significantly from -49.8% in 2019 to -
39.9% in 2021. Although this remains beyond the 
indicative threshold set in the MIP scoreboard (-
35% of GDP), external vulnerabilities remain 
contained, as major part of the NIIP consists of the 
accumulated stock of foreign direct investments.  
(114) The REER based on unit labour costs should be interpreted
with prudence as unit labour costs were distorted by labour
retention schemes in some countries, including Poland. 
6.6.2. Market integration 
Poland's economy is well integrated with the euro 
area through both trade and investment linkages. 
Trade openness increased from 51.4% in 2016 to 
59.5% of GDP in 2021. The share of trade with 
euro-area partners expressed in percentage of GDP 
was broadly stable in recent years, although in 
2021 it increased to around 34%. Poland's main 
goods trading partners in 2021 were Germany, 
China, the Netherlands, Czechia and Italy. 
FDI inflows to Poland have mainly originated 
from the Netherlands, Germany, Luxembourg and 
France, which together provided nearly two-thirds 
of the FDI stock at the end of 2020. The significant 
size and growth of the domestic market as well as 
good access to large regional markets have 
supported the attractiveness of the country for FDI. 
On the basis of selected indicators relating to the 
business environment, Poland ranks slightly below 
the average of euro-area Member States. In the 
2020 World Bank’s Ease of Doing Business index, 
Poland scored comparatively poorly with regard to 
starting a business, followed by the sub-index 
related to registering property (115). According to 
the World Bank's Worldwide Governance 
Indicators (2020), Poland ranks low in voice and 
accountability, and government effectiveness 
compared with the average of the five euro area 
Member States with the lowest scores. Poland 
(115) The World Bank Doing Business (DB) program was
paused in 2021. The programme will continue with a new
governance and improved accountability and transparency
under the name Business Enabling Environment (BEE).
The first edition of the BEE is expected in 2023. 
90
95
100
105
110
2016 2017 2018 2019 2020 2021
Graph 6.9: Poland - Effective exchange rates
NEER REER, HICP deflated REER, ULC deflated
(vs. 36 trading partners;  monthly averages;
index numbers, 2016 = 100)
Source: European Commission.
Table 6.5:
Poland - Market integration
2016 2017 2018 2019 2020 2021
Trade openness 1) (%) 51.4 53.5 54.8 54.2 53.3 59.5
Trade with EA in goods &amp; services 2)+3) (%) 29.2 30.4 31.0 30.4 30.5 33.9
World Bank's Ease of Doing Business Index rankings 4) 24 27 33 40 40 -
IMD World Competitiveness Ranking 5) 33 38 34 38 39 47
Internal Market Transposition Deficit 6) (%) 1.5 1.4 1.0 0.8 1.8 -
Real house price index 7) 102.3 104.1 109.2 115.9 124.0 128.6
 1) (Imports + Exports of goods and services / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics, Balance of Payments).
 2) (Imports + Exports of goods with EA-19 / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics).
 3) Trade in services with EA-19 (average credit and debit in % of GDP at current prices) (Balance of Payments).
 4) Data not available for 2021. The Ease of Doing Business report by the World Bank was discontinued in September 2021. 
 5) International Institute for Management Development (IMD).
 6) Percentage of internal market directives not yet communicated as having been transposed, relative to the total.
(November data, as of 2016 date refers to the year of publication).
 7) Deflated house price index (2015=100) (Eurostat). 
Sources: Eurostat, World Bank, International Institute for Management Development, European Commission calculations.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 155 –
European Commission 
Convergence Report 2022 
140 
ranks higher than the average five lowest euro area 
Member States for political stability and absence 
of violence, and control of corruption. According 
to the latest data, Poland lags behind in the 
transposition of EU directives as the deficit was at 
1.8% in 2020, which is above the target (0.5%) 
proposed by the European Commission in the 
Single Market Act (2011) (116).  
The legal and institutional framework to prevent 
and combat corruption is largely in place in 
Poland, although with some weaknesses. The 2021 
Rule of Law Report points to several risks 
regarding the effectiveness of the fight against 
high-level corruption in Poland, including a risk of 
undue influence on corruption prosecutions for 
political purposes. Specifically, the Report 
mentions concerns over the independence of the 
main anti-corruption bodies, with, for instance, the 
subordination of the Central Anti-Corruption 
Bureau to the executive. Poland is lagging behind 
in addressing Sustainable Development Goal 16 – 
Peace, Justice and Strong Institutions, although it 
has seen some progress in recent years. 
Poland has achieved a satisfactory level of 
transparency of legal persons, arrangements, and 
their beneficial ownership. However, more efforts 
are required to identify and assess certain ML/TF 
threats and vulnerabilities. The authorities should 
acknowledge and demonstrate with measures that 
terrorism financing is a stand-alone crime, not just 
a by-product of terrorism. The cash control 
mechanisms at the border should be strengthened 
by providing a legal basis to stop and restrain 
suspicious assets. A supervisory and sanctioning 
system on proliferation financing must be urgently 
put in place. Its transposition of the 5th AMLD is 
(116) A Member State is considered to have a ‘low’ (‘high’)
ranking compared with the average five euro area Member
States with the lowest scores for each indicator if its score
is at least 0.3 percentage points lower (higher) than that of
the average of this euro area group. 
not yet complete and still under assessment by the 
European Commission. 
Overall, the labour market appears flexible and 
employment protection legislation does not appear 
to be very strict (as also measured by the OECD 
employment protection indicator). However, 
structural challenges include a low participation of 
certain groups, especially women, the low-skilled, 
older people and persons with disabilities and their 
careers. A lack of labour market flexibility in some 
areas, such as a limited use of part-time 
employment arrangements, is another important 
challenge. Disincentives to work stemming from 
the benefit system and limited access to long-term 
care and childcare are important barriers to labour 
market participation. Domestic labour mobility is 
hampered by sector-specific arrangements, such as 
the special social security system for farmers, as 
well as underdeveloped rental housing market and 
the transport infrastructure, in particular in rural 
areas. Non-EU workers, in particular from 
Ukraine, play an important role in the Polish 
labour market. 
The financial sector in Poland is smaller and less 
developed than in the euro area. Relative to GDP, 
assets managed by the financial sector are a fifth of 
that of the euro area. The financial sector has 
increased slightly since 2016, but considerably less 
than in the euro area. Banking dominates the 
Polish financial sector and make up 58% of the 
financial sector’s assets. The central bank is the 
second largest holder of financial assets with a 
share of 18%. Although these shares are larger and 
more dominating than in the euro area, they 
compare well with the five euro-area Member 
States with the smallest financial sectors. 
The insurance and the pension-fund sector in 
Poland is much smaller than in the euro area, 
relative to GDP and it has decreased contrary to 
0.0
0.4
0.7
1.1
1.4
Voice and Accountability
Political Stability and Absence
of Violence/Terrorism
Government Effectiveness
Regulatory Quality
Rule of Law
Control of Corruption
Poland Euro area average five lowest Euro area average
Graph 6.10: Poland - 2020 World Bank's Worldwide Governance Indicators
Note: Estimate of governance ranges from -2.5 (weak) to 2.5 (strong). 
Source: World Bank.
Table 6.6:
Poland - Allocation of assets by financial sub-sector
Ratio to GDP (%)
PL EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Financial corporations (total) 163 167 722 796 177 215
Central bank 26 30 45 78 37 61
Monetary financial institutions 93 97 286 311 97 98
Other financial intermediaries 9 10 202 179 20 28
Non-MMF investment funds1) 16 14 100 127 4 5
Insurance co. and Pension Funds 19 16 90 102 18 23
Share of total (%)
PL EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Central bank 16 18 6 10 21 29
Monetary financial institutions 57 58 40 39 55 46
Other financial intermediaries 6 6 28 22 11 12
Non-MMF investment funds 10 8 14 16 2 2
Insurance co. and Pension Funds 12 10 12 13 10 11
1) MMF stands for money market funds.
Source: Eurostat.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 156 –
Convergence Report 2022 - Technical annex
Chapter 6 - Poland 
141 
the euro area. Since end-2016, it has decreased 
holdings of financial assets by 3.0 percentage 
points in relation to GDP, in the euro area it 
increased by 12.3 percentage points. The sector’s 
share of the total financial sector has decreased as 
well and widened the spread with the euro area. 
The investment-funds sector plays relevant role in 
the Polish financial system and its size is well 
above (by four times) to those of the five euro-area 
Member States with the smallest financial sectors. 
As to the financing of the economy, Poland has 
less developed credit and equity markets relative to 
GDP than countries in the euro area, and market 
financing (debt securities and listed shares) is 
relatively under developed. However, Poland is 
still fully comparable to the five euro-area Member 
States with the smallest national capital markets 
with only exception of the unlisted shares is it 
remained twice smaller in 2020.  
Loans are the dominant source of funding and 
make up 99% of GDP in 2020, compared to 236% 
of GDP in the euro area. Equity and private sector 
debt markets are very small compared to those of 
the euro area and represent 36% of GDP 
altogether. This compares to 83% for
privatesector debt and 73% for listed stocks in the euro 
area. Government debt is almost twice less than in 
the euro area. In terms of share of the sum of 
liabilities, loans in Poland are near to that of five 
euro-area Member States with the smallest 
financial sectors. For the securities, it is broadly in 
line with mentioned countries. 
Poland's banking sector is well integrated into the 
euro-area financial sector, in particular through a 
high level of foreign ownership in its banking 
system. The share of foreign-owned institutions in 
total bank assets stood at 43% in 2020. Bank 
concentration, as measured by the market share of 
the five largest credit institutions in total assets, 
has increased since 2016, and reached 54% in 
2020, which equals the same measure as of euro 
area. 
Intra-EU integration in equity and debt markets, as 
measured by the home bias (117) in portfolio 
investments, are in general relatively low across 
EU Member States. The integration levels of these 
markets in Poland are even smaller if compared to 
euro-area Member states and to that of five
euroarea Member States with the smallest financial 
sectors. Integration in the debt market segment has 
weakened somewhat between 2016 and 2020. 
Concerning portfolio investments in equity, the 
home bias is remained unchanged and very strong 
in Poland relative to euro-area Member States. 
Almost all investments in equity markets takes 
place domestically. 
(117) Home bias in portfolio investments measures the average
propensity of investors in a Member State to invest
domestically as compared with investing in other EU 
countries. The indicator ranges between 0 and 1, with a
value of 0 indicating that investors prefer domestic over
foreign assets. The inverse of the home bias can be
interpreted as one measure of financial integration among
EU countries.
Table 6.7:
Poland - Financing of the economy1)
Ratio to GDP (%)
PL EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Liabilities (total) 288 275 743 770 324 335
Loans 105 99 238 236 115 112
Non-financial co. debt securities 7 4 12 15 3 4
Financial co. debt securities 7 10 74 68 11 12
Government debt securities 48 52 83 95 51 57
Listed shares 29 22 65 73 17 18
Unlisted shares 27 24 186 193 55 56
Other equity 43 44 51 56 42 48
Trade credits and advances 23 21 33 35 29 29
Share of total (%)
PL EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Loans 37 36 32 31 35 33
Non-financial co. debt securities 2 1 2 2 1 1
Financial co. debt securities 3 4 10 9 3 3
Government debt securities 17 19 11 12 16 17
Listed shares 10 8 9 9 5 5
Unlisted shares 9 9 25 25 18 18
Other equity 15 16 7 7 13 14
Trade credits and advances 8 8 4 5 9 9
1) The table focuses on the financing needs of a country and how these are met by the financial system.
 The table is constructed from the liabilities of all economic sectors, but only considers loans, debt securities, 
equity and trade credits. The sum of liabilities in the table only reflects the total for the liabilities considered.
Source: Eurostat.
0
10
20
30
40
50
60
PL, 2016 PL, 2020 EA, 2016 EA, 2020
Concentration in the banking sector (CR5 ratio)
Share of foreign institutions as % of total assets
Graph 6.11: Poland - Foreign ownership and concentration 
in the banking sector
(in percent, weighted averages)
Source: ECB, Structural financial indicators. 
0.0
0.2
0.4
PL, 2016 PL, 2020 EA, 2016 EA, 2020 EA Low,
2016
EA Low,
2020
Debt Equity
Graph 6.12: Poland - Intra-EU integration in equity and debt portfolio 
investment
Note: The chart shows the extent of home bias in debt and equity markets. A value index 
of 1 implies ‘full integration’ with the financial markets of other Member States, while 0 
denotes ‘no integration’.
Source: FinFlows database: European Commission, Joint Research Centre (JRC). 
(index)
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 157 –

7. ROMANIA
143 
7.1. LEGAL COMPATIBILITY 
7.1.1. Introduction 
The Banca Naţională a României (BNR –
Romanian national bank, hereafter ‘BNR’) is 
governed by Law No. 312 on the Statute of the 
Bank of Romania of 28 June 2004 (hereinafter ‘the 
BNR Law’) which entered into force on 30 July 
2004. 
The BNR law has not been amended since the 
Commission’s 2020 Convergence Report. 
Therefore, the comments provided in the 
Commission’s 2020 Convergence Report are 
repeated also in this year's assessment. 
7.1.2. Central Bank independence 
As regards central bank independence, a number of 
incompatibilities and imperfections have been 
identified with respect to the TFEU and the 
ESCB/ECB Statute. 
According to Article 33(10) of the BNR Law, the 
Minister of Finance and one of the State 
Secretaries in the Ministry of Finance may 
participate, without voting rights, in the meetings 
of the BNR Board. Although a dialogue between a 
central bank and third parties is not prohibited as 
such, this dialogue should be constructed in such a 
way that the Government should not be in a 
position to influence the central bank's
decisionmaking in areas for which its independence is 
protected by the Treaty. The active participation of 
the Minister and one of the State Secretaries, even 
without voting right, in discussions of the BNR 
Board where BNR policy is set could structurally 
offer to the Government the possibility to 
influence the central bank when taking its key 
decisions. Against this background, Article 33(10) 
of the BNR Law is incompatible with Article 130 
of the TFEU. 
Article 3(1) of the BNR Law needs to be amended 
with a view to ensuring full compatibility with 
Article 130 of the TFEU and Article 7 of the 
ESCB/ECB Statute. Pursuant to Article 3(1) of the 
BNR Law, the members of the BNR's
decisionmaking bodies shall not seek or take instructions 
from public authorities or from any other 
institution or authority. First, for legal certainty 
reasons, it should be clarified that the BNR's 
institutional independence is also protected vis-
àvis national, foreign and EU institutions, bodies, 
offices or agencies. Moreover, Article 3 should 
expressly oblige the government not to seek to 
influence the members of the BNR's
decisionmaking bodies in the performance of their tasks. 
The BNR Law should be supplemented by rules 
and procedures ensuring a smooth and continuous 
functioning of the BNR in case of the Governor's 
termination of office (e.g. due to expiration of the 
term of office, resignation or dismissal). So far, 
Article 33(5) of the BNR Law provides that in case 
the Board of BNR becomes incomplete, the 
vacancies shall be filled following the procedure 
for the appointment of the members of the Board 
of BNR. Article 35(5) of the BNR Law stipulates 
that in case the Governor is absent or incapacitated 
to act, the First Deputy Governor shall replace the 
Governor. 
Pursuant to Article 33(9) of the BNR Law, the 
decision to recall a member of the BNR Board 
(including the Governor) from office may be 
appealed to the Romanian High Court of Cassation 
and Justice. However, Article 33(9) of the BNR 
Law remains silent on the right of judicial review 
by the Court of Justice of the European Union in 
the event of the Governor's dismissal provided in 
Article 14.2 of the ESCB/ECB Statute. This 
imperfection should be corrected. 
Article 33(7) of the BNR Law provides that no 
member of the Board of BNR may be recalled 
from office for other reasons or following a 
procedure other than those provided in Article 
33(6) of this Law. Law 161/2003 on certain 
measures for transparency in the exercise of public 
dignities, public functions and business 
relationships and for the prevention and 
sanctioning of corruption and the Law 176/2010 
on the integrity in the exercise of public functions 
and dignities define the conflicts of interest 
incompatibilities applicable to the Governor and 
other members of the Board of the BNR and 
require them to report on their interests and wealth. 
For the sake of legal certainty, it is recommended 
to remove this imperfection and provide a 
clarification that the sanctions for the breach of 
obligations under those Laws do not constitute 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 159 –
European Commission 
Convergence Report 2022 
144 
extra grounds for dismissal of the Governor of the 
Board of BNR, in addition to those contained in 
Article 33 of the BNR Law. 
According to Articles 21 and 23 of the Law 
concerning the organisation and functioning of the 
Court of Auditors (No 94/1992), the Court of 
Auditors is empowered to control the 
establishment, management and use of the public 
sector’s financial resources, including BNR's 
financial resources, and to audit the performance in 
the management of the funds of the BNR. Those 
provisions constitute an imperfection as regards 
Article 27.1 of the ESCB/ECB Statutes and thus, 
for legal certainty reasons, it is recommended to 
define clearly in the Law that the scope of audit by 
the Court of Auditors, is without prejudice to the 
activities of the BNR’s independent external 
auditors. 
Article 43 of the BNR Law provides that the BNR 
must transfer to the State budget an 80% share of 
the net revenues left after deducting expenses 
relating to the financial year, including provisions 
for credit risk, and any losses relating to previous 
financial years that remain uncovered. Such a 
procedure could, in certain circumstances, be seen 
as an intra-year credit (see Section 7.1.3.), which 
negatively impacts on the financial independence 
of the BNR. A Member State may not put its 
central bank in a position where it has insufficient 
financial resources to carry out its ESCB tasks, and 
also its own national tasks, such as financing its 
administration and own operations. Article 43(3) 
of the BNR Law also provides that the BNR sets 
up provisions for credit risk in accordance with its 
rules, after having consulted the Ministry of 
Finance. The central bank must be free to 
independently create financial provisions to 
safeguard the real value of its capital and assets. 
Article 43 of the BNR Law is incompatible with 
Article 130 of the TFEU and Article 7 of the ECB/ 
ESCB Statute and should, therefore, be adapted, to 
ensure that the above arrangements do not 
undermine the ability of the BNR to carry out its 
tasks in an independent manner. 
7.1.3. Prohibition of monetary financing and 
privileged access 
According to Article 26 of the BNR Law, the BNR 
under exceptional circumstances and only on a 
case-by-case basis may grant loans to credit 
institutions which are unsecured or secured with 
assets other than assets eligible to collateralise the 
monetary or foreign exchange policy operations of 
the BNR. It cannot be excluded that such lending 
results in the provision of solvency support to a 
credit institution that is facing financial difficulties 
and thereby would breach the prohibition of 
monetary financing and be incompatible with 
Article 123 of the TFEU. Article 26 of the BNR 
Law should be amended to avoid such a lending 
operation. 
Articles 6(1) and 29(1) of the BNR Law prohibit 
the direct purchases by the BNR in the primary 
market of debt instruments issued by the State, 
national and local public authorities, autonomous 
public enterprises, national corporations, national 
companies and other majority state-owned 
companies. Article 6(2) of the BNR Law extends 
this prohibition to the debt instruments issued by 
other bodies governed by public law and public 
undertakings of other EU Member States. Article 
7(2) of the BNR Law prohibits the BNR from 
granting overdraft facilities or any other type of 
credit facility to the State, central and local public 
authorities, autonomous public service 
undertakings, national societies, national 
companies and other majority state owned 
companies. Article 7(4) of the BNR Law extends 
this prohibition to other bodies governed by public 
law and public undertakings of Member States. 
These provisions do not fully mirror the entities 
listed in Article 123 of the TFEU (amongst others, 
a reference to Union institutions is missing) and, 
therefore, have to be amended.  
Pursuant to Article 7(3) of the BNR Law, majority 
state-owned credit institutions are exempted from 
the prohibition on granting overdraft facilities and 
any other type of credit facility under Article 7(2) 
of the BNR Law and benefit from loans granted by 
the BNR in the same way as any other credit 
institution eligible under the BNR's regulations. 
The wording of Article 7(3) of the BNR Law is 
incompatible with the wording of Article 123(2) of 
the TFEU, which only exempts publicly owned 
credit institutions ’in the context of the supply of 
reserves by central banks’, and should be aligned. 
As noted above in point 7.1.2., Article 43 of the 
BNR Law provides that the BNR shall transfer to 
the State on a monthly basis 80% of its net 
revenues left after deduction of the expenses 
related to the financial year and the uncovered loss 
of the previous financial years. This provision does 
not rule out the possibility of an intra-year 
anticipated profit distribution under circumstances 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 160 –
Convergence Report 2022 - Technical annex 
Chapter 7 - Romania 
145 
where the BNR would accumulate profit during 
the first half of a year, but suffer losses during the 
second half. The adjustment would be made by the 
State only after the closure of the financial year 
and would thus imply an intra-year credit to the 
State, which would breach the prohibition on 
monetary financing. This provision is, therefore, 
also incompatible with the Article 123 of the 
TFEU and has to be amended. 
7.1.4. Integration in the ESCB 
Objectives 
Pursuant to Article 2(3) of the BNR Law, the 
secondary objective of the BNR is to support the 
State’s general economic policy. Article 2(3) of the 
BNR Law contains an imperfection as it should 
contain a reference to the general economic 
policies in the Union as per Article 127(1) of the 
TFEU and Article 2 of the ESCB/ECB Statute. 
Tasks 
The incompatibilities in the BNR Law are linked 
to the following ESCB/ECB tasks: 
• absence of a general reference to the BNR as 
an integral part of the ESCB (Article 1 of the 
BNR Law); 
• definition of monetary policy and monetary 
functions, operations and instruments of the 
ESCB (Articles 2(2)(a), 5, 6(3), 7(1), 8, 19, 20, 
21 (1) and (2), 22(3) and 33(1)(a) and (e) of the 
BNR Law); 
• conduct of foreign exchange operations and the 
definition of foreign exchange policy (Articles 
2(2)(a) and (d), 9 and 33(1)(a) of the BNR 
Law); 
• holding and management of foreign reserves 
(Articles 2(2)(e), 9(2)(c), 30 and 31 of the BNR 
Law); 
• right to authorise the issue of banknotes and the 
volume of coins (Articles 2(2)(c), 12 to 18 of 
the BNR Law); 
• non-recognition of the role of the ECB and of 
the Council in regulating, monitoring and 
controlling foreign currency transactions 
(Articles 10 and 11 of the BNR Law); 
• lack of reference to the role of the ECB in 
payment systems (Articles 2(2)(b), 22 and 
33(1)(b) of the BNR Law). 
There are also imperfections regarding the:  
• non-recognition of the role of the ECB and the 
EU in the collection of statistics (Article 49 of 
the BNR Law);  
• non-recognition of the role of the ECB and of 
the Council in the appointment of an external 
auditor (Article 36(1) of the BNR Law);  
• absence of an obligation to comply with the 
ESCB/ECB regime for the financial reporting 
of NCB operations (Articles 37(3) and 40 of 
the BNR Law); 
• non-recognition of the ECB's right to impose 
sanctions (Article 57 of the BNR Law). 
7.1.5. Assessment of compatibility 
As regards the independence of the BNR, the 
prohibition on monetary financing and the BNR's 
integration into the ESCB at the time of euro 
adoption, the legislation in Romania, in particular 
the BNR Law, is not fully compatible with the 
compliance duty under Article 131 of the TFEU. 
The Romanian authorities are invited to remedy 
the above-mentioned incompatibilities. 
7.2. PRICE STABILITY 
7.2.1. Respect of the reference value 
At the time of the last convergence assessment of 
Romania in 2020, the twelve-month average 
inflation rate, which is used for the convergence 
assessment, was above the reference value. From 
3.6% in April 2020, the twelve-month average 
inflation rate decreased steadily to 2.1% by March 
2021, but rose sharply to 4.1% by the end of 2021. 
In April 2022, the reference value was 4.9%, 
calculated as the average of the 12-month average 
inflation rates in France, Finland and Greece plus 
1.5 percentage points. The corresponding inflation 
rate in Romania was 6.4%, which was 1.5 
percentage points above the reference value. The 
12-month average inflation rate is projected to 
remain well above the reference value in the 
months ahead. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 161 – 
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7.2.2. Recent inflation developments 
Annual HICP inflation in Romania stood at 4.1% 
in 2021, up from 2.3% in 2020. The low annual 
average rate of inflation in 2020 reflected the 
effect of lockdown and mobility restriction 
measures, which were felt throughout the economy 
in terms of reduced demand for goods and 
services. The year-on-year inflation rate fell from 
3.9% in January 2020 to 1.8% in May 2020, which 
was its lowest level since September 2017, also 
reflecting the sharp drop in the international price 
of crude oil in the first four months of 2020. After 
a temporary rise to 2.5% in July 2020, reflecting 
strong food price inflation, it decreased to 1.7% by 
November 2020. Subsequently, inflation rose 
uninterruptedly, reaching 3.5% in June 2021, 5.2% 
in September 2021 and 6.7% in November 2021, 
driven by high energy price inflation throughout 
2021 and, in the later part of 2021, also sustained 
by higher inflation for processed food and, to a 
lesser extent, non-energy industrial goods and 
services. Over the past two years, annual HICP 
inflation in Romania was higher than in the euro 
area by around 1.75 percentage points on average.  
Core inflation (measured as HICP inflation 
excluding energy and unprocessed food) declined 
slightly from 3.3% in 2020 to 3.1% in 2021. If fell 
from a high of 4.0% in January 2020 to 2.4% by 
July 2021, before increasing sharply during the 
subsequent months to 4.5% in November 2021. 
Higher prices for processed food, which increased 
by more than 4% in both years, contributed 
significantly to core inflation, while the annual 
price changes for non-energy industrial goods 
(2.3% and 2.6% in 2020 and 2021 respectively) 
and services (2.7% for both 2020 and 2021) were 
more muted. Wage growth was moderate in 2020 
due to falling economic activity, but went up again 
in 2021 against the background of a robust 
economic recovery and high inflation. 
While lower energy demand resulted in a decrease 
in the energy component of HICP inflation of 
almost 7.5% in 2020, relatively high increases 
were recorded in the prices for processed and 
unprocessed food that year, by 5% and 5.3% 
respectively. In 2021 when the economy fully 
recovered and pent-up demand was released, 
inflation picked up again. Energy price inflation 
was particularly high in the second half of the year, 
-4
-2
0
2
4
6
8
10
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Romania Reference value
Graph 7.1: Romania - Inflation criterion
(percent, 12-month moving average)
Note: The dots at the right end of the chart show the projected reference 
value and 12-month average inflation rate of the country in December 2022.
The reference values for 2016, 2018 and 2020 refer to the reference values 
calculated in the previous Convergence Reports.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
-4
-2
0
2
4
6
8
10
12
14
2016 2017 2018 2019 2020 2021
Romania Euro area
Graph 7.2: Romania - HICP inflation
(y-o-y percentage change)
Source: Eurostat.
Table 7.1: weights  
Romania - Components of inflation (percentage change)1) in total   
2016 2017 2018 2019 2020 2021 Apr-22 2022
HICP -1.1 1.1 4.1 3.9 2.3 4.1 6.4 1000
Non-energy industrial goods -0.7 0.9 1.7 2.4 2.3 2.6 3.1 292
Energy -4.4 0.4 12.2 2.7 -7.4 15.2 23.7 121
Unprocessed food -2.5 3.9 5.3 6.2 5.3 1.8 5.3 113
Processed food -0.9 2.2 3.7 5.5 5.0 4.0 6.2 251
Services 0.7 -0.5 2.7 3.6 2.7 2.7 3.8 223
HICP excl. energy and unproc. food -0.2 0.9 2.7 3.8 3.3 3.1 4.3 766
HICP at constant tax rates 2.1 2.0 3.8 3.7 2.3 3.9 6.3 1000
Administered prices HICP -2.5 0.5 4.2 2.6 1.2 1.8 3.0 94
1) Measured by the arithmetic average of the latest 12 monthly indices relative to the arithmetic average of the 12 monthly indices
in the previous period.
Source: Eurostat, European Commission calculations.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 162 –
Convergence Report 2022 - Technical annex 
Chapter 7 - Romania 
147 
up from 13.5% y-o-y in June to 25% in December. 
The support measures addressed to vulnerable 
consumers, households and SMEs moderated to a 
certain extent the increase in energy prices, as 
prices for electricity, gas, and heating energy were 
capped. Nevertheless, energy prices registered a 
12-month average increase of 21.7% in March 
2022. This was partly due to the fact that the HICP 
sub-component for liquid fuels and fuels and 
lubricants for personal transport equipment was 
not capped and recorded a 12-month average 
increase of 29.5% in March. International trade 
bottlenecks affecting supply-chains, as well as 
higher energy prices translated into marked 
increases in producer prices in manufacturing, 
averaging about 10.4% in 2021. 
7.2.3. Underlying factors and sustainability of 
inflation 
Macroeconomic policy mix and growth 
developments 
Real GDP dropped by 3.7% in 2020, but recovered 
in 2021 with a 5.9% increase. In 2020, due to the 
COVID-19 crisis, private consumption, imports 
and exports were particularly negatively affected, 
but investments and government consumption 
continued to grow. In 2021, real GDP was back to 
pre-pandemic levels by the end of the first half of 
the year, but the growth momentum declined in the 
third quarter and turned negative in the final one. 
Private consumption and investment represented 
the main growth drivers in 2021. After a 5.1% 
drop in the preceding year, private consumption 
grew at 7.9% in 2021. Gross fixed capital 
formation maintained a steady positive trend, even 
during the COVID-19 crisis. In particular, 
equipment investments were a strong growth 
driver as the economy quickly adapted to the new 
pandemic environment. Construction, on the other 
side, moderated its growth in 2020, but recorded a 
6.1% increase the next year. Strong domestic 
demand in 2021 fuelled import growth. As a 
consequence, despite a relatively strong export 
performance, net exports made a negative 
contribution to real GDP growth that year. The 
growing trade deficit worsened the current account 
balance. According to the Commission’s Spring 
2022 Economic Forecast, real GDP growth is 
expected to increase by 2.6% this year, as private 
consumption is projected to be more subdued on 
account of higher inflation and uncertainty. At the 
same time, investment, supported by the RRF and 
other EU funds, is set to increase robustly. For 
2023, real output growth is projected at 3.6%, as 
inflationary pressures and supply-side bottlenecks 
are expected to gradually abate. 
 
 
        
 
 
Table 7.2:
Romania - Other inflation and cost indicators (annual percentage change)
2016 2017 2018 2019 2020 2021 20221) 20231)
HICP inflation
Romania -1.1 1.1 4.1 3.9 2.3 4.1 8.9 5.1
Euro area 0.2 1.5 1.8 1.2 0.3 2.6 6.1 2.7
Private consumption deflator
Romania 0.7 2.7 3.8 5.4 2.4 5.5 9.1 5.3
Euro area 0.4 1.3 1.5 1.1 0.5 2.3 5.8 2.7
Nominal compensation per employee
Romania 15.5 14.8 12.9 10.9 2.6 5.7 8.3 7.0
Euro area 1.2 1.7 2.1 2.1 -0.7 4.1 3.6 3.5
Labour productivity 2)
Romania 5.9 4.8 4.4 4.1 -2.0 16.2 1.7 2.8
Euro area 0.4 1.0 0.2 0.3 -4.9 4.2 1.4 1.5
Nominal unit labour costs 2)
Romania 9.1 9.6 8.2 6.6 4.7 -9.0 6.4 4.1
Euro area 0.8 0.7 2.0 1.9 4.4 0.0 2.2 2.0
Imports of goods deflator
Romania -7.2 5.3 4.8 0.2 -2.3 10.5 12.0 4.0
Euro area -3.3 3.3 2.6 -0.5 -3.8 9.6 13.2 0.8
1) Commission's Spring 2022 Economic Forecast.
2) Due to a break in the historical employment data for Romania in 2021, employment-related variables have been affected.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 163 – 
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In 2020-2021, as part of the policy response to the 
COVID-19 crisis, the government provided 
support to the healthcare sector and to households 
and companies hit by the pandemic, including 
incentives to retain the workforce. This response 
was facilitated by new European instruments, 
namely loans from SURE (Support to mitigate 
Unemployment Risks in an Emergency) and loans 
and grants from NextGenerationEU/RRF.  
In 2021, the fiscal stance (118), was contractionary, 
at 0.5% of GDP , after a supportive stance of -
1.6% in 2020. Going forward, the Commission’s 
Spring 2022 Economic Forecast projects a 
supportive fiscal stance at -1.0% of GDP in 2022, 
driven by higher nationally-financed investment, 
expenditure financed through the RRF and other 
EU grants and the temporary support to mitigate 
the impact of high energy prices (estimated around 
0.7% of GDP. The budgetary costs related to 
assisting people fleeing Ukraine is assumed at 
close to 0.1% of GDP. The no policy-change 
forecast for 2023 shows a contractionary stance 
(1.3% of GDP) reflecting the withdrawal of the 
support measures introduced in response to the 
increase in energy prices. 
The BNR, operating within an inflation targeting 
framework (119), gradually reduced the key policy 
rate by 125 basis points between March 2020 and 
January 2021, as part of the measures taken in 
response to COVID-19 crisis. The policy rate 
remained stable at 1.25% until October 2021. In 
response to rising inflation, the BNR tightened its 
monetary policy stance by steadily raising the 
policy rate by a total of 250 basis points between 
October 2021 and May 2022. In May 2022, the 
policy rate stood at 3.75%.  
In April 2020, the BNR also started purchasing 
government bonds in the secondary market to 
consolidate the structural liquidity in the banking 
system, thereby supporting favourable financing 
conditions for the economy. It continued to 
purchase government securities on an irregular 
(118) The fiscal stance is measured as the change in primary
expenditure (net of discretionary revenue measures),
excluding Covid-19 crisis-related temporary emergency
measures but including expenditure financed by
nonrepayable support (grants) from the Recovery and
Resilience Facility and other EU funds, relative to
mediumterm potential growth. A negative (positive) sign of the
indicator corresponds to an excess (shortfall) of primary
expenditure growth compared with medium-term economic
growth, indicating an expansionary (contractionary) fiscal
policy.
(119) As from 2013, the BNR follows a flat multi-annual 
inflation target of 2.5% (± 1 percentage point). 
basis throughout 2020, 2021 and in the first 
months of 2022. The reserve requirement ratio on 
accounts opened with BNR for the foreign 
currency holdings of the credit institutions, which 
stood at 6% in February 2020, has been reduced to 
5% since November of the same year. The reserve 
requirement ratio for leu denominated holdings has 
been unchanged since May 2015 at 8%. 
The overall credit to the economy continued to 
expand in 2020 and 2021, sustained by 
government support measures. These increases 
were primarily supported by the expansion of 
credit to households for housing (9.9% in 2020 and 
12.9% in 2021) and to Non-Financial Corporations 
(5.3% in 2020 and 19.8% in 2021). Consumer 
loans to households were down by 2.2% at the end 
of 2020    compared to the preceding year, before 
rebounding by 4.9% by the end of 2021. Loans to 
the general government grew by close to 116% in 
2021, reflecting the overall need of the government 
to finance its sizeable budget deficit.  
Wages and labour costs 
Labour market conditions improved in the second 
half of 2020 and in 2021 after the initial 
deterioration due to the COVID-19 shock in early 
2020, in line with robust economic growth and 
government’s support measures. Also through the 
help of measures financed from SURE, the 
employment rate improved, from a low of 64% in 
the second quarter of 2020 to more than 67% at the 
end of 2021, while the unemployment rate 
continued to decrease from 6.7% in June 2020 to 
5.7% in December 2021. Unemployment is 
projected to decrease and stay at levels close to 
5.5% in the next two years, as the economy 
continues to grow (120). Undeclared work remains 
a challenge, but its negative impact on social 
contribution system and government revenues is 
expected to be partly addressed by RRP reforms 
such as the introduction of work cards for domestic 
work and improvements of tax administration 
processes. 
The increase in labour market slack, coupled with 
the relatively low inflation and the drop in 
productivity that took place in 2020, toned down 
wage pressures. As a result, nominal compensation 
per employee increased by only 2.6%. In 2021, 
wage growth remained stable, also as a result of 
(120) Due to the change in the Labour Force Survey
methodology, the figures in the 2022 Convergence Report
are not comparable with the ones in the 2020 Report.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 164 –
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Chapter 7 - Romania 
149 
the freezing of public sector wages (expected to 
continue in 2022), whereas for 2022 the 
combination of a tighter labour market, skill 
shortages, higher productivity and inflationary 
pressures are expected to push wages up again, 
especially in the services sector. On the other hand, 
supply chain bottlenecks could negatively affect 
wages in the manufacturing sector. Minimum 
wage increases of 3.1% in mid-2021 and 10.9% in 
January 2022 were legislated to compensate 
households for the loss of purchasing power due to 
higher inflation. As of 2024, Romania committed 
in the RRP to create a new mechanism formula to 
objectively set the minimum wage level.   
Labour productivity per person contracted by 2.2% 
in 2020, reflecting efforts to retain workers in 
employment notwithstanding the contraction in 
economic activity, but recorded an increase in the 
year after. In 2022, labour productivity is forecast 
to improve by just 2%, in line with the more 
subdued output growth. During the pandemic, 
while wage growth moderated, labour 
compensation still grew more than productivity, 
resulting in an increase in nominal unit labour 
costs (ULC). According to the Commission’s 
Spring 2022 Economic Forecast, the ULC growth 
rate in Romania is expected to slowly pick-up in 
2022 and 2023 and to remain above the average 
growth rates in the euro area, mirroring the 
projected growth in wages continuing to outpace 
productivity increases.   
               
External factors 
Due to the openness of the Romanian economy 
and its deep integration into the global and the EU 
economy, developments in import prices play a 
significant role in domestic price formation. In 
particular, energy and food import prices have 
been a significant determinant of price inflation in 
Romania, given the large weight of these 
categories in the Romanian HICP and the fact that 
Romania is a net importer of energy. Import price 
inflation (measured by the imports of goods 
deflator) was significantly lower than consumer 
price inflation in 2020, reflecting the reduction in 
the price of fuel commodities. In 2021, however, 
import price inflation exceeded by almost 6.4 
percentage points the HICP inflation, reflecting the 
sudden increase in the prices of the same 
commodities. 
The leu’s nominal effective exchange rate 
(measured against a group of 36 trading partners) 
remained broadly stable in the past two years, 
depreciating only moderately, by less than 1% 
between the beginning of 2020 and the end of 
2021. Looking ahead, imported inflation is 
expected to remain high and above HICP inflation, 
in line with expected developments in global 
commodity and energy prices. 
Administered prices and taxes 
The weight of administered prices in the 2021 
Romanian HICP basket (9.4%) is below the euro 
area average (15.5%). The average annual change 
in administered prices was 1.2% in 2020, below 
the headline inflation rate by 1.1 percentage points. 
In 2021, administered prices increased by just 
1.8%, which was much below the 4.1% headline 
figure, mainly reflecting the slow increase in the 
non-energy administered prices component and 
decreases of the energy one in the first half of the 
year. Following legislative changes adopted at the 
beginning of 2020, the liberalisation of gas and 
electricity prices for households has been 
completed as of 1 July 2020 and 1 January 2021, 
respectively. However, in the context of marked 
price increases in late 2021, the government 
adopted legislation capping gas and electricity 
prices, with reduced tariffs for lower energy 
consumption brackets. The support measures were 
extended until April 2023. 
Tax changes had a marginal influence on inflation 
in Romania in the last two years. HICP inflation 
measured at constant taxes was similar to headline 
HICP inflation. For 2020, the former stood at 
2.3%, equal to the headline inflation figure, 
whereas it was 3.9% in 2021, 0.2 percentage point 
lower than the headline HICP inflation rate. 
-12
-8
-4
0
4
8
12
16
20
2016 2017 2018 2019 2020 2021 2022 2023
Productivity (real GDP per person employed)
Nominal compensation per employee
Nominal unit labour costs
HICP inflation
Graph 7.3: Romania - Inflation, productivity and wage trends
(y-o-y % change)
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Note: Due to a break in the historical employment data for Romania in 2021, 
employment-related variables have been affected.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 165 – 
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150 
Medium-term prospects 
According to the Commission’s Spring 2022 
Economic Forecast, annual HICP inflation is 
projected to increase further to 8.9% in 2022 
before falling to 5.1% in 2023. The significant 
increase in 2022 is mainly due to the hike in 
energy prices, with pass-through into other 
components, but also due to a rise in food prices. 
Services’ inflation is also projected to pick-up, 
reflecting a surge in transport services inflation 
due to higher fuel prices. Inflation in non-energy 
industrial goods is projected to show a similar 
dynamic as HICP energy inflation, but of a 
considerably lower magnitude. 
Risks to the inflation outlook are mainly on the 
upside, stemming from the implications of 
Russian’s invasion of Ukraine for global food and 
energy prices. Other aspects, such as an 
increasingly tight labour market, contribute to the 
uncertainty of the inflation forecast. 
In 2020, the level of consumer prices in Romania 
was about 52% of the euro area average. The GDP 
per capita was around 70% of the euro area 
average in PPS terms in 2021. Due to the process 
of catching-up of the Romanian economy, price 
level convergence is expected over the next years. 
7.3. PUBLIC FINANCES 
7.3.1. Recent fiscal developments 
The general government deficit decreased from 
9.3% of GDP in 2020 to 7.1% in 2021. The 
markedly high deficit in 2020  was mainly driven 
by a combination of additional expenditure due to 
the COVID-19 outbreak (healthcare spending and 
support measures to the economy and labour 
market) and a denominator effect given the 3.9% 
drop in real output. In 2021, the government 
enacted some limited consolidation measures, 
including a freeze in public sector wages, while 
revenues increased due to the economic recovery. 
Still, COVID-19 support measures continued in 
2021. 
Romania is subject to an excessive deficit 
procedure (121). On 18 June 2021, the Council 
adopted a recommendation under Article 126(7) of 
the Treaty (TFEU), with a view to bringing an end 
to the situation of an excessive government deficit 
in Romania by 2024 at the latest. Romania was 
recommended to reduce the general government 
deficit to 8.0% of GDP in 2021, 6.2% of GDP in 
2022, 4.4% of GDP in 2023, and 2.9% of GDP in 
2024. On 23 May 2022, the Commission 
concluded that Romania’s deficit outturn of 7.1% 
                                                          
(121) Following the expansionary fiscal stance and the high 
fiscal deficit recorded in 2019 and previous years, Romania 
entered an Excessive Deficit Procedure (EDP) in the spring 
of 2020. 
 
 
  
 
 
Table 7.3:
Romania - Budgetary developments and projections (as % of GDP unless indicated otherwise)
Outturn and forecast 1) 2016 2017 2018 2019 2020 2021 20221) 20231)
General government balance -2.6 -2.6 -2.8 -4.3 -9.3 -7.1 -7.5 -6.3
- Total revenue 32.0 30.8 32.0 31.9 32.7 32.8 33.6 33.3
- Total expenditure 34.6 33.5 34.8 36.2 42.0 39.9 41.1 39.6
   of which: 
- Interest expenditure 1.5 1.3 1.0 1.1 1.4 1.4 1.5 1.6
p.m.: Tax burden 26.7 25.8 26.8 26.8 27.1 27.3 27.9 27.7
Primary balance -1.1 -1.4 -1.8 -3.2 -8.0 -5.7 -6.0 -4.7
Fiscal stance 2) -1.6 0.5 -1.0 1.3
Government gross debt 37.3 35.1 34.7 35.3 47.2 48.8 50.9 52.6
p.m: Real GDP growth (%) 4.7 7.3 4.5 4.2 -3.7 5.9 2.6 3.6
1) Commission's Spring 2022 Economic Forecast. 
2) A negative (positive) sign of the indicator corresponds to an excess (shortfall) of primary expenditure growth 
compared with medium-term economic growth, indicating an expansionary (contractionary) fiscal policy.
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 166 – 
Convergence Report 2022 - Technical annex 
Chapter 7 - Romania 
151 
of GDP in 2021 and the fiscal effort are in line 
with the Article 126(7) recommendation of the 
Council and, therefore, the excessive deficit 
procedure was kept in abeyance.  
The general government debt-to-GDP ratio rose 
from 35.3% of GDP in 2019 to 47.2% in 2020 and 
48.8% in 2021. The increases in 2020 and 2021 
were mainly driven by the high primary deficit. 
The snow-ball effect and stock-flow adjustments 
both contributed to the increase in the debt ratio in 
2020, whereas in 2021 they had a diminishing 
effect on the debt ratio. Liquidity support for 
households and companies in the form of 
guarantees and tax deferrals did not have a direct 
budgetary impact, but the guarantees represent 
contingent liabilities, estimated by the 
Commission services at around 3.2% of GDP as of 
December 2021.  
7.3.2. Medium-term prospects 
The 2022 budget, published on 28 December 2021, 
targets a reduction of the general government 
deficit to 6.2% of GDP in 2022. Several
deficitincreasing expenditure measures were announced, 
such as an increase in the pension point value, an 
increase in minimum pensions by 20%, the one-off 
top-up of pensions in the RON 1,600-2,200 
bracket for people with disabilities and the growth 
of children’s allowance by 16%. The planned 
improvement of the headline budget balance for 
2022 is mainly due to automatic stabilisers, as the 
economy’s growth is set to stay robust, and to the 
expiry of the emergency health and labour market 
support measures. Moreover, a number of
deficitreducing measures will come into effect in 2022, 
such as the levying of social security contributions 
for health for pensions higher than RON 4,000.   
In light of the increase in energy prices, the 
government approved measures to support 
measures to particular groups, such as poorer 
households and SMEs, to shield them against the 
increase in energy prices. These measures 
amounted to 0.7 of GDP in 2022 and consisted of 
allowances to vulnerable consumers, compensation 
schemes for households’ energy bills, and energy 
and gas price caps on the expenditure side, and a 
measure to tax the energy and gas domestic 
producers’ windfall revenues on the revenue side. 
In view of the humanitarian crisis following the 
invasion of Ukraine by Russia, the Commission 
estimates a budgetary cost of the support measures 
adopted by the Romanian government of 0.1% of 
GDP in 2022 and 0.1% in 2023. 
On 5 May 2022, Romania submitted its 2022 
Convergence Programme. According to the 
Programme, the headline deficit is projected to 
decline steadily to 6.2% of GDP in 2022 and 4.4% 
in 2023. The Programme targets a reduction of the 
government deficit to under 3% of GDP by 2024, 
in line with the Council recommendation.  
The Commission Spring 2022 Economic Forecast, 
which is based on a no-policy change assumption, 
projects a general government deficit of around 
7.5% of GDP in 2022. The difference from the 
planned deficit in the Convergence Programme 
stems, in particular, from a difference in the 
underlying macroeconomic projections, an 
increase of some revenue items in the 2022 budget 
(and the Convergence Programme) that are not 
fully supported by enacted measures and therefore 
not taken into account in the Commission’s 
forecast, increased social expenditure and support 
to the economy and the measures to deal with the 
surge in energy prices and the flow of refugees. 
The Commission projects the general government 
deficit to further decrease to around 6.3% of GDP 
in 2023, as revenues are expected to grow strongly 
on the back of the economic recovery, while 
COVID-19 temporary emergency measures are 
expected to be phased out and the cost of the 
measures to deal with the surge of energy price are 
assumed to decrease. Romania is at risk of
noncompliance with the fiscal targets for 2022 
established in the Council Recommendation of 18 
June 2021. 
In 2022, the fiscal stance is projected in the 
Commission’s Spring 2022 Economic Forecast to 
be supportive, at -1.0% of GDP (122). The 
additional positive contribution to economic 
activity of expenditure financed by Recovery and 
Resilience Facility grants and other EU funds is 
projected to increase by 0.3 percentage point of 
GDP in 2022. Nationally financed investment is 
projected to provide an expansionary contribution 
to the fiscal stance of 1.5 percentage points of 
GDP in 2022. At the same time, the growth in 
nationally financed primary current expenditure 
(net of new revenue measures) in 2022 is projected 
to provide a contractionary contribution of 0.6 
percentage point of GDP to the overall fiscal 
                                                          
(122) For a definition of the fiscal stance used in this report, see 
footnote in Section 7.2.3 on underlying factors and 
sustainability of inflation.  
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 167 – 
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152 
stance, as current expenditure is set to grow at a 
slower pace than medium-term potential growth. 
This contribution is contractionary notwithstanding 
the expansionary impact of the measures related to 
the energy crisis (0.7% of GDP) and the assistance 
to those fleeing Ukraine (less than 0.1% of GDP).  
In 2023, the fiscal stance is projected to be 
contractionary at 1.3% of GDP. The additional 
positive contribution to economic activity of 
expenditure financed by Recovery and Resilience 
Facility grants and other EU funds is projected to 
decrease by 0.1 percentage points of GDP. 
Nationally financed investment is projected to 
provide an expansionary contribution to the fiscal 
stance of 0.2 percentage point of GDP (123), 
whereas the growth in nationally financed primary 
current expenditure is projected to provide a 
contractionary contribution of 1.1 percentage point 
of GDP to the overall fiscal stance in 2023, as the 
support measures to face the energy crisis in 2022 
are assumed to be phased out.   
The government debt-to-GDP ratio is forecast by 
the Commission to increase to 50.9% in 2022 and 
52.6% in 2023. Debt sustainability risks appear 
medium over the medium term. Government debt 
is projected to increase reaching around 73% of 
GDP in 2032. This projection assumes that the 
structural primary balance (except for the impact 
of ageing) remains constant at the forecast level for 
2023 of -3.8% of GDP, which is the same 
compared to the 2019 level.  
The sensitivity to possible macro-fiscal shocks 
contributes to this assessment. In particular, if only 
half of the projected percentage point improvement 
in the structural primary balance in 2022-2023 
(123) Other nationally financed capital expenditure is projected
to provide a contractionary contribution of 0.2 percentage 
point of GDP each year in 2022 and in 2023. 
were to occur, the projected debt ratio in 2032 
would be about 5 percentage points of GDP higher 
than in the baseline. 
Some factors mitigate risks, including the 
lengthening of debt maturity in recent years and 
relatively stable financing sources and the 
expected positive impact on long-term growth of 
reforms under the Recovery and Resilience Plan. 
Risk-increasing factors include the share of debt 
held by non-residents, the currency denomination 
of debt, and the country’s negative net 
international investment position. An additional 
risk-increasing factor is the possible 
materialisation of state guarantees granted to firms 
and self-employed during the COVID-19 crisis, 
though this risk remains currently limited due to 
relatively low take-up (124). 
Romania has a strong fiscal framework in place, 
consisting of in principle well-designed fiscal 
rules, a medium-term budgetary framework and an 
independent fiscal council. However, the track 
record in the application of the framework has 
been generally poor, as noted in previous 
Convergence Reports (2020 and 2018). In 
particular, the annual budget laws have repeatedly 
been in contradiction with national fiscal rules and 
not guided by the medium-term budgetary 
strategies following significant delays in the 
adoption of the latter. Faced with the COVID-19 
shock in 2020, fiscal rules were equipped with the 
required flexibility to allow for a large deviation 
from targets. 
7.4. EXCHANGE RATE STABILITY 
The Romanian leu does not participate in ERM II. 
Romania has been operating a de jure managed 
floating exchange rate regime since 1991 with no 
preannounced path for the exchange rate (125). De 
facto, the exchange rate regime moved gradually 
from a strongly managed float – including through 
the use of administrative measures until 1997 – to 
a more flexible one. In 2005, Romania shifted to a 
direct inflation targeting framework combined 
with a floating exchange rate regime. The BNR 
has, nonetheless, stressed that currency 
(124) For further details see the 2021 Fiscal Sustainability
Report. 
(125) On 1 July 2005 the Romanian Leu (ROL) was replaced by
the new leu (RON), with a conversion factor of 1 RON =
10,000 ROL. For convenience, however, the text of this
report consistently refers to leu, meaning ROL before and
RON after the conversion. 
-2
-1
0
1
2
2020 2021 2022 2023
Net nationally financed  primary current expenditure Nationally financed investment
Other capital expenditure Expenditure financed by RRF grants and EU funds
Fiscal stance
Expansionary
Contractionary
Graph 7.4: Romania - Fiscal stance and its components
Source: Commission's Spring 2022 Economic Forecast. 
(percent of GDP)
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 168 –
Convergence Report 2022 - Technical annex 
Chapter 7 - Romania 
153 
intervention remains available as a policy 
instrument and has actively used this instrument. 
The leu has depreciated steadily against the euro 
since 2017. Between the beginning of 2020 and 
April 2022, the leu weakened against the euro by 
around 3.5%. Over this period, the volatility of the 
leu’s inter-day exchange rate was moderate 
compared to that of other floating currencies in 
Member States with a derogation. The leu 
weakened against the euro by around 1.0% 
between January and April 2021. It remained 
relatively stable on average in the subsequent four 
months, but in October 2021 the leu depreciated 
against the euro by 0.5%. It averaged around a 
RON/EUR level of 4.95 during the rest of 2021 
and the first four months of 2022. In April 2022, 
the leu’s exchange rate against the euro averaged 
around 4.94. 
The gross international reserves held by the BNR 
declined to a low of around EUR 38bn in the third 
quarter of 2020 and recovered to around EUR 
43bn at the end of 2020. The reserves continued to 
increase throughout most of 2021 to close to EUR 
46bn at the end of 2021, reaching close to 19% of 
GDP and stood at around EUR 46bn in the first 
quarter of 2022. Over this period, movements in 
the level of international reserves were influenced 
by changes in the foreign exchange reserve 
requirements of credit institutions, sovereign debt 
management decisions, such as euro-denominated 
government bond issuances and, towards the end 
of 2021 and beginning of 2022, the first
prefinancing payments under the EU’s Recovery and 
Resilience Facility. 
Short-term interest rate spreads vis-à-vis the euro 
area decreased by around 120 basis points between 
March 2020 and February 2021, mirroring the 
above-mentioned policy rate cuts by the Romanian 
central bank over this period. The three-month 
interest rate spread stabilised at around 210 basis 
points until September 2021, before steadily 
increasing to almost 500 basis points by March 
2022. These developments in part reflected the 
tightening of monetary policy by the BNR in 
response to the increasing inflation, with the key 
policy rate raised from 1.25% in September 2021 
to 3.75% in May 2022. The three-month interest 
rate spread relative to the euro stood at around 520 
basis points in April 2022, well above its
prepandemic levels. 
7.5. LONG-TERM INTEREST RATES 
The long-term interest rates in Romania used for 
the purpose of the convergence examination reflect 
secondary market yields on a single government 
benchmark bond with a residual maturity of 
around 10 years. 
4.2
4.4
4.6
4.8
5.0
2016 2017 2018 2019 2020 2021
Graph 7.5: Romania - RON/EUR exchange rate
(monthly averages)
Source: ECB.
0
100
200
300
400
500
600
2016 2017 2018 2019 2020 2021
Graph 7.6: Romania - 3-M Robor spread to 3-M Euribor
(basis points, monthly values)
Source: National Bank of Romania, Eurostat and Thomson Reuters
0
2
4
6
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Romania Reference value
Graph 7.7: Romania - Long-term interest rate criterion
(percent, 12-month moving average)
Source: European Commission.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 169 –
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154 
The Romanian twelve-month moving average 
long-term interest rate relevant for the assessment 
of the Treaty criterion was above the reference 
value at the time of the last convergence 
assessment of Romania in 2020. From 4.4% in 
April 2020, it fell to around 3.1% by July 2021 but 
increased again throughout the rest of 2021. In 
April 2022, the reference value, which is measured 
as the average of long-term interest rates in France, 
Finland and Greece plus 2 percentage points, stood 
at 2.6%. In that month, the twelve-month moving 
average of the yield on the Romanian benchmark 
bond was at 4.7%, i.e. 2.1 percentage points above 
the reference value. 
At the outset of the COVID-19 crisis, the
longterm interest rate in Romania increased sharply 
from 4.0% in February 2020 to 4.8% in April 
2020. Subsequently, the long-term interest rate 
decreased steadily, reaching a through of 2.7% in 
February 2021. The decline reflected the 
widespread monetary policy loosening measures 
by central banks, which depressed long-term 
yields. Interest rates started to increase again in 
March 2021 and were on an upward path 
throughout 2021, rising to 5.4% in December 
2021, reflecting higher inflationary pressures and, 
as from October 2021, monetary policy tightening 
in Romania. The long-term interest rate of 
Romania increased further during the first four 
months of 2022, in the context of continued 
inflationary pressures, further monetary policy 
tightening, and heightened risk aversion following 
Russia’s invasion of Ukraine. It reached 6.6% in 
April 2022 and the long-term spread versus the 
German benchmark bond reached 586 basis points 
in that month, up from 310 basis points in 
February 2021. 
7.6. ADDITIONAL FACTORS 
The Treaty (Article 140 TFEU) calls for an 
examination of other factors relevant to economic 
integration and convergence to be taken into 
account in the assessment. The assessment of the 
additional factors – including balance of payments 
developments, product, labour and financial 
market integration – gives an important indication 
of a Member State's ability to integrate into the 
euro area without difficulties. 
In November 2021, the Commission published its 
eleventh Alert Mechanism Report (AMR 2022) 
under the Macroeconomic Imbalance Procedure 
(MIP - see also Box 1.7), which concluded that an 
In-Depth Review (IDR) was warranted for 
Romania. In May 2022, the Commission published 
its annual country report on Romania and 
separately an In-Depth Review. These reports 
confirmed the existence of macroeconomic 
imbalances in Romania. Vulnerabilities relate to 
external accounts, linked to large fiscal deficits, 
and to competitiveness issues that are re-emerging. 
The high current account deficit further worsened 
in 2021 and is not forecast to improve in 2022 or 
2023. Large fiscal deficits pre-date the COVID-19 
crisis and have driven up the current account 
deficit which poses risks to external debt 
sustainability. Sovereign borrowing costs have 
increased since early 2021. The expected 
acceleration in wages could weigh further on cost 
competitiveness. Nominal depreciation could 
mitigate competitiveness losses but add to 
inflationary pressures and increase the burden of 
serving debts in foreign currencies, which are 
significant for the government and the private 
sector. The negative net international investment 
position is expected to remain below its
prepandemic levels. The external position is expected 
to benefit from significant RRF funds but external 
financing can otherwise become more challenging 
amid tighter global financial conditions. Recent 
policy initiatives, including the successful 
implementation of Romania’s RRP, can address 
some vulnerabilities, still further action is needed 
to improve competitiveness and potential growth.   
Romania submitted its recovery and resilience plan 
(RRP) on 31 May 2021. The Commission’s 
positive assessment on 27 September 2021 and the 
Council’s approval on 29 October 2021 paved the 
way for the implementation of the RRP and the 
disbursement of EUR 14.25 billion in grants and 
-2
0
2
4
6
8
2016 2017 2018 2019 2020 2021
Romania Germany
Graph 7.8: Romania - Long-term interest rates
(percent, monthly values)
Source: Eurostat.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 170 –
Convergence Report 2022 - Technical annex 
Chapter 7 - Romania 
155 
14.97 billion in loans over the period 2021-2026, 
which is equivalent to 13.1% in 2019 GDP. 
Romania’s plan includes an extensive set of 
mutually reinforcing reforms and investments (107 
investments and 64 reforms) that should contribute 
to effectively addressing all or a significant subset 
of the economic and social challenges outlined in 
the country-specific recommendations (CSRs) 
addressed to Romania by the Council in the 
European Semester in 2019 and 2020. The plan 
will address key macro-economic challenges such 
as the sustainability of public finances, education, 
increasing greenhouse gas emissions and the lack 
of digital connectivity. Key investments are 
included for railway modernisation, the energy 
efficiency of buildings, the digitalisation of public 
administration and making the health system more 
resilient. Investments will also focus on increasing 
the quality and access to education, including 
digitalisation and overall infrastructure. Key 
reforms aim at addressing fiscal sustainability, 
improving access to financing, strengthening the 
public administration and modernising the social 
benefits system. By strengthening the 
independence and increasing the efficiency of the 
judiciary, improving access to justice, and stepping 
up the fight against corruption, the plan aims to 
address the main issues related to respect of the 
rule of law in Romania in accordance with the 
relevant case-law of the Court of Justice of the 
European Union and taking into account 
recommendations made in the Cooperation and 
Verification Mechanism (CVM) reports, the 
reports by the Group of States against Corruption 
(GRECO), the opinions of the Venice 
Commission, and the Rule of Law Reports. 
The plan devotes 41% of its total allocation to 
measures supporting climate objectives, 20.5% to 
the digital transition and 25% on social 
expenditure, all while respecting the ‘do no 
significant harm’ principle. 
The implementation of the investments in the 
Romanian plan, along with other investments 
under Next Generation EU (NGEU), is estimated 
to raise Romania’s GDP by 2.9% by 2026, of 
which 0.2% due to the positive spillover effects of 
the coordinated implementation of NGEU across 
Member States (126). This does not take into 
(126) See Pfeiffer P., Varga J. and in ’t Veld J. (2021),
“Quantifying Spillovers of NGEU investment”, European
Economy Discussion Papers, No. 144 and Afman et al. 
(2021), “An overview of the economics of the Recovery
Table 7.4:
Romania - Balance of payments (percentage of GDP)
2016 2017 2018 2019 2020 2021
Current account -1.6 -3.1 -4.6 -4.9 -5.0 -7.0
of which: Balance of trade in goods -5.7 -6.8 -7.5 -8.0 -8.7 -9.6
Balance of trade in services 4.6 4.4 4.1 3.9 4.3 4.0
Primary income balance -1.3 -1.4 -1.8 -1.4 -1.5 -1.7
Secondary income balance 0.8 0.8 0.6 0.7 0.9 0.4
Capital account 2.5 1.2 1.2 1.3 1.9 2.2
External balance 1) 0.9 -1.9 -3.4 -3.6 -3.1 -4.8
Financial account 1.6 -1.7 -2.5 -2.3 -3.6 -5.4
of which: Direct investment -2.7 -2.6 -2.4 -2.2 -1.4 -3.0
Portfolio investment -0.6 -1.6 -1.4 -1.1 -6.1 -1.3
                Other investment 2) 3.5 2.3 1.7 1.1 1.3 -2.0
Change in reserves 1.3 0.2 -0.4 -0.1 2.6 0.9
Financial account without reserves 0.2 -1.9 -2.1 -2.2 -6.1 -6.3
Errors and omissions 0.6 0.3 0.9 1.3 -0.5 -0.6
Gross capital formation 23.4 23.4 22.8 23.6 24.4 25.9
Gross saving 22.2 20.3 18.3 18.4 18.6 18.9
Net international investment position -49.2 -47.4 -43.8 -43.6 -47.9 -45.7
1) The combined current and capital account.
2) Including financial derivatives.
Sources: Eurostat, European Commission calculations, National Bank of Romania.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 171 –
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account the positive impact of structural reforms 
on growth. 
7.6.1. Developments of the balance of 
payments 
Romania's external balance (i.e. the combined 
current and capital account) improved from -3.6% 
of GDP in 2019 to -3.1% in 2020, before 
deteriorating to -4.8% in 2021. In 2021, the capital 
account remained in surplus and actually 
increased, but this was more than offset by the 
worsening of the current account deficit, which 
increased from -5.0% of GDP in 2020 to -7.0% of 
GDP in 2021. 
Despite growth in export market shares in 2021, 
the growth of imports spurred by booming private 
consumption has outpaced that of exports. The 
balance of trade in goods deteriorated markedly, 
particularly in 2020 and 2021 when it reached -
8.7% of GDP and -9.6%, respectively. The balance 
of trade in services, driven mainly by exports of 
transportation and IT services, remained positive at 
4.3% of GDP in 2020 and 4.0% in 2021, but did 
not offset the negative and widening deficit in the 
trade in goods. 
The balance of primary income remained negative, 
slightly more so in 2020 compared to 2019, 
reflecting mainly the outflow of investment 
income linked to the country's negative net 
international investment position. The balance of 
secondary income, which consists mainly of 
remittances, continues to be positive, with a slight 
increase in 2020. The latter was outweighed 
however by the negative balance of primary 
income. The capital account surplus stood at 1.9% 
of GDP in 2020, an improvement compared to 
2019, reflecting the slight increase in 2020 of the 
uptake of projects financed by EU funds under the 
2014-2020 programming period. In 2021, the 
capital account surplus benefited from the positive 
impact of the RRP pre-financing flows received at 
the end of the year, thus increasing slightly to 
2.2% of GDP. 
Net FDI inflows took a hit in 2020 due to the 
COVID crisis, and the net portfolio inflows 
accounted for the largest contribution to the 
external financing of the current account. Over 
2020, net FDI inflows amounted to 1.3% of GDP, 
while the portfolio investments represented 6.1%. 
and Resilience Facility”, Quarterly Report on the Euro 
Area (QREA), Vol. 20, No. 3 pp. 7-16.   
In 2021, however, the mix between the two 
sources of financing reversed again, with FDI 
amounting to 3.0% of GDP and portfolio 
investments 1.3%. Other investments including 
financial derivatives continued to record net 
outflows. Against the background of a slight 
widening current account deficit in 2020 and due 
to a denominator effect, Romania's net 
international investment position as a share of 
GDP deteriorated by more the 4 percentage points. 
In 2021, however, and despite the larger current 
account deficit, the net international investment 
position (NIIP) marginally improved due to the 
denominator effect of a high GDP growth rate. It 
rose from -47.8% of GDP in 2020 to -45.7% in 
2021.  
Romania’s external cost competitiveness, as 
measured by ULC-deflated real effective exchange 
rate (REER), plateaued and even recorded periods 
of improvement between 2020 and 2021, after a 
span of rapid deterioration from 2016 to 2019 (127). 
This came as a result of a toning down of wage 
pressures, as public sector wages were frozen and 
the private sector suffered reductions in earnings in 
the context of the pandemic. At the same time, the 
HICP-based REER indicates broadly stable 
external price competitiveness, although 
maintaining a spread with respect to the nominal 
effective exchange rate, reflecting Romania’s 
positive inflation differential relative to its trading 
partners broadly offsetting the gain in 
competitiveness from the moderate nominal RON 
depreciation. 
According to the Commission’s Spring 2022 
Economic Forecast, the external deficit is expected 
to widen in 2022, mainly due to price increase for 
(127) The REER based on unit labour costs should be interpreted
with prudence as unit labour costs were distorted by labour
retention schemes in some countries, including Romania. 
90
100
110
120
130
2016 2017 2018 2019 2020 2021
Graph 7.9: Romania - Effective exchange rates
NEER REER, HICP deflated REER, ULC deflated
(vs. 36 trading partners;  monthly averages;
index numbers, 2016 = 100)
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 172 –
Convergence Report 2022 - Technical annex 
Chapter 7 - Romania 
157 
energy commodities, such as gas and oil, for which 
Romania is a net importer. These negative 
dynamics are set to be partially offset by  
dynamics in the capital account, as the RRP funds 
will start flowing in.  
7.6.2. Market integration 
Romania's economy is well integrated with the 
euro area through both trade, including through 
participation in supply chains, and foreign 
investment. The relatively low trade openness (see 
Table 7.5 for a definition) of Romania decreased 
further in 2020, reflecting the domestic and global 
contraction in demand due to the COVID-19 crisis. 
Trade openness in 2020 stood at 41.1% of GDP 
and increased in 2021 to around 45% of GDP. In 
2021, Romania's main trading partners within the 
euro area were Germany, Italy and France, while 
outside the euro area Romania mainly traded with 
Hungary, Poland, China and Turkey. Trade with 
the euro area increased from 23% of GDP in 2020 
to 24.6% of GDP in 2021.  
Romania attracted substantial amounts of FDI in 
the past decade. Net FDI inflows, originating 
mainly from euro-area Member States, such as the 
Netherlands, Germany and Austria, decreased 
markedly by close to 40% in 2020, but made a 
strong comeback in 2021, recording an increase of 
almost 150%.  
Romania’s regulatory framework has scope for 
improvements. The use of Government Emergency 
Ordinances (GEOs) - for which there is neither 
mandatory ex-ante impact assessment nor public 
consultations - is still widespread: their number 
increased from 91 in 2019 to 226 in 2020 (also due 
to the extraordinary measures that had to be taken 
against the pandemic) and decreased to 145 in 
2021. Frequent legislative changes coupled with 
inadequate impact assessments harm investments 
and the business environment. The recovery and 
resilience plan foresees measures enhancing the 
capacity of the central government to better steer 
and monitor the legislative process, the quality of 
the laws, as well as coherence and transparency 
throughout the regulatory framework. 
Romania’s performance in international rankings 
of competitiveness and ease of doing business is 
relatively weak compared to many euro-area 
Member States. In the IMD’s World 
Competitiveness Index, Romania's position is still 
low although it has slightly improved lately, 
moving from a placing of 51 in 2020 to 48 in 2021 
from a total of 64 surveyed economies. A patchy 
legal and regulatory framework, an inefficient 
justice system and at times opaque corporate 
governance of State Owned Enterprises are some 
of the main obstacles to competitiveness. 
According to the World Bank's Ease of Doing 
Business indicator, Romania maintained the same 
rank in 2020, as in 2019, i.e. 55, but a relative 
worsening can be noticed with respect to 2018, 
when it ranked 52 (128). According to the World 
Bank's Worldwide Governance Indicators (2020), 
Romania ranks low in voice and accountability, 
government effectiveness, regulatory quality and 
control of corruption compared with the average of 
                                                          
(128) The World Bank Doing Business (DB) program was 
paused in 2021. The programme will continue with a new 
governance and improved accountability and transparency 
under the name Business Enabling Environment (BEE). 
The first edition of the BEE is expected in 2023. 
 
 
   
 
 
Table 7.5:
Romania - Market integration
2016 2017 2018 2019 2020 2021
Trade openness 1) (%) 45.4 46.4 46.5 45.0 41.1 45.0
Trade with EA in goods &amp; services 2)+3) (%) 25.7 26.2 26.3 25.1 23.0 24.6
World Bank's Ease of Doing Business Index rankings 4) 36 45 52 55 55 -
IMD World Competitiveness Ranking 5) 49 50 49 49 51 48
Internal Market Transposition Deficit 6) (%) 2.0 1.5 1.1 1.1 1.1 -
Real house price index 7) 105.2 108.6 110.5 108.4 110.8 109.6
 1) (Imports + Exports of goods and services / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics, Balance of Payments).
 2) (Imports + Exports of goods with EA-19 / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics).
 3) Trade in services with EA-19 (average credit and debit in % of GDP at current prices) (Balance of Payments).
 4) Data not available for 2021. The Ease of Doing Business report by the World Bank was discontinued in September 2021. 
 5) International Institute for Management Development (IMD).
 6) Percentage of internal market directives not yet communicated as having been transposed, relative to the total.
    (November data, as of 2016 date refers to the year of publication).
 7) Deflated house price index (2015=100) (Eurostat). 
Sources: Eurostat, World Bank, International Institute for Management Development, European Commission calculations.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 173 – 
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the five euro area Member States with the lowest 
scores. Romania ranks higher than the average five 
lowest euro area Member States for political 
stability and absence of violence (129). On a more 
positive note, according to the 2020 Single Market 
Scoreboard, Romania's transposition deficit of EU 
Directives was at 1.1%, a stable result for the 3rd 
consecutive year, very close to the EU average 
(1%) and the target (0.5%) proposed by the 
European Commission in the Single Market Act 
(2011). 
As part of the 2022 Country Report, the 
Commission has identified four main obstacles 
undermining Romania’s competitiveness and 
capacity to innovate. First, services markets, in 
particular many professions servicing companies 
(such as lawyers, accountants and notaries) remain 
highly regulated. This may translate into high 
prices for low quality services. Second, the 
fragmented coordination of Research and 
Development and Innovation policy at the central 
level and weak linkages between science and 
industry discourage entrepreneurship and catching 
up. Third, the cadastre is underdeveloped and can 
result in insufficient protection of property rights. 
Finally, access to credit especially for SMEs and 
start-ups remains problematic, both because of 
companies’ weak balance sheets and relatively 
underdeveloped capital markets.  
The 2022 Country Report highlights that some 
concerns remain on the rule of law. In particular, 
the justice system is facing efficiency challenges, 
and there are concerns about judicial 
independence. This reflects on lengthy 
administrative proceedings and low clearance 
rates, and a relatively low trust in courts. 
Furthermore, frequent changes in legislation 
(129) A Member State is considered to have a ‘low’ (‘high’)
ranking compared with the average five euro area Member
States with the lowest scores for each indicator if its score 
is at least 0.3 percentage points lower (higher) than that of
the average of this euro area group. 
undermine the protection of companies’ 
investments by the law and courts. The RRP aims 
to address these issues by increasing the 
independence and efficiency of the justice system, 
and the quality of legislative process. 
The 4th Anti-Money Laundering Directive (AML) 
imposed transposition by 26 June 2017. After 
being referred before the Court of Justice for not 
having notified any transposition measures on July 
2018 (Case C-2018/549), Romania has 
communicated to the Commission the adoption of 
transposition measures, which ensure a complete 
transposition of the Directive. An assessment of 
the concrete implementation and effective 
application of the 4th Anti money Laundering 
Directive in Romania is at present ongoing. 
As regards the 5th Anti-Money Laundering 
Directive, whose transposition deadline elapsed on 
10 January 2020, a letter of formal notice from the 
Commission was sent in February 2020 regarding 
the absence of notification of national transposition 
measures by the expected date. Since then, further 
transposition measures have been notified, 
enabling the Commission to conclude that 
transposition is now complete. As regards the 
conformity of this transposition, a letter of formal 
notice was sent on 18 February 2021 concerning 
the transposition of the provisions related to 
beneficial ownership registers (Articles 30(1) and 
30(3) AMLD5). Romania formally responded on 
18 June 2021. The Commission is currently 
analysing this reply and the formal follow-up to be 
proposed. At the same time, the Commission is 
assessing whether there are any potential 
conformity issues regarding the other provisions of 
the 5th AML Directive or effectiveness issues in 
the transposition or implementation of the entire 
legal act. 
The Romanian labour market continues to face 
significant structural challenges. Adverse 
demographics are expected to worsen. Aging 
population, limited internal labour mobility and 
continued emigration are a drag on potential 
economic growth. Despite recent improvements, 
employment and activity rates remain below EU 
averages. Skills shortages and mismatches also 
continue to affect the labour market. Although the 
latest minimum wage increases in 2020, 2021 and 
2022 were based on several economic indicators, 
an objective mechanism has not yet been properly 
established. The Romanian recovery and resilience 
plan contains a reform setting a new mechanism 
-0.5
0.0
0.5
1.0
1.5
Voice and Accountability
Political Stability and Absence of
Violence/Terrorism
Government Effectiveness
Regulatory Quality
Rule of Law
Control of Corruption
Romania Euro area average five lowest Euro area average
Graph 7.10: Romania - 2020 World Bank's Worldwide Governance Indicators
Note: Estimate of governance ranges from -2.5 (weak) to 2.5 (strong). 
Source: World Bank.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 174 –
Convergence Report 2022 - Technical annex
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159 
for determining the minimum wage, based on 
objective criteria, consistent with job creation and 
competitiveness. The functioning of social 
dialogue remains weak and social partners' 
involvement in policymaking continues to be very 
limited. 
The financial sector in Romania is smaller and less 
developed than in the euro area. Relative to GDP, 
assets managed by the financial sector are around 
12% of that of the euro area. The size of the 
financial sector has remained broadly unchanged 
since 2016. Banking dominates the Romanian 
financial sector and makes up around 56% of the 
financial sector’s assets in 2020. The central bank 
is the second largest holder of financial assets with 
a share of 21%. Although these shares are larger 
than in the euro area, they are relatively similar to 
those of the five euro-area Member States with the 
smallest financial sectors. Non-money-market 
funds and other financial intermediaries hold a 
small share of total financial assets. 
The insurance and the pension-fund sector in 
Romania is much smaller than in the euro area, 
relative to GDP. However, the sector’s share of the 
total financial sector assets, at around 10%, is only 
slightly less than in the euro area (13%) and 
comparable with the five euro-area Member States 
with the smallest financial sectors. Since end-2016, 
the Romanian sector has increased its holdings of 
financial assets relative to GDP by 2.7 percentage 
points, compared to an increase by 12.3 percentage 
points in the euro area. The investment-funds 
sector plays a very small role in the Romanian 
financial system, but its size relative to GDP is 
comparable to that of the five euro-area Member 
States with the smallest financial sectors. 
As to the financing of the economy, Romania has 
less developed credit and equity markets relative to 
GDP than countries in the euro area, and market 
financing (debt securities and listed shares) is 
relatively underdeveloped. However, Romania is 
still comparable to the five euro-area Member 
States with the smallest financial sectors. Loans 
are the dominant source of funding and make up 
60% of GDP in 2020, compared to 240% of GDP 
in the euro area. Trade credits and advances are 
another important source of funding and stand at 
41% of GDP in 2020, compared to 35% in the euro 
area. Financing through private debt markets is 
practically inexistent, while equity markets are 
very small compared to those of the euro area and 
represent 9% of GDP. This compares to 83% for 
private-sector debt and 73% for listed stocks in the 
euro area. Government debt is also lower than in 
the euro area. In terms of the share of the sum of 
liabilities, loans in Romania are comparable to that 
of the euro area, while the government debt and 
trade credits and advances are higher than in the 
euro area. For security and equity financing, the 
large differences reflect the smaller share of 
market funding available in Romania compared to 
the euro area. 
Romania’s banking sector is well integrated with 
the euro area financial sector, in particular through 
a high level of foreign ownership in its banking 
system. Foreign-owned banks, the majority of 
which are subsidiaries of parent banks based in the 
euro area, had a share of assets in the total held by 
the Romanian banking sector of 58.9% in 2020, 
well above the euro area average of nearly 16%. 
Bank concentration, as measured by the market 
share of the five largest credit institutions in total 
assets, has increased since 2016, and reached 
almost 62% in 2020. This is 9 percentage points 
above the euro area average in 2020. 
Table 7.6:
Romania - Allocation of assets by financial sub-sector
Ratio to GDP (%)
RO EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Financial corporations (total) 97 97 722 796 177 215
Central bank 23 21 45 78 37 61
Monetary financial institutions 54 54 286 311 97 98
Other financial intermediaries 7 8 202 179 20 28
Non-MMF investment funds1) 6 4 100 127 4 5
Insurance co. and Pension Funds 7 10 90 102 18 23
Share of total (%)
RO EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Central bank 24 21 6 10 21 29
Monetary financial institutions 56 56 40 39 55 46
Other financial intermediaries 7 8 28 22 11 12
Non-MMF investment funds 6 4 14 16 2 2
Insurance co. and Pension Funds 7 10 12 13 10 11
1) MMF stands for money market funds.
Source: Eurostat.
Table 7.7:
Romania - Financing of the economy1)
Ratio to GDP (%)
RO EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Liabilities (total) 204 220 743 770 324 335
Loans 68 60 238 236 115 112
Non-financial co. debt securities 0 0 12 15 3 4
Financial co. debt securities 0 0 74 68 11 12
Government debt securities 31 44 83 95 51 57
Listed shares 9 9 65 73 17 18
Unlisted shares 30 29 186 193 55 56
Other equity 27 37 51 56 42 48
Trade credits and advances 39 41 33 35 29 29
Share of total (%)
RO EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Loans 33 27 32 31 35 33
Non-financial co. debt securities 0 0 2 2 1 1
Financial co. debt securities 0 0 10 9 3 3
Government debt securities 15 20 11 12 16 17
Listed shares 4 4 9 9 5 5
Unlisted shares 15 13 25 25 18 18
Other equity 13 17 7 7 13 14
Trade credits and advances 19 19 4 5 9 9
1) The table focuses on the financing needs of a country and how these are met by the financial system.
 The table is constructed from the liabilities of all economic sectors, but only considers loans, debt securities, 
equity and trade credits. The sum of liabilities in the table only reflects the total for the liabilities considered.
Source: Eurostat.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 175 –
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160 
Although intra-EU integration in equity and debt 
markets, as measured by the home bias in portfolio 
investments, are in general relatively low across 
EU Member States, Romania has levels of 
integration in debt markets below that of the 
average euro-area Member State (130). However, 
integration in this market segment has improved 
between 2016 and 2020. Concerning portfolio 
investments in equity, the home bias is also 
significantly stronger in Romania relative to
euroarea Member States. The very large home bias 
indicates that almost all investments in equity 
markets take place domestically. 
(130) Home bias in portfolio investments measures the average
propensity of investors in a Member State to invest
domestically as compared with investing in other EU
countries. The indicator ranges between 0 and 1, with a
value of 0 indicating that investors prefer domestic over
foreign assets. The inverse of the home bias can be
interpreted as one measure of financial integration among
EU countries.
0
20
40
60
80
RO, 2016 RO, 2020 EA, 2016 EA, 2020
Concentration in the banking sector (CR5 ratio)
Share of foreign institutions as % of total assets
Graph 7.11: Romania - Foreign ownership and concentration 
in the banking sector
(in percent, weighted averages)
Source: ECB, Structural financial indicators. 
0.0
0.2
0.4
RO, 2016 RO, 2020 EA, 2016 EA, 2020 EA Low,
2016
EA Low,
2020
Debt Equity
Graph 7.12: Romania - Intra-EU integration in equity and debt portfolio 
investment
Note: The chart shows the extent of home bias in debt and equity markets. A value index 
of 1 implies ‘full integration’ with the financial markets of other Member States, while 0 
denotes ‘no integration’.
Source: FinFlows database: European Commission, Joint Research Centre (JRC). 
(index)
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 176 –
8. SWEDEN
161 
8.1. LEGAL COMPATIBILITY 
8.1.1. Introduction 
The legal rules governing the Swedish Central 
Bank (Riksbank) are laid down in the Instrument 
of Government (as part of the Swedish 
Constitution), the Riksbank Act from 1988, as 
amended, and the Law on Exchange Rate Policy 
from 1998. No amendments to these legal acts 
were passed with regard to the incompatibilities 
and the imperfections mentioned in the 
Commission’s 2020 Convergence Report. 
Therefore, this year’s assessment repeats the 
comments provided in the previous report. 
8.1.2. Central Bank independence 
Article 3 of Chapter 6 of the Riksbank Act obliges 
the Riksbank to inform the minister appointed by 
the Swedish Government about a monetary policy 
decision of major importance prior to its approval 
by the Riksbank. A dialogue between a central 
bank and third parties is not prohibited as such, but 
regular upfront information of government 
representatives about monetary policy decisions, 
especially when the Riksbank would consider them 
as of major importance, could structurally offer to 
the government an incentive and the possibility to 
influence the Riksbank when taking key decisions. 
Therefore, the obligation to inform the minister 
about a monetary policy decision of major 
importance prior to its approval by the Riksbank 
limits the possibility for the Riksbank to take 
decisions independently and offers the possibility 
for the Government to seek to influence them. 
Such procedure is incompatible with the 
prohibition on giving instructions to the Central 
Bank, pursuant to Article 130 of the TFEU and 
Article 7 of the ESCB/ECB Statute. Article 3 of 
Chapter 6 should be revised in order to ensure that 
monetary policy decisions of major importance are 
communicated to the minister, if ever, only after its 
approval by the Riksbank and for information 
purposes only. 
Pursuant to Article 2 of Chapter 3 of the Riksbank 
Act and Article 13 of Chapter 9 of the Instrument 
of Government, the prohibition on the members of 
the Executive Board to seek or take instructions 
only covers monetary policy issues. The provisions 
do not provide for their independence in the 
performance of ESCB-related tasks directly 
entrusted by the Treaties. By means of broad 
interpretation through reference to the explanatory 
memorandum to the Law (the memorandum 
extends the coverage to all ESCB tasks), one could 
consider these tasks as tacitly encompassed by the 
principle of central bank independence. However, 
the principle of the Riksbank's institutional 
independence cannot be considered as fully 
respected as long as the legal text itself does not 
contain a clear reference to them. Both provisions, 
therefore, are considered as incompatible with 
Article 130 of the TFEU and Article 7 of the 
ESCB/ECB Statute. 
Pursuant to Article 4 of Chapter 10 of the 
Riksbank Act, the Swedish Parliament approves 
the Central Bank's profit and loss account and its 
balance sheet and determines the allocation of the 
Central Bank's profit. This practice impinges on 
the financial independence of the Riksbank and is 
incompatible with Article 130 of the TFEU. The 
Parliament must not be involved in the relevant 
decision-making process. Its right should be 
limited to approving the Central Bank's decision 
on the profit allocation. (131) 
Article 4 of Chapter 1 of the Riksbank Act 
provides for the replacement of the Governor, in 
case of absence or incapacity, by the Vice-
Governors nominated by the General Council. It is 
unclear whether the notion "absence" in Article 4 
also refers to cases such as the expiry of the term 
of office, resignation, dismissal or other cause of 
termination of office. To ensure the smooth and 
continuous functioning of the Riksbank, the 
Riksbank Act would benefit from some 
improvement and should provide for clear 
procedures and rules regarding the succession of 
the Governor in case the notion ’absence’ also 
refers to instances of termination of office as well 
as in case the Governor is incapacitated. 
(131) Legislative proposals to tackle the flaw have been
submitted by the Swedish legislator since 2013 but those
still provided for a decisive role of the Parliament in profit
distribution and budget allocation, which are incompatible
with the principle of financial independence as enshrined in 
Article 130 of the TFEU.
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Convergence Report 2022 
162 
8.1.3. Prohibition of monetary financing and 
privileged access 
Under Article 8 of Chapter 6 of the Riksbank Act, 
the Riksbank may, in exceptional circumstances, 
grant credits or provide guarantees on special 
terms to banking institutions and Swedish 
companies that are under the supervision of the 
Financial Services Authority. In order to comply 
with the prohibition on monetary financing of 
Article 123 of the TFEU it should be clearly 
specified that the loan is granted against adequate 
collateral to ensure that the Riksbank would not 
suffer any loss in case of the debtor's default. 
When the Swedish Parliament inserted a new 
article 8a in Chapter 6 of the Riksbank Act 
obliging the Riksbank to provide information to 
the Government and a number of relevant public 
authorities on implemented liquidity support, the 
occasion was not seized to amend Article 8 as 
suggested above. Therefore, it continues to 
constitute an incompatibility with the prohibition 
on monetary financing under Article 123 of the 
TFEU. 
Pursuant to Article 1(3) of Chapter 8 of the 
Riksbank Act, the Riksbank shall not extend 
credits or purchase debt instruments ’directly from 
the State, another public body or institution of the 
European Union’. The Article does not enumerate 
the entities covered by the prohibition of monetary 
financing correctly. Therefore, Article 1 is 
incompatible with the wording of Article 123(1) of 
the TFEU and 21(1) of the ESCB/ECB Statute. 
According to Article 1(4) of Chapter 8 of the 
Riksbank Act, the Riksbank may grant credit to 
and purchase debt instruments from financial 
institutions owned by the State or another public 
body. This provision of Article 1 does not fully 
comply with Article 123(2) of the TFEU and 
Article 21.3 of the ESCB/ECB Statute because the 
exemption only covers publicly owned institutions. 
For the sake of legal certainty, it should be added 
that, in the context of the supply of reserves by 
central banks, these publicly owned credit 
institutions should be given the same treatment as 
private credit institutions. 
The provisions of Article 4 of Chapter 10 on the 
allocation of the Riksbank’s profit are 
supplemented by non-statutory guidelines on profit 
distribution, according to which the Riksbank 
should pay 80% of its profit to the Swedish State, 
after adjustment for exchange rate and gold 
valuation effects and based on a five-year average, 
with the remaining 20% used to increase its 
contingency and balancing funds. Although these 
guidelines are not legally binding but accepted as a 
practice by Parliament for calculating profit 
allocation and as there is no statutory provision 
limiting the amount of profit that may be paid out, 
such practice could constitute an incompatibility 
with the principle on the prohibition of monetary 
financing under Article 123 of the TFEU. The law 
should ensure that the reserve capital of Riksbank 
is left unaffected in any case and that the actual 
contribution to the State budget does not exceed 
the amount of the net distributable profit. 
8.1.4. Integration in the ESCB 
Objectives 
Chapter 1, Article 2 of the Riksbank Act should 
include a reference to the secondary objective of 
the ESCB, while the promotion of a safe and 
efficient payment system as a task should be 
subordinated to the primary and secondary 
objectives of the ESCB. 
Tasks 
The incompatibilities of the Riksbank Act with 
regard to the ESCB/ECB tasks are as follows: 
• absence of a general reference to the Riksbank
as an integral part of the ESCB and to its
subordination to the ECB’s legal acts (Chapter
1, Articles 1 and 2 of the Act and Chapter 9,
Article 13 of the Instrument of Government);
• definition of monetary policy and monetary
functions, operations and instruments of the
ESCB (Chapter 1, Article 2 and Chapter 6,
Articles 2, 3 and 5 and 6, Chapter 11, Article 1
and 2a of the Act; Chapter 9, Article 13 of the
Instrument of Government);
• conduct of foreign exchange operations and the
definition of foreign exchange policy (Chapter
7 of the Act; Chapter 8, Article13 and Chapter
9, Article 12 of the Instrument of Government);
Articles 1 to 4 of the Law on Exchange Rate
Policy of 1998;
• right to authorise the issue of banknotes and the
volume of coins and definition of the monetary
unit (Chapter 5 of the Act; Chapter 9, Article
14 of the Instrument of Government);
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 178 –
Convergence Report 2022 - Technical annex 
Chapter 8 - Sweden 
163 
• ECB's right to impose sanctions (Chapter 11, 
Articles 2a, 3 and 5 of the Act). 
There are furthermore some imperfections 
regarding the: 
• non-recognition of the role of the ECB and of 
the EU in the collection of statistics (Chapter 6, 
Articles 4(2) and Article 9, 10 and 11 of the 
Act); 
• non-recognition of the role of the ECB in the 
functioning of payment systems (Chapter 1, 
Article 2; Chapter 6, Article 7 of the Act); 
• non-recognition of the role of the ECB and of 
the Council in the appointment of an external 
auditor; 
• non-recognition of the role of the ECB in the 
field of international cooperation (Chapter 7, 
Article 6). 
8.1.5. Assessment of compatibility 
As regards the prohibition on monetary financing, 
the independence of the Riksbank as well as its 
integration into the ESCB at the time of euro 
adoption, the legislation in Sweden, in particular 
the Riksbank Act and the Instrument of 
Government as part of the Swedish Constitution, is 
not fully compatible with the compliance duty 
under Article 131 of the TFEU. 
The Swedish authorities are invited to remedy the 
abovementioned incompatibilities. 
8.2. PRICE STABILITY 
8.2.1. Respect of the reference value 
The twelve-month average inflation rate, which is 
used for the convergence assessment, was below 
the reference value at the time of the last 
convergence assessment of Sweden in 2020. The 
twelve-month average inflation rate in Sweden 
then gradually decreased to a low of 0.7% in 
December 2020, after which it increased 
throughout 2021. In April 2022, the reference 
value was 4.9%, calculated as the average of the 
12-month average inflation rates in France, 
Finland and Greece plus 1.5 percentage points. 
The corresponding inflation rate in Sweden was 
3.7%, i.e. below the reference value. The 12-month 
average inflation rate is projected to increase, but 
stay below the reference value in the months 
ahead. 
      
8.2.2. Recent inflation developments 
HICP inflation in Sweden dropped markedly at the 
beginning of 2020 as COVID-19 took hold, driven 
down by declining energy prices and moderating 
services inflation. This resulted in an average 
inflation rate of 0.7% in 2020. In 2021, HICP 
inflation rose to 2.7% on average. The pick-up in 
headline inflation began in early 2021, mainly due 
to the combined impact of markedly higher energy 
prices dominating strong negative base effects for 
unprocessed food prices, while other inflation 
components showed marked volatility. After a few 
months of declining inflation in the middle of 
2021, the inflation rate accelerated from August 
onwards, initially mainly driven by sharply higher 
energy prices — foremost electricity prices. In the 
second half of 2021, price increases broadened 
across various categories of the consumer price 
index, lifting core inflation. In the first part of 
2022 headline HICP inflation picked up, with more 
broadly entrenched price increases for a wide 
range of other goods and services. In April 2022, 
HICP inflation reached 6.6%, the highest rate on 
record since the harmonised consumer price index 
was first published in 1996, on the back of strong 
increases across a wide range of goods and 
services in the consumption basket. 
In 2020 and 2021, core inflation (measured as 
HICP inflation excluding energy and unprocessed 
food) remained relatively subdued at around 1.5%, 
despite pandemic-induced sharp swings in import 
prices and nominal unit labour costs, the latter 
affected by the impact of temporary 
unemployment support schemes. Underlying 
labour costs remained muted on the back of 
0
1
2
3
4
5
6
7
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Sweden Reference value
Graph 8.1: Sweden - Inflation criterion
(percent, 12-month moving average)
Note: The dots at the right end of the chart show the projected reference 
value and 12-month average inflation rate of the country in December 2022.
The reference values for 2016, 2018 and 2020 refer to the reference values 
calculated in the previous Convergence Reports.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 179 – 
European Commission 
Convergence Report 2022 
164 
moderate multi-annual wage agreements, which 
extend, into 2023. Firms absorbed part of the cost 
increases caused by supply chain disruptions in 
their margins, while the rate of increase of 
administered prices fluctuated around 2%, a 
similar rate as before the onset of the pandemic. 
From the second quarter of 2020 to the first quarter 
of 2022, the behaviour of inflation components 
exhibited larger-than-usual volatility, reflecting the 
impact of the pandemic on supply chains, 
consumption patterns (which in turn affected index 
weights) and seasonal patterns. The lagged impact 
of the strengthening of the effective exchange rate 
of the krona during most of 2020 helped achieve a 
moderate increase in prices for non-energy 
industrial goods. In 2020, unprocessed food prices 
registered strong gains as the pandemic started, 
while in 2021 demand for and prices of
contactrelated services received impetus from the easing 
of restrictions. The strong initial downturn and 
subsequent acceleration in energy prices accounted 
for the largest part of the marked swings in HICP 
inflation from 2020 through 2021. These dynamics 
were also a key determinant of the observed 
pattern for import and producer prices. In the first 
months of 2022, inflation rates increased markedly 
to the highest harmonised inflation rate on record, 
with price increases across a broad range of goods 
and services, mirrored in rising core inflation. 
8.2.3. Underlying factors and sustainability of 
inflation 
Macroeconomic policy mix and growth 
developments 
The Swedish economy experienced an 
unprecedented, but relatively short-lived decline in 
real GDP in the immediate wake of the COVID-19 
pandemic, followed by a strong but unevenly 
paced recovery from the third quarter of 2020 
onwards, as the initial recovery was interrupted by 
new COVID waves. Overall, the economy 
contracted by 2.9% in 2020, driven by a 
simultaneous fall in domestic demand and exports, 
as disruptions in global supply chains aggravated 
the initial downturn. Sweden’s real GDP 
rebounded strongly in the second half of 2020 with 
the recovery continuing in 2021, mainly driven by 
strong gains in private consumption and 
investment, while exports also recovered markedly 
and helped lift economic growth. Sweden returned 
to the pre-crisis output level in the second quarter 
of 2021. In the second half of 2021 demand picked 
up for contact-related services such as restaurant 
and hotel services with the lifting of restrictions, 
facilitated by the progress in vaccination. Real 
GDP growth reached 4.8% for the year 2021. The 
slowdown at the beginning of 2022 reflects the 
combined impact of another wave of the pandemic, 
elevated inflation, the war in Ukraine and 
coincident persistent supply chain problems that 
had its roots in the pandemic affecting purchasing 
power, business and consumer confidence. This 
further lifted inflation with negative consequences 
-2
0
2
4
6
8
2016 2017 2018 2019 2020 2021
Sweden Euro area
Graph 8.2: Sweden - HICP inflation
(y-o-y percentage change)
Source: Eurostat.
Table 8.1: weights  
Sweden - Components of inflation (percentage change)1) in total   
2016 2017 2018 2019 2020 2021 Apr-22 2022
HICP 1.1 1.9 2.0 1.7 0.7 2.7 3.7 1000
Non-energy industrial goods 1.1 0.0 0.0 0.3 0.9 1.0 1.4 322
Energy 1.0 5.3 9.6 2.9 -8.8 15.3 22.7 96
Unprocessed food 2.6 2.0 4.5 2.3 2.6 -0.4 2.1 34
Processed food 0.5 2.0 1.8 2.8 1.9 0.9 1.8 163
Services 1.3 2.3 1.8 2.0 1.8 2.5 2.7 385
HICP excl. energy and unproc. food 1.1 1.5 1.2 1.6 1.5 1.6 2.0 870
HICP at constant tax rates 1.0 1.7 1.8 1.6 0.6 2.6 3.7 1000
Administered prices HICP 0.9 2.2 1.3 2.0 2.4 1.7 1.9 160
1) Measured by the arithmetic average of the latest 12 monthly indices relative to the arithmetic average of the 12 monthly indices
in the previous period.
Source: Eurostat, European Commission calculations.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 180 –
Convergence Report 2022 - Technical annex 
Chapter 8 - Sweden 
165 
for household purchasing power and costs to 
businesses. Moreover, it also induced further 
supply bottlenecks and falls in confidence among 
households and businesses. Real GDP growth is 
poised to recover in the course of 2022, as the 
Swedish economy adjusts to the changed global 
environment. However, the pace of expansion, 
would remain comparatively modest in 2023. 
Overall, real GDP is forecast to grow by around 
2¼% in 2022 and 1½% in 2023. 
The fiscal stance turned contractionary in 2020 and 
remained broadly neutral in 2021 (132). It is 
expected to turn expansionary in 2022, due to 
additional expenditure aimed at addressing the 
economic impact of the pandemic, strengthening 
health care, easing some of the consequences of 
higher energy prices, and strengthening the 
military defence. In 2023, the fiscal stance is 
expected to be contractionary. 
                                                          
(132) The fiscal stance is measured as the change in primary 
expenditure (net of discretionary revenue measures), 
excluding Covid-19 crisis-related temporary emergency 
measures but including expenditure financed by
nonrepayable support (grants) from the Recovery and 
Resilience Facility and other EU funds, relative to
mediumterm potential growth. A negative (positive) sign of the 
indicator corresponds to an excess (shortfall) of primary 
expenditure growth compared with medium-term economic 
growth, indicating an expansionary (contractionary) fiscal 
policy. 
Monetary policy, conducted within an inflation 
targeting framework (133), has remained 
expansionary in the period covered by the report. 
The Riksbank raised its main policy rate to 0% in 
January 2020, and has not changed it since. 
However, in response to the COVID crisis, the 
Riksbank cut the interest rate on the standing loan 
facility, which is defined in terms of a deviation 
above the policy rate, i.e. the repo rate plus 0.2 of a 
percentage point to the repo rate plus 0.1 of a 
percentage point. However, at its latest meeting on 
28 April 2022, the Riksbank raised its main policy 
rate, the repo rate, by 25 basis points to 0.25%. 
The Executive Board’s forecast is that the repo rate 
will be raised gradually going forward, and that it 
will be somewhat below 2 % in three year’s time. 
The Riksbank maintained an expansionary policy, 
also in view of its extensive purchases of 
government bonds. In order to limit the impact of 
the COVID-19 crisis, the Riksbank took a series of 
measures in several monetary policy meetings in 
March 2020. These decisions involved: (i) further 
purchases of securities up to SEK 300 billion in 
2020, including government, municipal and 
mortgage bonds; (ii) a first reduction in the lending 
rate for overnight loans to banks from 0.75 to 0.20 
                                                          
(133) Since 1995, the Riksbank has targeted increases in the 
domestic CPI with the aim of keeping inflation at 2%. In 
September 2017, the Riksbank changed its target from 
measuring inflation in terms of CPI to CPIF (CPI with the 
interest rate component kept unchanged). 
 
 
       
 
 
Table 8.2:
Sweden - Other inflation and cost indicators (annual percentage change)
2016 2017 2018 2019 2020 2021 20221) 20231)
HICP inflation
Sweden 1.1 1.9 2.0 1.7 0.7 2.7 5.3 3.0
Euro area 0.2 1.5 1.8 1.2 0.3 2.6 6.1 2.7
Private consumption deflator
Sweden 0.9 1.8 2.5 2.1 1.1 1.9 5.7 4.0
Euro area 0.4 1.3 1.5 1.1 0.5 2.3 5.8 2.7
Nominal compensation per employee
Sweden 2.6 2.1 3.8 3.0 2.5 4.3 2.7 3.7
Euro area 1.2 1.7 2.1 2.1 -0.7 4.1 3.6 3.5
Labour productivity
Sweden 0.2 0.1 0.3 1.4 -1.7 3.5 0.1 0.5
Euro area 0.4 1.0 0.2 0.3 -4.9 4.2 1.4 1.5
Nominal unit labour costs
Sweden 2.4 1.9 3.5 1.5 4.3 0.8 2.6 3.2
Euro area 0.8 0.7 2.0 1.9 4.4 0.0 2.2 2.0
Imports of goods deflator
Sweden -2.2 4.6 6.7 2.3 -5.4 5.1 14.5 5.5
Euro area -3.3 3.3 2.6 -0.5 -3.8 9.6 13.2 0.8
1) Commission Spring 2022 Economic Forecast.
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 181 – 
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Convergence Report 2022 
166 
percentage points above the repo rate; (iii) 
allowing banks to borrow unlimited amounts on a 
weekly basis against collateral at three months’ 
maturity at an interest rate of 0.20 percentage point 
above the repo rate; (iv) purchasing commercial 
paper issued in Swedish kronor by Swedish
nonfinancial corporations; and (v) offering loans in 
dollars thanks to the swap arrangement of up to 60 
billion USD that the Riksbank agreed with the US 
Federal Reserve (134). The Riksbank also increased 
the flexibility of the collateral framework, giving 
banks more scope to use mortgage bonds as 
collateral and subsequently temporarily enlarged 
the circle of monetary policy counterparties. The 
Riksbank extended the framework for asset 
purchases from SEK 300 billion to SEK 500 
billion in July 2020, and again to SEK 700 billion 
in November 2020. The Riksbank's total holdings 
of domestic government bills and bonds amounted 
to a cumulative SEK 415 billion in January 2022, 
more than 40% of the outstanding stock of central 
government debt instruments. The Riksbank also 
held SEK 420 billion of covered bonds, about one 
fifth of the market. However, on 28 April 2022, the 
Executive Board decided to reduce the pace of the 
Riksbank’s asset purchases during the second half 
of 2022, so that the holdings starts to decrease. 
Moreover, the Riksbank ceased purchasing 
treasury bills as of 28 April 2022. 
Wages and labour costs 
In the years before 2019, employment growth had 
been quite strong. However, this did not lead to a 
marked decline in the unemployment rate, due to 
the relatively strong growth of the labour force. 
The initial slump in the labour market after the 
pandemic had started was countered by sizable and 
frontloaded policy support, including support to 
households affected by temporary unemployment 
and to businesses suffering from turnover losses. 
During the recovery from the pandemic, 
employment growth picked up markedly, 
unemployment fell, and the number of vacancies 
rose to all-time highs by the first quarter of 2022 as 
employed shifted away from contact-intensive 
services to other branches of activity. The 
unemployment rate is expected to fall to 7% on 
average in 2023, around the 2019 level. 
The growth in nominal compensation per 
employee stood at close to 3% on average in 2019. 
In Sweden, social partners typically first negotiate 
a benchmark agreement for exporting sectors 
(134) The Riksbank has a standing swap line with the ECB. 
aimed at maintaining cost competitiveness vis-
avis major trading partners; other sectors, including 
services, tend to follow this benchmark rather 
closely. Against the backdrop of the COVID-19 
crisis, social partners deferred the collective 
bargaining round foreseen for the first half of 
2020. With a delay, a new multi-annual wage 
agreement was reached, which extends into 2023 
and provides for relatively moderate overall 
compensation growth. The current collective 
agreements should be a dampening factor for 
underlying inflation in 2022 and into the first 
months of 2023. Notwithstanding this, wage 
demands and wage drift might rise in response to 
the tightening labour market and the sharp increase 
in inflation that started in the second half of 2021, 
and gathered pace in the first months of 2022. 
Overall, the risks of significant second round 
effects of wage increases on inflation appears to be 
contained. 
Sweden had moderate labour productivity growth 
in the years before 2019. In 2020 and 2020, the 
pandemic induced strong swings in economic 
activity while employment was supported by 
temporary unemployment schemes and various 
support schemes. As a result, aggregate measures 
of changes in labour productivity and unit labour 
costs for 2020 and 2021 are distorted. 
External factors 
Given the openness of the Swedish economy, 
developments in import prices traditionally play an 
important role in domestic price formation. Import 
price growth (measured by the deflator of imports 
of goods) has fluctuated markedly over the past 
years. This was chiefly due to large swings in 
energy and other commodity prices, but also 
mirrors the price effects of pandemic-related trade, 
supply and demand disruptions, as well as 
-4
-2
0
2
4
6
8
2016 2017 2018 2019 2020 2021 2022 2023
Productivity (real GDP per person employed)
Nominal compensation per employee
Nominal unit labour costs
HICP inflation
Graph 8.3: Sweden - Inflation, productivity and wage trends
(y-o-y % change)
Source: Eurostat, Commission's Spring 2022 Economic Forecast.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 182 –
Convergence Report 2022 - Technical annex 
Chapter 8 - Sweden 
167 
exchange rate fluctuations. In 2020, the import 
deflator for goods fell sharply by 5.4%, due to 
lower commodity prices. This development was 
reversed in 2021, as import prices grew by 5.1%, 
largely because of energy prices, even though the 
rate of increase stayed below that in the euro area, 
which in turn was partly due to the lagged effect of 
exchange rate appreciation. The impact of changes 
in import prices on consumer price inflation is 
difficult to gauge. There is evidence that the
passthrough had been weakening before the pandemic 
in view of, for instance, changes in competitive 
conditions related to the rise of global value 
chains. However, during the pandemic it became 
very difficult to assess the pass-through of trade 
prices to consumer price inflation, given their high 
volatility and complex interactions with price 
effects of supply chain disruptions, exchange rate 
movements, inventory adjustments, sales 
restrictions, and other pandemic-related factors. 
Nevertheless, the recent marked increase in 
inflation indicates that import prices have been 
among the significant determinants of consumer 
price increases. 
After an initial weakening at the onset of the 
COVID-19 crisis, the real effective exchange rate 
of the krona (measured against a group of 36 
trading partners) strengthened in the course of 
2020, having fallen over a number of previous 
years. The real effective exchange rate then 
slightly weakened in the course of 2021. For both 
years, there were no major discrepancies between 
the growth in domestic prices and the growth in 
domestic prices of Sweden’s main trading partners. 
Likewise, for 2022 and 2023, major discrepancies 
between nominal and real effective exchange rates 
are not expected to occur. Overall, Swedish cost 
developments do not pose major challenges to 
competitiveness. 
Administered prices and taxes 
The share of administered prices in the Swedish 
HICP basket amounts to just above 15%, a value 
more than 2 percentage points above the euro-area 
average. The most important item in the 
administrated price basket is rents. In 2020, at 
2.4%, administered price inflation exceeded 
headline HICP inflation. By contrast, in 2021 
administered price increases were more subdued at 
1.7% and fell appreciably below the overall 
inflation rate. The changes in this component are 
largely accounted for by a marked increase in fully 
administered prices. 
Tax changes contributed only marginally to in 
headline inflation in both 2020 and 2021, as the 
pace at which HICP at constant taxes increased 
over these two years was just below the headline 
number. 
Medium-term prospects 
According to the Commission’s Spring 2022 
Economic Forecast, inflation is set to remain 
elevated in 2022, mirroring broad-based price 
increases across a range of goods and services as 
trade and production bottlenecks persist. Domestic 
wage pressures are projected to remain relatively 
contained over the forecast period, despite the 
sharp increase in headline inflation, and some 
expected rise in compensation growth in 2023, 
reflecting the upcoming round of collective wage 
bargaining. Risks to the labour cost outlook appear 
skewed to the upside. However, the country has a 
long tradition of social partners taking into account 
competiveness in their wage agreements. Overall, 
Sweden should not experience major changes in 
cost competitiveness. However, increases in 
energy and food prices in particular, along with 
broad-based increases in other components of core 
inflation are expected to keep headline inflation at 
a relatively elevated rate. In all, HICP inflation is 
forecast to average 5.3% in 2022 and decrease to 
3% in 2023. Underlying inflation is set to rise 
markedly from 1.6% in 2021 to 4.1% in 2022, 
before decreasing to 3% in 2023 on the back of 
base effects. 
The amending budgets for 2022 contain measures 
to compensate households and, in particular, the 
agricultural sector for increases in energy prices 
(energy tax deductions as well as an electricity 
allowance) amounting to 0.4% of GDP. 
Overall, as of 2023 inflation is expected to meet 
the Riksbank’s target, as the economy is 
normalising, despite some persistence in 
underlying price pressures. Risks to the inflation 
outlook are on the upside, in view of a
strongerthan-expected pass-through of cost increases and 
war-related supply disruptions, possibly coupled 
with higher wage increases due to the tight labour 
market. While it is hard to interpret surveys on 
inflation expectations at this juncture, market 
expectations show a progressive rise of inflation 
above the Riksbank’s target over the medium term. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 183 – 
European Commission 
Convergence Report 2022 
168 
The level of consumer prices in Sweden relative to 
the euro area has increased since Sweden joined 
the EU in 1995. In 2020, the Swedish price level 
stood at 123% of the euro-area average. At the 
same time, the relative real GDP per capita level in 
Sweden has risen since 2019, reaching about 117% 
of the euro-area average in PPS terms in 2021. 
In the medium term, inflation could prove to 
remain relatively high for longer, given the size 
and possible persistence of price and cost pressures 
(also reflecting the energy transition), possible 
persistence of supply constraints, weak 
productivity trends, high vacancy rates, and 
reported skill shortages. However, as resource 
utilisation is expected to abate somewhat over the 
forecast period, there is uncertainty on how 
resource pressures will feed into inflation. In 
particular, if wage expectations would remain 
relatively moderate in their response to upside 
inflation surprises, which has been the case in the 
prevailing wage bargaining system, there is no 
reason to believe that wage increases will add a 
push towards higher inflation. 
8.3. PUBLIC FINANCES 
8.3.1. Recent fiscal developments 
Sweden’s general government balance improved 
from a deficit of 2.7% of GDP in 2020 to a deficit 
of 0.2% of GDP in 2021. The expenditure-to-GDP 
ratio decreased from 52.6% of GDP in 2020 to 
50.2% in 2021, whereas the revenues-to-GDP ratio 
stabilised at around 50% of GDP during the same 
period. This reflected mainly the phasing out of 
several COVID-19 measures during the autumn of 
2021, dominating continued expenditure support in 
some areas, as well as a denominator effect as 
growth rebounded strongly in 2021. 
After an increase of close to 5 percentage points in 
the public debt-to-GDP ratio from 2019 to 2020, 
the debt level resumed its downward path in 2021, 
falling back to 36.7% of GDP, which is lower than 
what it was in 2018. Apart from the impact of an 
improving nominal balance with the recovery in 
economic activity, some of the decrease reflects 
the stepwise debt-reducing repayment of a 
Riksbank loan for foreign currency reserves during 
the 2021-2023 period, equivalent to around 3.5% 
of GDP. 
8.3.2. Medium-term prospects 
The 2022 budget, adopted in November 2021, 
includes new spending and revenue measures 
amounting to around 1.5% of GDP. On the 
expenditure side, it contains measures to 
strengthen social benefits (notably during sick 
leave), increased grants to local governments and 
regions (to cover pandemic-related costs), 
strengthened active labour market policies 
(focused on the young and the long-term 
unemployed), and measures to strengthen law 
enforcement. Significant outlays also stem from 
extended COVID support in the first months of the 
 
 
  
 
 
Table 8.3:
Sweden - Budgetary developments and projections (as % of GDP unless indicated otherwise)
Outturn and forecast 1) 2016 2017 2018 2019 2020 2021 20221) 20231)
General government balance 1.0 1.4 0.8 0.6 -2.7 -0.2 -0.5 0.5
- Total revenue 50.7 50.6 50.7 49.7 49.9 50.0 48.7 47.7
- Total expenditure 49.7 49.2 49.8 49.1 52.6 50.2 49.1 47.2
   of which: 
- Interest expenditure 0.5 0.4 0.5 0.4 0.3 0.2 0.1 0.2
p.m.: Tax burden 44.7 44.7 44.4 43.5 43.6 43.7 42.7 42.2
Primary balance 1.5 1.9 1.3 1.0 -2.4 0.0 -0.3 0.7
Fiscal stance 2) 1.5 0.1 -0.6 1.3
Government gross debt 42.3 40.7 38.9 34.9 39.6 36.7 33.8 30.5
p.m: Real GDP growth (%) 2.1 2.6 2.0 2.0 -2.9 4.8 2.3 1.4
1) Commission’s Spring 2022 Economic Forecast. 
2) A negative (positive) sign of the indicator corresponds to an excess (shortfall) of primary expenditure growth 
compared with medium-term economic growth, indicating an expansionary (contractionary) fiscal policy.
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 184 – 
Convergence Report 2022 - Technical annex 
Chapter 8 - Sweden 
169 
year, including in sick pay. In addition, the 2022 
budget includes spending on green and digital 
items financed by grants from the Recovery and 
Resilience Facility, amounting to 0.2% of GDP. 
On the revenue side, the draft budget entails a 
generalised income tax cut as well as targeted 
reductions for people on sickness and disability 
benefits. Nevertheless, tax receipts are expected to 
hold up, in line with the resilient labour market and 
healthy corporate profitability. 
In addition, the parliament adopted a set of 
amending budgets in the first months of the year. 
Further measures were announced on 19 April 
2022 in the Spring amending budget bill, which 
remains to be adopted. On balance, these 
additional measures amount to an increase in net 
expenditures of close to 1.5% of GDP to address 
the continuing impact of the pandemic, introduce 
extraordinary compensation to households and 
firms for soaring energy prices, cover the costs of 
refugees from Ukraine, and provide for structurally 
higher spending on defence. In all, the general 
government balance is expected to register a small 
deficit of 0.5% of GDP in 2022, in light of the 
planned expenditure increases. 
On 29 April 2022, Sweden submitted its 2022 
Convergence Programme. According to the 
Programme, the headline deficit is projected to 
increase somewhat to 0.5% of GDP in 2022 and 
turn into a surplus of 0.7% of GDP in 2023. The 
government deficit in 2022 is impacted by the 
additional measures taken by the government to 
counter the social and economic impact of the 
pandemic and the increase in energy prices. Based 
on the Commission’s Spring 2022 Economic 
Forecast, the measures to cushion the impact of the 
increase in energy prices are estimated at 0.4% of 
GDP in 2022, which are currently expected to be 
temporary and to be withdrawn in 2023. The 
annual cost of humanitarian assistance is projected 
at 0.1% of GDP in 2022 and 2023. 
The Commission’s Spring 2022 Economic 
Forecast projects the general government deficit to 
reach 0.5% of GDP in 2022 and turn into a surplus 
of 0.5% of GDP in 2023. The projections for 
public finances in the 2022 Convergence 
Programme are thus close to the Commission’s  
Spring 2022 forecast. 
For 2022, the Commission’s Spring 2022 
Economic Forecast projects the fiscal stance to be 
supportive at 0.6% of GDP (135). The Forecast 
projects that expenditures financed by the 
Recovery and Resilience Facility grants and other 
EU funds will contribute positively to economic 
activity at 0.2 of a percentage point of GDP in 
2022, higher by 0.1 of a percentage point of GDP 
compared to 2021. Nationally financed investment 
is projected to provide a neutral contribution to the 
fiscal stance. At the same time, the growth in 
nationally financed primary current expenditure 
(net of new revenue measures) in 2022 is projected 
to provide an expansionary contribution of 0.4 of a 
percentage point of GDP to the overall fiscal 
stance, as current expenditure is set to grow at a 
faster pace than medium-term potential growth. 
However, much of this expansion is due to 
temporary measures to support the economy in 
facing current headwinds.  
        
In 2023, the fiscal stance is projected to turn 
contractionary at 1.3% of GDP. The positive 
contribution to economic activity of expenditure 
financed by Recovery and Resilience Facility 
grants and other EU funds is projected at 0.1 of a 
percentage point of GDP in 2023, reflecting the 
frontloaded financial support from the Recovery 
and Resilience Facility in 2021 and 2022. 
Nationally financed investment is projected to 
provide a slightly contractionary contribution to 
the fiscal stance (136). The growth in nationally 
financed primary current expenditure is projected 
to provide a contractionary GDP contribution to 
the overall fiscal stance in 2023. 
Debt sustainability risks appear low over the 
medium term. Government debt is projected to 
decrease reaching around 11% of GDP in 2032. 
                                                          
(135) For a definition of the fiscal stance used in this report, see 
footnote in Section 8.2.3 on underlying factors and 
sustainability of inflation.  
(136) Other nationally financed capital expenditure is projected 
to provide a neutral GDP contribution. 
-1
0
1
2
2020 2021 2022 2023
Net nationally financed  primary current expenditure Nationally financed investment
Other capital expenditure Expenditure financed by RRF grants and EU funds
Fiscal stance
Expansionary
Contractionary
Graph 8.4: Sweden - Fiscal stance and its components
(percent of GDP)
Source: Commission's Spring 2022 Economic Forecast. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 185 – 
European Commission 
Convergence Report 2022 
170 
This projection assumes that the structural primary 
balance (except for the impact of ageing) remains 
constant at the forecast level for 2023 of 1.3% of 
GDP, which constitutes an improvement compared 
to the 2019 level. 
The low sensitivity to possible macro-fiscal shocks 
also contributes to this assessment. In particular, if 
only half of the projected improvement in the 
structural primary balance in 2022-2023 were to 
occur, the projected debt ratio in 2032 would be 
only some 1 percentage points of GDP higher than 
in the baseline, i.e. still substantially below 60% of 
GDP. 
Some factors mitigate risks, including the stability 
of debt maturity in recent years, relatively stable 
financing sources (with a diversified and large 
investor base), historically low borrowing costs 
reflecting a long-standing strong creditor status, 
Sweden’s positive net international investment 
position and the expected positive impact on
longterm growth of reforms under the Recovery and 
Resilience Plan. Risk-increasing factors include 
the possible materialisation of state guarantees 
granted to firms and self-employed during the 
COVID-19 crisis, though currently this risk 
remains limited due to relatively low take-up (137). 
Building on a strong institutional set-up and a 
robust fiscal track-record, revisions to the fiscal 
framework took effect in 2019. Among the 
novelties, the government introduced a debt 
anchor, set at 35% of GDP with a 5-
percentagepoint tolerance margin, and the net lending target 
was lowered from 1% of GDP over the cycle to 
0.33% of GDP. The expenditure ceiling and the 
balanced budget requirement for local authorities 
were left unchanged. The fulfilment of the net 
lending target will be assessed based on a single 
indicator, the structural balance in the current and 
subsequent year, replacing a system of several 
indicators with undefined weights. The 
government also decided to conduct regular 
reviews of the adequacy of the framework every 
eight years, in the final year of every second 
parliament. Despite the relaxation of the target, the 
authorities still consider there to be an adequate 
safety margin to allow for normal economic 
fluctuations without breaching the 3% of GDP 
deficit benchmark of the Stability and Growth 
Pact. 
                                                          
(137) For further details see the 2021 Fiscal Sustainability 
Report. 
The revisions to the fiscal framework also entailed 
a widened mandate for the Fiscal Policy Council 
(Finanspolitiska rådet), set up in 2007. The 
Council was tasked to evaluate the official 
macroeconomic forecasts and to perform costing 
of reform proposals. It also received the explicit 
task to assess whether there is a deviation from the 
net lending target and, if so, to assess the reasons 
for the deviation, and to propose how fast the 
government should eliminate it. Furthermore, in 
order to increase the diversity of the Council, the 
member selection process was changed. Instead of 
current Council members nominating new 
candidates, this task now resides with a nomination 
committee, which among its members has the 
Chair and Deputy Chair of the parliamentary 
Finance Committee. It is still the government that 
formally appoints the new members. 
Some of the new elements in the fiscal framework 
contribute to bringing the framework in line with 
the Budgetary Frameworks Directive (138), such as 
introducing the debt anchor as an explicit
multiannual debt objective, or mandating the Fiscal 
Council with the regular assessment of the 
government's economic forecasts. 
8.4. EXCHANGE RATE STABILITY 
The Swedish krona does not participate in ERM II. 
As indicated above, the Riksbank pursues inflation 
targeting under a de jure floating exchange rate 
regime. 
    
The long-term trend of the krona depreciating 
against the euro started in 2013 and ended in early 
April 2020, after a cumulated depreciation of more 
                                                          
(138) The Council Directive 2011/85/EU of 8 November 2011 on 
requirements for budgetary frameworks of the Member 
States, available at: https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32011L0085 
8.0
8.5
9.0
9.5
10.0
10.5
11.0
11.5
2016 2017 2018 2019 2020 2021
Graph 8.5: Sweden - SEK/EUR exchange rate
(monthly averages)
Source: ECB.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 186 – 
Convergence Report 2022 - Technical annex 
Chapter 8 - Sweden 
171 
than 30%. With the onset of the COVID-19 crisis, 
the krona first weakened, but then started to 
appreciate, on the back of the resilience of the 
economy, with Sweden implementing less strict 
measures than most euro-area Member States in 
response to the pandemic. Between April 2020 and 
November 2021, the krona appreciated by almost 
8% against the euro, and reached a new peak at 
10.05 SEK/EUR. As the euro-area economy 
recovered, and Member States gradually loosened 
their restrictions, the krona fell back by 3% in 
December 2021 and January 2022. In February and 
March 2022, the krona depreciated by another 
1.8%, as Russia’s invasion of Ukraine spurred 
safe-haven flows. This was followed by a 2.2% 
reversal in April. Volatility in the exchange rate is 
significant, where short-term fluctuations reflect 
changes in risk appetite and short-term funding 
flows, as well as changing perceptions of the 
future direction of monetary policy. 
The 3-month STIBOR-EURIBOR spread has 
remained broadly stable since June 2020. The 
spread averaged 50 basis points in 2020 and 
51 basis points in 2021. Since June 2020, the 
spread has remained in a range of 43-56 basis 
points, without any large swings. Thus, the episode 
of appreciation and subsequent depreciation of the 
Swedish krona between 2020 and early 2022 
cannot be accounted for by changes in the spreads 
on short-term interest rates. 
Since December 2015, the Riksbank can intervene 
on foreign exchange markets in order to prevent a 
de-anchoring of inflation expectations due to a 
strengthening krona. The level of foreign currency 
reserves and gold decreased by almost 9% in krona 
between December 2019 and December 2020 and 
increased by more than 5% between December 
2020 and December 2021, when it stood at around 
SEK 461 billion. At the beginning of 2022, 
international reserves stood just below the level of 
SEK 460 billion, or around 8.5% of GDP. The 
change in 2020 reflects changes in the exchange 
rate and the Riksbank decisions to lower the level 
of foreign exchange reserves, which had increased 
substantially after the global financial crisis. The 
post-crisis increase was financed by loans from the 
Swedish National Debt Office. However, the 
Riksbank has decided to repay the loans and 
instead obtain dollars and euros using Swedish 
krona. 
8.5. LONG-TERM INTEREST RATES 
Long-term interest rates used to assess adherence 
to the convergence criterion reflect secondary 
market yields on a single benchmark government 
bond with a residual maturity of around ten years. 
The Swedish 12-month moving average long-term 
interest rate, relevant for the assessment of the 
Treaty criterion was well below the reference 
value at the time of the 2020 convergence 
assessment of Sweden. The 12-months average 
continued to stay below 1% over the last two 
years, where it has been since June 2015. It 
remained stable during 2020, and the first quarter 
of 2021 at around -0.04%. Since March 2021, the 
12-month average interest rate has edged up into
positive territory and reached 0.3% in January
2022. In April 2022, the latest month for which
data are available, the reference value, given by the
average of long-term interest rates in France,
Finland and Greece plus 2 percentage points, stood
at 2.6%. In that month, the 12-month moving
average of the yield on the Swedish benchmark
bond stood at 0.4%, i.e. 2.2 percentage points
below the reference value.
-40
-20
0
20
40
60
80
2016 2017 2018 2019 2020 2021
Graph 8.6: Sweden - 3-M Stibor spread to 3-M Euribor
(basis points, monthly values)
Source: Eurostat and Thomson Reuters.
-2
0
2
4
6
Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21 Jan-22
Sweden Reference value
Graph 8.7: Sweden - Long-term interest rate criterion
(percent, 12-month moving average)
Source: European Commission.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 187 –
European Commission 
Convergence Report 2022 
172 
As regards monthly data, long-term interest rates 
were very stable during 2020, with small 
fluctuations around 0%. The highest rate in 2020 
was 0.1% and the lowest was -0.2%. Since the 
beginning of 2021, the interest rate has been 
fluctuating around a slightly higher level of 0.3%. 
Volatility increased somewhat in 2021, but overall 
the long-term interest rate continued to be broadly 
stable in a range of 0.1-0.4%. The compression of 
Swedish long-term interest rates in 2020-2021 
reflected the continuation of the non-standard 
monetary policy measures, with continued 
acquisition and reinvestment of governments 
bonds as a response to the low domestic inflation 
environment. The Riksbank decided to increase its 
asset-purchase programme in response to the 
COVID-19 crisis. The yields of the Swedish 
benchmark government bond remained relatively 
closely aligned to the German benchmark bond, in 
line with the safe-haven status of Swedish 
government bonds. However, long-term interest 
spreads vis-à-vis the German benchmark bond 
increased during 2020 and 2021, from a low of 37 
basis points to a high of 76 basis points in March 
2021. Since then the spread declined until 
February 2002, before increasing to 72 basis points 
in April 2022. 
8.6. ADDITIONAL FACTORS 
The Treaty (Article 140 TFEU) calls for an 
examination of other factors relevant to economic 
integration and convergence to be taken into 
account in the assessment. The assessment of the 
additional factors — including balance of 
payments developments, product, labour and 
financial market integration — gives an important 
indication of a Member State's ability to integrate 
into the euro area without difficulties. 
In November 2021, the Commission published its 
latest Alert Mechanism Report (AMR 2022) under 
the Macroeconomic Imbalance Procedure (MIP - 
see also Box 1.7), which concluded that an In-
Depth Review was warranted for Sweden. Taking 
into account the assessment in its In-Depth 
Review, the Commission, in its Communication 
‘European Semester – 2022 Spring Package’ (139), 
considers that Sweden is experiencing imbalances 
with vulnerabilities that relate to high and rising 
house prices and high household indebtedness. In 
2021, house prices moved further away from 
fundamental values with supportive financial 
conditions continuing to fuel housing demand. 
High household debt exposes Sweden to the risk of 
adverse shocks and a disorderly correction of 
housing prices, with potential harmful implications 
for the real economy and the banking sector. 
Private debt has risen further, a large share of 
which is concentrated in real estate, both 
commercial and housing, and most of household 
mortgage debt is at variable interest rates. Policy 
measures have not sufficiently addressed 
vulnerabilities relating to housing debt and 
potential house price overvaluations. Tax 
incentives for debt-financed housing remain, along 
with shortages in supply and identified 
shortcomings in the functioning of the rental 
market. Measures in the RRP only address the 
vulnerabilities in a partially satisfactory manner. 
Sweden submitted its recovery and resilience plan 
(RRP) on 28 May 2021. The Commission’s 
positive assessment on 29 March 2022 and 
Council’s approval on 4 May 2022 paved the way 
for the implementation of the RRP and the 
disbursement of EUR 3.3 billion in grants, which 
is equivalent to 0.7% of 2019 GDP, over the 
period 2022-2026. 
Sweden’s plan includes a set of mutually 
reinforcing reforms and investments (12 
investments and 15 reforms) that contribute to 
effectively addressing all or a significant subset of 
the economic and social challenges outlined in the 
country-specific recommendations (CSRs) 
addressed to Sweden by the Council in the 
European Semester in 2019 and 2020. 
The plan addresses among others key
macroeconomic challenges such as green and digital 
transition, demographic change, and strengthening 
the education and healthcare systems. Key 
investments are included to support the low carbon 
(139) COM(2022)600 final. 
-1
0
1
2
2016 2017 2018 2019 2020 2021
Sweden Germany
Graph 8.8: Sweden - Long-term interest rates
(percent, monthly values)
Source: Eurostat.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 188 –
Convergence Report 2022 - Technical annex 
Chapter 8 - Sweden 
173 
and energy transitions, as well as sustainable 
infrastructure, such as broad subsidy schemes 
aimed at speeding up the decarbonisation of 
industry and transport via the promotion of 
investment in the development and application of 
innovative technologies for fossil-free solutions, 
acceleration of the roll out of high-speed 
broadband in sparsely populated areas and 
investing in continuous learning and digital skills. 
Key reforms include promoting decarbonisation by 
requiring fuel suppliers to blend in sustainable 
biofuels in petrol, diesel and jet fuel, improving the 
sustainability of the pension and social security 
system, combating money laundering, increasing 
the accessibility and capacity of the health 
care system, in particular through training of 
elderly care providers, as well as measures that aim 
to promote housing supply by reducing bottlenecks 
in permit procedures. 
The plan devotes 44.4% of its total allocation to 
measures supporting climate objectives, 20.5% to 
the digital transition and 38.1% on social 
expenditure, all while respecting the do no 
significant harm principle. 
The implementation of the investments in the 
Swedish plan, along with other investments under 
NextGenerationEU, is estimated to raise Sweden’s 
GDP by 0.6% by 2026, of which 0.3% due to the 
positive spillover effects of the coordinated 
implementation of NextGenerationEU across 
Member States (Pfeiffer et al. 2021) (140). This 
does not take into account the positive impact of 
structural reforms on growth. 
8.6.1. Developments of the balance of 
payments 
According to Balance of Payments data, Sweden's 
current account surplus increased to 6% of GDP in 
2020, as domestic demand retrenched and goods 
trade held up comparatively well, despite plant 
closures and other supply and production 
disruptions in the wake of the pandemic. A decline 
in the balance on services offset the further 
increase in the primary income balance that had 
trended up from 2015 onwards. In 2021, the 
current account broadly stabilised at 5.5% of GDP, 
driven by high surpluses in the goods and the 
(140) See Pfeiffer P., Varga J. and in ’t Veld J. (2021),
“Quantifying Spillovers of NGEU investment”, European
Economy Discussion Papers, No. 144 and Afman et al.
(2021), “An overview of the economics of the Recovery
and Resilience Facility”, Quarterly Report on the Euro
Area (QREA), Vol. 20, No. 3 pp. 7-16. 
Table 8.4:
Sweden - Balance of payments (percentage of GDP)
2016 2017 2018 2019 2020 2021
Current account 2.4 3.0 2.7 5.5 6.1 5.5
of which: Balance of trade in goods 1.6 2.1 2.0 3.9 4.6 4.5
Balance of trade in services 1.5 0.6 0.3 0.6 0.0 -0.1
Primary income balance 0.5 1.7 2.0 2.9 3.5 3.0
Secondary income balance -1.3 -1.5 -1.6 -1.9 -2.1 -1.9
Capital account 0.0 0.0 0.0 0.0 0.1 0.2
External balance 1) 2.3 2.9 2.8 5.5 6.1 5.7
Financial account -4.9 4.1 1.6 4.5 -9.5 1.7
of which: Direct investment -2.8 2.7 2.5 1.3 0.9 -1.1
Portfolio investment 1.1 0.6 -1.8 2.2 -11.0 7.1
                Other investment 2) -4.0 0.7 0.9 2.2 0.5 -5.2
Change in reserves 0.8 0.1 -0.1 -1.2 0.1 1.0
Financial account without reserves -5.7 4.1 1.6 5.7 -9.7 0.8
Errors and omissions -7.2 1.2 -1.2 -1.0 -15.7 -3.9
Gross capital formation 24.7 25.7 26.0 25.1 24.8 25.6
Gross saving 27.1 28.5 28.6 30.3 30.8 31.1
Net international investment position -3.5 -0.9 8.1 16.2 14.1 17.8
1) The combined current and capital account.
2) Including financial derivatives.
Sources: Eurostat, Statistics Sweden, European Commission calculations.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 189 –
European Commission 
Convergence Report 2022 
174 
primary income balances. The solid export 
performance in goods was supported by the strong 
competitive position of Swedish exporters. By 
contrast, as in 2020, current transfers delivered a 
negative impact on the current account balance, 
reflecting Sweden's foreign aid and positive net 
contributions to international organisations, as well 
as remittances transferred by foreign workers in 
Sweden to their home countries. 
Sweden's net international investment position 
improved markedly to nearly 15% of GDP in 
2020, and is expected to have improved further in 
2021. Sweden's financial account shows relatively 
large fluctuations over time. However, seen over a 
longer period, the financial account balance has 
been mostly in surplus and mainly reflects 
Sweden's role as a net FDI investor abroad. 
Similarly, the balance of portfolio investments 
fluctuated appreciably from year to year, mirroring 
the interplay of financial market conditions and 
perceptions, exchange rates and relative cyclical 
positions but remained mostly in surplus. External 
debt was on a declining trend, and decreased by 
more than 20 percentage points between 2014 and 
2019, to around 170% of GDP in the latter year. 
The strong fiscal position with the concurrent 
decline in gross government debt has been a factor 
behind this decline. In 2020 and 2021, the ratio of 
external debt to GDP remained broadly stable. 
Sweden's export market share has been declining 
overall since the early 2000s, a phenomenon 
shared with several other high-income countries. 
The trend decline in the export market shares is 
linked to changing global trade patterns, which 
affect most mature, industrialised economies with 
a similar focus on high-value-added exports. Thus, 
this downward trend does not suggest any 
underlying competitiveness issues per se. It is 
difficult to assess short-term fluctuations in export 
shares given the high degree of volatility in global 
trade since 2020. These make it even harder than 
in more stable phases of the cycle to separate 
specific factors that impact trade performance from 
cyclical composition effects of export 
specialisation and from changes in structural 
features. 
This benign conclusion on competitiveness is 
buttressed by the developments in cost 
competitiveness indicators. The nominal and real 
effective exchange rates strengthened over 2020, 
but fell slightly in 2021. Unit labour costs 
exhibited large swings in 2020 and 2021 in view of 
the disparate behaviour of economic activity and 
employment metrics, all affected heavily by the 
pandemic as well as large-scale policy 
intervention (141). Allowing for such volatility, the 
underlying trend is that unit labour costs have been 
growing fairly moderately over the past number of 
years and broadly in line with Sweden's main 
trading partners. 
According to the Commission’s Spring 2022 
Economic Forecast, which is based on National 
Accounts data, the current account surplus is 
projected to fall further in 2022, to 4.8% of GDP, 
in National Account terms, before rising again to 
5.8% of GDP in 2023. 
8.6.2. Market integration 
Sweden is well integrated with the euro area 
through trade and investment linkages. Trade 
openness of the Swedish economy has been high, 
at over 40% (except in 2016, when it was just 
below that level) or more every year since 2005, 
although falling back in 2020 to somewhat over 
the 2016 level. However, trade openness recovered 
in 2021. The main euro-area trading partners are 
Germany, the Netherlands and Finland, while 
among non-euro-area countries Norway and 
Denmark are the main trade partners. 
The stock of inward FDI has remained fairly stable 
relative to GDP in recent years (equivalent to 
92.2% of GDP in 2020 and 92.9% in 2021). As 
regards net inward FDI in 2021, close to 56% 
originated from the euro area, whereas substantial 
flows originate from non-euro-area countries, 
primarily Denmark, Norway and the UK, a
wellestablished pattern over a longer period. 
(141) The REER based on unit labour costs should be interpreted
with prudence as unit labour costs were distorted by labour
retention schemes in some countries, including Sweden.
80
90
100
110
2016 2017 2018 2019 2020 2021
Graph 8.9: Sweden - Effective exchange rates
NEER REER, HICP deflated REER, ULC deflated
(vs. 36 trading partners;  monthly averages;
index numbers, 2016 = 100)
Source: European Commission.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 190 –
Convergence Report 2022 - Technical annex 
Chapter 8 - Sweden 
175 
Regarding the business environment, Sweden 
regularly scores top positions in international 
rankings, well above most euro-area Member State 
and currently ranks in the top ten at global level, 
with respect to the World Bank's Ease of Doing 
Business indicator and to the IMD World 
Competitiveness Ranking (142). According to the 
World Bank's Worldwide Governance Indicators 
(2020), Sweden ranks higher than the average of 
the euro-area Member States in all six categories, 
notably voice and accountability, political stability 
and absence of violence, government 
effectiveness, regulatory quality, rule of law and 
control of corruption. (143) Sweden's deficit in the 
transposition of EU directives in 2020 was at 
0.7%, below the EU average and just above the 
0.5% target as proposed by the European 
Commission in the Single Market Act (2011). 
Sweden has notified a complete transposition of 
the 5th Anti-Money Laundering Directive, and the 
Commission is currently assessing whether there 
are any potential conformity or effectiveness issues 
in the transposition or implementation of the legal 
act. 
(142) The World Bank Doing Business (DB) program was
paused in 2021. The programme will continue with a new
governance and improved accountability and transparency
under the name Business Enabling Environment (BEE).
The first edition of the BEE is expected in 2023. 
(143) A Member State is considered to have a ‘low’ (‘high’)
ranking compared with the average five euro area Member
States with the lowest scores for each indicator if its score
is at least 0.3 percentage points lower (higher) than that of 
the average of this euro area group. 
The Swedish labour market, largely governed by 
negotiations between social partners at sectorial 
level, is characterised by high employment rates. 
Sweden has the largest labour force participation 
rate in the EU. Low nominal wage increases in 
recent years have been a factor behind muted 
underlying inflation. In the wake of the COVID-
pandemic, modest multi-year wage agreements 
among social partners (which extend into 2023) 
have helped contain wage-induced inflation risks. 
Sweden has one of the lowest wage dispersions in 
the EU, with high entry wages and relatively little 
wage progression. According to the 2019 OECD 
employment protection indicator, the employment 
protection of permanent workers is rather high 
compared to that of temporary workers. The 
dispersion of regional unemployment rates is 
relatively low, but persistent imbalances in the 
housing market and high costs of housing, not only 
in the larger cities but also in new development 
poles, like in the north of the country, pose 
challenges to labour mobility. The integration of 
low-skilled workers and those born outside the EU 
remain a key challenge for the Swedish labour 
market, though, as the employment rate of both 
groups is significantly below the overall 
0.0
0.6
1.2
1.8
2.4
Voice and Accountability
Political Stability and Absence
of Violence/Terrorism
Government Effectiveness
Regulatory Quality
Rule of Law
Control of Corruption
Sweden Euro area average five lowest Euro area average
Graph 8.10: Sweden - 2020 World Bank's Worldwide Governance Indicators
Note: Estimate of governance ranges from -2.5 (weak) to 2.5 (strong). 
Source: World Bank.
Table 8.5:
Sweden - Market integration
2016 2017 2018 2019 2020 2021
Trade openness 1) (%) 39.8 41.2 43.4 44.3 40.7 42.4
Trade with EA in goods &amp; services 2)+3) (%) 17.4 18.2 19.0 19.2 17.7 18.6
World Bank's Ease of Doing Business Index rankings 4) 9 10 12 10 10 -
IMD World Competitiveness Ranking 5) 5 9 9 9 6 2
Internal Market Transposition Deficit 6) (%) 1.4 0.3 0.1 0.7 0.7 -
Real house price index 7) 107.3 112.4 108.7 109.1 112.4 121.5
 1) (Imports + Exports of goods and services / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics, Balance of Payments).
 2) (Imports + Exports of goods with EA-19 / (2 x GDP at current market prices)) x 100 (Foreign Trade Statistics).
 3) Trade in services with EA-19 (average credit and debit in % of GDP at current prices) (Balance of Payments).
 4) Data not available for 2021. The Ease of Doing Business report by the World Bank was discontinued in September 2021. 
 5) International Institute for Management Development (IMD).
 6) Percentage of internal market directives not yet communicated as having been transposed, relative to the total.
(November data, as of 2016 date refers to the year of publication).
 7) Deflated house price index (2015=100) (Eurostat). 
Sources: Eurostat, World Bank, International Institute for Management Development, European Commission calculations.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 191 –
European Commission 
Convergence Report 2022 
176 
employment rate. During the recovery from the 
initial COVID-19 shock, the number of unfilled 
vacancies rose sharply. In the first quarter of 2022, 
the vacancy ratio rose to the highest level on 
record since the statistic reporting on this variable 
started in 2009. While this high ratio partly reflects 
transitory shortages, given the high rate of labour 
market turnover and job-switching in the wake of 
the pandemic, it also points at mismatches 
extending to a wide range of branches of economic 
activity. Skills shortages remain particularly 
pronounced in education, health care, social work, 
information and communication technology, 
industry and construction. 
The financial sector in Sweden is highly developed 
and is commensurate to that of the average in the 
euro area. Relative to GDP, assets managed by the 
financial sector are about 85% of that of the euro 
area. Since 2016, the Swedish financial sector has 
grown significantly more than it has in the euro 
area. Banking dominates the Swedish financial 
sector and makes up around 45% of the assets of 
the financial sector, which is more than in the euro 
area. Non-money-market funds are at par with the 
euro area, and despite the Riksbank’s extensive 
asset-purchase programme, it only holds a 
relatively small share of total financial assets (less 
than half of what the ECB accounts for). 
The insurance and pension-fund sector in Sweden 
is the second largest manager of financial assets. It 
is almost twice as big as it is in the euro area, 
relative to GDP. This reflects the high degree of 
development of the funded pension system. Since 
end-2016, the sector has increased its holdings of 
financial assets by almost 29 percentage points in 
relation to GDP, while in the euro area it increased 
by only 12 percentage points. However, as a share 
of total assets managed by all financial 
corporations in the economy, the insurance and 
pension fund sector has been broadly stable. The 
investment-funds sector is of roughly equal size as 
in the euro area, and plays a similar role. 
As to the financing of the economy, Sweden has 
among the most developed credit and equity 
markets relative to GDP, and market financing 
(debt securities and listed shares) is among the 
highest in the EU. Loans are still an important 
source of funding and make up 276% of GDP in 
2020, compared to 240% of GDP in the euro area. 
This partially reflect the high degree of household 
indebtedness. Equity and private-sector-debt 
markets are very large compared to those of the 
euro area. Private-sector debt markets represent 
134% of GDP, and listed stocks represents 182% 
of GDP. This compares to 83% for private-sector 
debt and 73% for listed stocks in the euro area. 
Government debt is significantly lower than in the 
euro area. In terms of share of the sum of 
liabilities, loans in Sweden are comparable to that 
of the euro area. For securities, the differences 
reflect the larger share of market funding available 
in Sweden, and the traditional recourse to this type 
of funding. 
Sweden's banking sector is well integrated into the 
euro-area financial sector, through a high level of 
foreign ownership in its banking system, and 
because Stockholm acts as regional financial hub. 
The share of foreign-owned institutions in total 
bank assets stood at 21% in 2020, surpassing the 
euro-area average by 5 percentage points. The 
share more than doubled between 2016 and 2020, 
when Nordea’s headquarter moved to Finland in 
2018. Bank concentration, as measured by the 
market share of the five largest credit institutions 
Table 8.6:
Sweden - Allocation of assets by financial sub-sector
Ratio to GDP (%)
SE EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Financial corporations (total) 577 677 722 796 177 215
Central bank 19 26 45 78 37 61
Monetary financial institutions 285 302 286 311 97 98
Other financial intermediaries 65 83 202 179 20 28
Non-MMF investment funds1) 81 108 100 127 4 5
Insurance co. and Pension Funds 126 158 90 102 18 23
Share of total (%)
SE EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Central bank 3 4 6 10 21 29
Monetary financial institutions 49 45 40 39 55 46
Other financial intermediaries 11 12 28 22 11 12
Non-MMF investment funds 14 16 14 16 2 2
Insurance co. and Pension Funds 22 23 12 13 10 11
1) MMF stands for money market funds.
Source: Eurostat.
Table 8.7:
Sweden - Financing of the economy1)
Ratio to GDP (%)
SE EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Liabilities (total) 893 1016 743 770 324 335
Loans 247 278 238 236 115 112
Non-financial co. debt securities 21 30 12 15 3 4
Financial co. debt securities 115 112 74 68 11 12
Government debt securities 36 30 83 95 51 57
Listed shares 139 182 65 73 17 18
Unlisted shares 250 291 186 193 55 56
Other equity 64 73 51 56 42 48
Trade credits and advances 21 22 33 35 29 29
Share of total (%)
SE EA EA 5 smallest
2016 2020 2016 2020 2016 2020
Loans 28 27 32 31 35 33
Non-financial co. debt securities 2 3 2 2 1 1
Financial co. debt securities 13 11 10 9 3 3
Government debt securities 4 3 11 12 16 17
Listed shares 16 18 9 9 5 5
Unlisted shares 28 29 25 25 18 18
Other equity 7 7 7 7 13 14
Trade credits and advances 2 2 4 5 9 9
1) The table focuses on the financing needs of a country and how these are met by the financial system.
 The table is constructed from the liabilities of all economic sectors, but only considers loans, debt securities, 
equity and trade credits. The sum of liabilities in the table only reflects the total for the liabilities considered.
Source: Eurostat.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 192 –
Convergence Report 2022 - Technical annex 
Chapter 8 - Sweden 
177 
in total assets, has remained broadly stable at 55%, 
slightly above the euro-area average, which was 
53% at the end of 2020. 
  
Intra-EU integration in equity and debt markets, as 
measured by the home bias in portfolio 
investments, are in general relatively low across 
EU Member States, but Sweden scores well below 
the euro-area averages for both equity and debt 
holdings. (144) In terms of equity-market 
integration, Sweden reaches a comparable level of 
integration to those of the five euro-area Member 
States with the lowest level of integration. 
Concerning portfolio investments in debt, the 
home bias is very strong in Sweden relative to 
euro-area Member States. The level of home bias 
in Sweden has not changed by much between 2016 
and 2020. To some extent, these results reflect the 
high degree of development of Swedish financial 
markets and the country’s large and diverse 
industry sector. This allows Swedish investors to 
hold liquid assets in a broad set of companies 
operating on world markets, letting them hold 
diversified portfolios exposed to world market risk 
without investing abroad. 
                                                          
(144) Home bias in portfolio investments measures the average 
propensity of investors in a Member State to invest 
domestically as compared with investing in other EU 
countries. The indicator ranges between 0 and 1, with a 
value of 0 indicating that investors prefer domestic over 
foreign assets. The inverse of the home bias can be 
interpreted as one measure of financial integration among 
EU countries. 
   
 
0
10
20
30
40
50
60
SE, 2016 SE, 2020 EA, 2016 EA, 2020
Concentration in the banking sector (CR5 ratio)
Share of foreign institutions as % of total assets
Graph 8.11: Sweden - Foreign ownership and concentration 
in the banking sector
(in percent, weighted averages)
Source: ECB, Structural financial indicators.
0.0
0.2
0.4
SE, 2016 SE, 2020 EA, 2016 EA, 2020 EA Low,
2016
EA Low,
2020
Debt Equity
Graph 8.12: Sweden - Intra-EU integration in equity and debt portfolio 
investment
Note: The chart shows the extent of home bias in debt and equity markets. A value index 
of 1 implies ‘full integration’ with the financial markets of other Member States, while 0 
denotes ‘no integration’.
Source: FinFlows database: European Commission, Joint Research Centre (JRC). 
(index)
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 193 – 

 
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Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 198 –
Convergence Report
June 2022
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 199 –
Anlage 3
Convergence Report, June 2022 1 
Contents
1 Introduction 3
2 Framework for analysis 5
2.1 Economic convergence 5
Box 1  Price developments 6
Box 2  Fiscal developments 8
Box 3  Exchange rate developments 12
Box 4  Long-term interest rate developments 13
Box 5  Other relevant factors 15
2.2 Compatibility of national legislation with the Treaties 16
3 The state of economic convergence 43
3.1 The price stability criterion 50
3.2 The government budgetary position criterion 53
3.3 The exchange rate criterion 56
3.4 The long-term interest rate criterion 57
3.5 Other relevant factors 57
4 Country summaries 64
4.1 Bulgaria 64
4.2 Czech Republic 65
4.3 Croatia 67
4.4 Hungary 69
4.5 Poland 71
4.6 Romania 73
4.7 Sweden 74
5 Examination of economic convergence in individual countries 77
5.1 Bulgaria 77
5.2 Czech Republic 90
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Convergence Report, June 2022 
 
2 
5.3 Croatia 103 
5.4 Hungary 117 
5.5 Poland 131 
5.6 Romania 144 
5.7 Sweden 158 
6 Statistical methodology of convergence indicators 169 
6.1 Institutional features relating to the quality of statistics for the 
assessment of the convergence process 169 
6.2 HICP inflation 175 
6.3 Government finance statistics 176 
6.4 Exchange rates 177 
6.5 Long-term interest rates 178 
6.6 Other factors 178 
7 Examination of compatibility of national legislation with the 
Treaties 181 
7.1 Bulgaria 181 
7.2 Czech Republic 187 
7.3 Croatia 193 
7.4 Hungary 194 
7.5 Poland 204 
7.6 Romania 212 
7.7 Sweden 218 
 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 201 – 
Convergence Report, June 2022 3 
1 Introduction
Since 1 January 1999 the euro has been introduced in 19 EU Member States; 
this report examines seven of the eight EU countries that have not yet adopted 
the single currency. One of the eight countries, Denmark, in 1992 notified the 
Council of the European Union (EU Council) of its intention not to participate in Stage 
Three of Economic and Monetary Union (EMU).1 As a consequence, Convergence 
Reports only have to be provided for Denmark if the country so requests. Given the 
absence of such a request, this report examines the following countries: Bulgaria, the 
Czech Republic, Croatia, Hungary, Poland, Romania and Sweden. All seven countries 
are committed under the Treaty on the Functioning of the European Union (hereinafter 
the “Treaty”) to adopt the euro, which implies that they must strive to fulfil all the 
convergence criteria.2 
In producing this report, the ECB fulfils its requirement under Article 140 of the 
Treaty. Article 140 says that at least once every two years, or at the request of an EU 
Member State with a derogation, the ECB and the European Commission must report 
to the EU Council “on the progress made by the Member States with a derogation in 
fulfilling their obligations regarding the achievement of economic and monetary union”. 
The seven countries under review in this report have been examined as part of the 
regular two-year cycle. The European Commission has also prepared a report, and 
both reports are being submitted to the EU Council in parallel. 
In this report, the ECB uses the framework applied in its previous Convergence 
Reports. It examines, for the seven countries concerned, whether a high degree of 
sustainable economic convergence has been achieved, whether the national 
legislation is compatible with the Treaties and the Protocol on the Statute of the 
European System of Central Banks and of the European Central Bank (hereinafter the 
“Statute of the ESCB”), and whether the statutory requirements are fulfilled for the 
relevant national central bank (NCB) to become an integral part of the Eurosystem. 
This report includes a more in-depth assessment of Croatia than of the other 
countries under review. This is because the Croatian authorities have on various 
occasions announced their intention to adopt the euro as of 1 January 2023. 
The examination of the economic convergence process is highly dependent on 
the quality and integrity of the underlying statistics. The compilation and reporting 
of statistics, particularly government finance statistics, must not be subject to political 
considerations or interference. EU Member States have been invited to consider the 
quality and integrity of their statistics as a matter of high priority, to ensure that a 
1 When the Maastricht Treaty was concluded in 1992, Denmark was granted an exemption clause or 
“opt-out” under which it does not have to participate in the third stage of EMU and, therefore, introduce 
the euro.
2 Unless otherwise stated, all references in this report to the “Treaty” refer to the Treaty on the Functioning 
of the European Union, and the references to article numbers reflect the numbering in effect since 
1 December 2009. Unless otherwise stated, all references in this report to the “Treaties” refer to both the 
Treaty on European Union and the Treaty on the Functioning of the European Union. See also the 
clarification of these terms in the ECB web glossary.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 202 –
 
Convergence Report, June 2022 
 
4 
proper system of checks and balances is in place when these statistics are compiled, 
and to apply minimum standards in the domain of statistics. These standards are of 
the utmost importance in reinforcing the independence, integrity and accountability of 
the national statistical institutes and in supporting confidence in the quality of 
government finance statistics (see Chapter 6). 
From 4 November 20143 it became mandatory for any EU Member State whose 
derogation is abrogated to join the Single Supervisory Mechanism (SSM) at the 
latest on the date on which it adopts the euro. At that point, all SSM-related rights 
and obligations start to apply to that country. Therefore, it is of the utmost importance 
that the necessary preparations are made. In particular, the banking system of any 
Member State joining the euro area, and therefore the SSM, is subject to a 
comprehensive assessment.4 On 10 July 2020 the ECB announced that it had 
adopted the decisions to establish close cooperation with Българска народна банка 
(Bulgarian National Bank) and Hrvatska narodna banka, following the fulfilment of the 
necessary supervisory and legislative prerequisites.5 With the entry into force of the 
close cooperation frameworks on 1 October that year, the ECB assumed responsibility 
for (i) the direct supervision of the significant institutions in the two countries, (ii) the 
common procedures for all supervised entities, and (iii) the oversight of less significant 
institutions, which continue to be supervised by their national supervisors. ECB 
Banking Supervision, Българска народна банка (Bulgarian National Bank) and 
Hrvatska narodna banka have collaborated very closely to ensure the smooth 
integration of the national competent authorities into the SSM.6 
This report is structured as follows. Chapter 2 describes the framework used for 
the examination of economic and legal convergence. Chapter 3 provides a horizontal 
overview of the key aspects of economic convergence. Chapter 4 contains the country 
summaries, which provide the main results of the examination of economic and legal 
convergence. Chapter 5 examines in more detail the state of economic convergence 
in each of the seven EU Member States under review. Chapter 6 provides an overview 
of the convergence indicators and the statistical methodology used to compile them. 
Finally, Chapter 7 examines the compatibility of the national legislation of the Member 
States under review, including the statutes of their NCBs, with Articles 130 and 131 of 
the Treaty. 
 
3  This is the date on which the ECB assumed the tasks conferred on it by Council Regulation (EU) 
No 1024/2013 of 15 October 2013 conferring specific tasks on the European Central Bank concerning 
policies relating to the prudential supervision of credit institutions (OJ L 287, 29.10.2013, p.63). See 
Article 33(2) of that Regulation. 
4  See recital 10 of Regulation (EU) No 468/2014 of the European Central Bank of 16 April 2014 
establishing the framework for cooperation within the Single Supervisory Mechanism between the 
European Central Bank and national competent authorities and with national designated authorities 
(SSM Framework Regulation) (ECB/2014/17) (OJ L 141, 14.5.2014, p.1). 
5  See Decision (EU) 2020/1015 of the European Central Bank of 24 June 2020 on the establishment of 
close cooperation between the European Central Bank and Българска народна банка (Bulgarian 
National Bank) (ECB/2020/30) (OJ L 224I, 13.7.2020, p. 1) and Decision (EU) 2020/1016 of the 
European Central Bank of 24 June 2020 on the establishment of close cooperation between the 
European Central Bank and Hrvatska narodna banka (ECB/2020/31) (OJ L 224I, 13.7.2020, p. 4). The 
agreement on the inclusion of the Bulgarian lev and the Croatian kuna in ERM II entered into force 
simultaneously. 
6  See the ECB Annual Report on supervisory activities 2020, in particular Section 4.1 “Enlarging the SSM 
through close cooperation”. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 203 – 
Convergence Report, June 2022 5 
2 Framework for analysis
2.1 Economic convergence
To examine the state of economic convergence in EU Member States seeking to 
adopt the euro, the ECB makes use of a common framework for analysis. This 
common framework, which has been applied in a consistent manner throughout all 
European Monetary Institute (EMI) and ECB Convergence Reports, is based, first, on 
the Treaty provisions and their application by the ECB with regard to developments in 
prices, fiscal balances and debt ratios, exchange rates and long-term interest rates, as 
well as in other factors relevant to economic integration and convergence. Second, it 
is based on a range of additional backward and forward-looking economic indicators 
considered to be useful for examining the sustainability of convergence in greater 
detail. Some elements of this framework have been enhanced over time. The 
examination of the Member State concerned based on all these factors also provides 
important information which helps to ensure that its integration into the euro area will 
proceed without major difficulties. Boxes 1 to 5 below briefly outline the legal 
provisions and provide methodological details on the application of these provisions 
by the ECB. 
This report builds on principles set out in previous reports published by the 
ECB (and prior to that by the EMI) in order to ensure continuity and equal 
treatment. In particular, a number of guiding principles are used by the ECB in the 
application of the convergence criteria. First, the individual criteria are interpreted and 
applied in a strict manner. The rationale behind this principle is that the main purpose 
of the criteria is to ensure that only those Member States with economic conditions 
conducive to the maintenance of price stability and the coherence of the euro area can 
participate in it. Second, the convergence criteria constitute a coherent and integrated 
package, and they must all be satisfied. The Treaty lists the criteria on an equal footing 
and does not suggest a hierarchy. Third, the convergence criteria have to be met on 
the basis of actual data. Fourth, the application of the convergence criteria should be 
consistent, transparent and simple. Moreover, when considering compliance with the 
convergence criteria, sustainability is an essential factor, as convergence must be 
achieved on a lasting basis and not just at a given point in time. For this reason, the 
country examinations elaborate on the sustainability of convergence. 
In this respect, economic developments in the countries concerned are 
reviewed from a backward-looking perspective, covering, in principle, the past 
ten years. This helps to better determine the extent to which current achievements 
are the result of genuine structural adjustments, which in turn should lead to a better 
assessment of the sustainability of economic convergence. 
In addition, and to the extent appropriate, a forward-looking perspective is 
adopted. In this context, particular attention is paid to the fact that the sustainability of 
favourable economic developments hinges critically on appropriate and lasting policy 
responses to existing and future challenges. Strong governance, sound institutions 
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and sustainable public finances are also essential for supporting sustainable output 
growth over the medium to long term. Overall, it is emphasised that ensuring the 
sustainability of economic convergence depends on the achievement of a strong 
starting position, the existence of sound institutions, resilience to shocks and the 
pursuit of appropriate policies after the adoption of the euro. 
The common framework is applied individually to the seven EU Member States 
under review. These examinations, which focus on each Member State’s 
performance, should be considered separately, in line with the provisions of 
Article 140 of the Treaty. 
The cut-off date for the statistics included in this Convergence Report was 
25 May 2022. The statistical data used in the application of the convergence criteria 
are provided by the European Commission (see Chapter 6 as well as the tables and 
charts), in cooperation with the ECB in the case of exchange rates and long-term 
interest rates. In agreement with the European Commission, the reference period for 
both the price stability criterion and the long-term interest rate criterion is from May 
2021 to April 2022. For exchange rates, the reference period is from 26 May 2020 to 
25 May 2022. Historical data on fiscal positions cover the period up to 2021. Account 
is also taken of forecasts from various sources, together with the most recent 
convergence programme of the Member State concerned and other information 
relevant to a forward-looking examination of the sustainability of convergence. The 
European Commission’s Spring 2022 Economic Forecast and the Alert Mechanism 
Report 20227, which are also taken into account in this report, were released on 
16 May 2022 and 24 November 2021 respectively. This report was adopted by the 
General Council of the ECB on 27 May 2022. 
This Convergence Report considers the impact of the Russia-Ukraine war on 
the convergence assessment only to a limited extent. It is too early to draw any 
firm conclusions about how the convergence paths will be affected and whether this 
effect will materialise in a symmetric or asymmetric way across the relevant countries. 
In particular, the forward-looking convergence assessment is surrounded by high 
uncertainty, and the full impact can only be evaluated ex post. 
With regard to price developments, the legal provisions and their application by 
the ECB are outlined in Box 1. 
Box 1  
Price developments 
1. Treaty provisions 
Article 140(1), first indent, of the Treaty requires the Convergence Report to examine the 
achievement of a high degree of sustainable convergence by reference to the fulfilment by each 
Member State of the following criterion: 
 
7  European Commission, Alert Mechanism Report 2022 (COM(2021) 741 final). 
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“the achievement of a high degree of price stability; this will be apparent from a rate of inflation which 
is close to that of, at most, the three best performing Member States in terms of price stability”.
Article 1 of Protocol (No 13) on the convergence criteria stipulates that:
“The criterion on price stability referred to in the first indent of Article 140(1) of the Treaty on the 
Functioning of the European Union shall mean that a Member State has a price performance that is 
sustainable and an average rate of inflation, observed over a period of one year before the 
examination, that does not exceed by more than 1½ percentage points that of, at most, the three best 
performing Member States in terms of price stability. Inflation shall be measured by means of the 
consumer price index on a comparable basis taking into account differences in national definitions”.
2. Application of Treaty provisions
In the context of this report, the ECB applies the Treaty provisions as outlined below.
First, with regard to “an average rate of inflation, observed over a period of one year before the 
examination”, the inflation rate has been calculated using the change in the 12-month average of the
HICP in the reference period from May 2021 to April 2022 compared with the previous 12-month
average. Inflation has been measured on the basis of the HICP, which was developed for the purpose 
of assessing convergence in terms of price stability on a comparable basis (see Section 6.2).
Second, the notion of “at most, the three best performing Member States in terms of price stability”, 
which is used for the definition of the reference value, has been applied by taking the unweighted 
arithmetic average of the rates of inflation of the following three Member States: France (3.2%), 
Finland (3.3%) and Greece (3.6%). As a result, adding 1½ percentage points to the average rate, the 
reference value is 4.9%. It should be stressed that under the Treaty a country’s inflation performance 
is examined in relative terms, i.e. against that of other Member States. The price stability criterion thus 
takes into account the fact that common shocks (stemming, for example, from global commodity 
prices) can temporarily drive inflation rates away from central banks’ targets.
The inflation rates of Malta and Portugal have been excluded from the calculation of the reference 
value. Price developments in these countries over the reference period resulted in a 12-month
average inflation rate in April 2022 of 2.1% and 2.6% respectively. These two countries have been 
treated as “outliers” for the calculation of the reference value, as inflation rates in both countries were 
significantly lower than the comparable rates in other Member States over the reference period and, 
in both countries, this was due to exceptional factors. In Malta, subdued inflation developments 
largely reflected stable energy prices, owing to the Government’s financial support for the 
state-owned energy company and a reduction in the excise tax on fuel, as well as technical factors
related to the computation of the index. In particular, the household consumption basket changed 
considerably in 2020, albeit temporarily, as a result of the COVID-19 pandemic, which brought about
a large change in the weights of certain subcomponents of the index in 2021. This pattern was 
particularly pronounced for services inflation. In Portugal, the difference in inflation dynamics vis-à-vis
the euro area is mainly the result of more subdued growth in both services and energy prices. While 
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the former reflects a higher impact of depressed demand for tourism-related services, the latter is due 
to a lower pass-through of the increase in international oil prices and other energy costs.8 
 
The average rate of HICP inflation over the 12-month reference period from May 
2021 to April 2022 is reviewed in the light of the country’s economic 
performance over the last ten years in terms of price stability. This allows a more 
detailed examination of the sustainability of price developments in the country under 
review. In this connection, attention is paid to the orientation of monetary policy, in 
particular to whether the focus of the monetary authorities has been primarily on 
achieving and maintaining price stability, as well as to the contribution of other areas of 
economic policy to this objective. Moreover, the implications of the macroeconomic 
environment for the achievement of price stability are taken into account. Price 
developments are examined in the light of supply and demand conditions, focusing on 
factors such as unit labour costs and import prices. Finally, trends in other relevant 
price indices are considered. From a forward-looking perspective, a view is provided 
of prospective inflationary developments in the coming years, including forecasts by 
major international organisations and market participants. Moreover, institutional and 
structural aspects relevant for maintaining an environment conducive to price stability 
after adoption of the euro are discussed. 
With regard to fiscal developments, the legal provisions and their application 
by the ECB, together with procedural issues, are outlined in Box 2. 
Box 2  
Fiscal developments 
1. Treaty and other legal provisions 
Article 140(1), second indent, of the Treaty requires the Convergence Report to examine the 
achievement of a high degree of sustainable convergence by reference to the fulfilment by each 
Member State of the following criterion: 
“the sustainability of the government financial position; this will be apparent from having achieved a 
government budgetary position without a deficit that is excessive as determined in accordance with 
Article 126(6)”. 
Article 2 of Protocol (No 13) on the convergence criteria stipulates that: 
“The criterion on the government budgetary position referred to in the second indent of Article 140(1) 
of the said Treaty shall mean that at the time of the examination the Member State is not the subject of 
a Council decision under Article 126(6) of the said Treaty that an excessive deficit exists”. 
 
8  It should be noted that the concept of “outlier” has been referred to in previous ECB Convergence 
Reports as well as in the Convergence Reports of the EMI. In line with those reports, a Member State is 
considered to be an “outlier” if two conditions are fulfilled: first, its 12-month average inflation rate is 
significantly below the comparable rates in other Member States; and, second, its price developments 
have been strongly affected by exceptional factors. The identification of outliers does not follow any 
mechanical approach. The approach used was introduced to deal appropriately with potential significant 
distortions in the inflation developments of individual countries. 
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Article 126 sets out the excessive deficit procedure (EDP). In accordance with Article 126(2) and (3), 
the European Commission prepares a report if a Member State does not fulfil the requirements for 
fiscal discipline, in particular if:
1. the ratio of the planned or actual government deficit to GDP exceeds a reference value (defined
in the Protocol on the EDP as 3% of GDP), unless either:
(a) the ratio has declined substantially and continuously and reached a level that comes close
to the reference value; or, alternatively,
(b) the excess over the reference value is only exceptional and temporary and the ratio
remains close to the reference value;
2. the ratio of government debt to GDP exceeds a reference value (defined in the Protocol on the
EDP as 60% of GDP), unless the ratio is sufficiently diminishing and approaching the reference
value at a satisfactory pace.
In addition, the report prepared by the Commission must take into account whether the government 
deficit exceeds government investment expenditure and all other relevant factors, including the 
medium-term economic and budgetary position of the Member State. The Commission may also
prepare a report if, notwithstanding the fulfilment of the criteria, it is of the opinion that there is a risk of 
an excessive deficit in a Member State. The Economic and Financial Committee formulates an 
opinion on the Commission’s report. Finally, in accordance with Article 126(6), the EU Council, on the 
basis of a recommendation from the Commission and having considered any observations which the 
Member State concerned may wish to make, decides, acting by qualified majority and excluding the 
Member State concerned, and following an overall assessment, whether an excessive deficit exists in 
a Member State.
The Treaty provisions under Article 126 are further clarified by Regulation (EC) No 1467/979 as
amended by Regulation (EU) No 1177/201110, which, among other things: 
• confirms the equal footing of the debt criterion with the deficit criterion by making the former
operational, while allowing for a three-year period of transition for Member States exiting EDPs
opened before 2011. Article 2(1a) of the Regulation provides that when it exceeds the reference
value, the ratio of the government debt to GDP shall be considered sufficiently diminishing and
approaching the reference value at a satisfactory pace if the differential with respect to the
reference value has decreased over the previous three years at an average rate of one twentieth
per year as a benchmark, based on changes over the last three years for which the data are
available. The requirement under the debt criterion shall also be considered to be fulfilled if the
required reduction in the differential looks set to occur over a defined three-year period, based
on the Commission’s budgetary forecast. In implementing the debt reduction benchmark, the
influence of the economic cycle on the pace of debt reduction shall be taken into account;
9 Council Regulation (EC) No 1467/97 of 7 July 1997 on speeding up and clarifying the implementation of 
the excessive deficit procedure (OJ L 209, 2.8.1997, p. 6).
10  Council Regulation (EU) No 1177/2011 of 8 November 2011 amending Regulation (EC) No 1467/97 on 
speeding up and clarifying the implementation of the excessive deficit procedure (OJ L 306, 23.11.2011, 
p. 33).
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• details the relevant factors that the Commission shall take into account when preparing a report 
under Article 126(3) of the Treaty. Most importantly, it specifies a series of factors considered 
relevant in assessing developments in medium-term economic, budgetary and government debt 
positions (see Article 2(3) of the Regulation and, below, details on the ensuing ECB analysis). 
Moreover, the Treaty on Stability, Coordination and Governance in the Economic and Monetary Union 
(TSCG), which builds on the provisions of the enhanced Stability and Growth Pact, entered into force 
on 1 January 2013.11 Title III (Fiscal Compact) provides, among other things, for a binding fiscal rule 
aimed at ensuring that the general government budget is balanced or in surplus. This rule is deemed 
to be respected if the annual structural balance meets the country-specific medium-term objective 
and does not exceed a deficit – in structural terms – of 0.5% of GDP. If the government debt ratio is 
significantly below 60% of GDP and risks to long-term fiscal sustainability are low, the medium-term 
objective can be set at a structural deficit of at most 1% of GDP. The TSCG also includes the debt 
reduction benchmark rule referred to in Regulation (EU) No 1177/2011, which amended Regulation 
(EC) No 1467/97. The signatory Member States are required to introduce in their constitution – or 
equivalent law of higher level than the annual budget law – the stipulated fiscal rules accompanied by 
an automatic correction mechanism in case of deviation from the fiscal objective. 
2. Application of Treaty provisions 
For the purpose of examining convergence, the ECB expresses its view on fiscal developments. With 
regard to sustainability, the ECB examines key indicators of fiscal developments from 2012 to 2021, 
the outlook and the challenges for general government finances, focusing on the links between deficit 
and debt developments. Regarding the impact of the COVID-19 pandemic on general government 
finances, the ECB refers to the Stability and Growth Pact’s general escape clause, which was 
activated on 20 March 2020. In particular, for the preventive arm, Articles 5(1) and 9(1) of Regulation 
(EC) No 1466/9712 state that “in periods of severe economic downturn for the euro area or the Union 
as a whole, Member States may be allowed temporarily to depart from the adjustment path towards 
the medium-term budgetary objective…, provided that this does not endanger fiscal sustainability in 
the medium term”. For the corrective arm, Article 3(5) of Regulation (EC) No 1467/97 stipulates that 
“in the case of a severe economic downturn in the euro area or in the Union as a whole, the Council 
may also decide, on a recommendation from the Commission, to adopt a revised recommendation 
under Article 126(7) TFEU provided that this does not endanger fiscal sustainability in the medium 
term”, while Article 5(2) of Regulation (EC) No 1467/97 stipulates that “in the case of a severe 
economic downturn in the euro area or in the Union as a whole, the Council may also decide, on a 
recommendation from the Commission, to adopt a revised notice under Article 126(9) TFEU, on 
condition that this does not endanger fiscal sustainability in the medium term”. The ECB also provides 
an analysis with regard to the effectiveness of national budgetary frameworks, as referred to in Article 
2(3)(b) of Regulation (EC) No 1467/97 and in Directive 2011/85/EU13. With regard to Article 126, the 
ECB, in contrast to the Commission, has no formal role in the EDP. Therefore, the ECB report only 
states whether the country is subject to an EDP. 
 
11  The TSCG also applies to those EU Member States with a derogation that have ratified it as from the date 
when the decision abrogating that derogation takes effect or as from an earlier date if the Member State 
concerned declares its intention to be bound at such earlier date by all or part of the provisions of the 
TSCG. 
12  Council Regulation (EC) No 1466/97 of 7 July 1997 on the strengthening of the surveillance of budgetary 
positions and the surveillance and coordination of economic policies (OJ L 209, 2.8.1997, p.1). 
13  Council Directive 2011/85/EU of 8 November 2011 on requirements for budgetary frameworks of the 
Member States (OJ L 306, 23.11.2011, p. 41). 
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With regard to the Treaty provision that a debt ratio of above 60% of GDP should be “sufficiently 
diminishing and approaching the reference value at a satisfactory pace”, the ECB examines past and 
future trends in the debt ratio. For Member States in which the debt ratio exceeds the reference value, 
the ECB provides the European Commission’s latest assessment of compliance with the debt 
reduction benchmark laid down in Article 2(1a) of Regulation (EC) No 1467/97.
The examination of fiscal developments is based on data compiled on a national accounts basis, in 
compliance with the European System of Accounts 2010 (ESA 2010) (see Chapter 6). Most of the 
figures presented in this report were provided by the Commission in April 2022 and include 
government financial positions from 2012 to 2021 as well as Commission forecasts for 2022-23. 
With regard to the sustainability of public finances, the outcome in the 
reference year, 2021, is reviewed in the light of the performance of the country 
under review over the past ten years. First, the development of the deficit ratio is 
investigated. It is useful to bear in mind that the change in a country’s annual deficit
ratio is typically influenced by a variety of underlying forces. These influences can be 
divided into “cyclical effects” on the one hand, which reflect the reaction of deficits to 
changes in the economic cycle, and “non-cyclical effects” on the other, which are often
taken to reflect structural or permanent adjustments to fiscal policies. However, such 
non-cyclical effects, as quantified in this report, cannot necessarily be seen as entirely 
reflecting a structural change to fiscal positions, because they include temporary 
effects on the budgetary balance stemming from the impact of both policy measures 
and special factors. Indeed, assessing how structural budgetary positions have 
changed during the COVID-19 pandemic is particularly difficult in view of uncertainty 
over the level and growth rate of potential output. 
As a further step, the development of the government debt ratio in this period is 
considered, as well as the factors underlying it. These factors are the difference 
between nominal GDP growth and interest rates, the primary balance and the 
deficit-debt adjustment. Such a perspective can offer further information on the extent 
to which the macroeconomic environment, in particular the combination of growth and 
interest rates, has affected the dynamics of debt. It can also provide more information 
on the contribution of the structural balance and the cyclical developments, as 
reflected in the primary balance, and on the role played by special factors, as included 
in the deficit-debt adjustment. In addition, the structure of government debt is 
considered, by focusing in particular on the shares of debt with a short-term maturity 
and foreign currency debt, as well as their development. By comparing these shares 
with the current level of the debt ratio, the sensitivity of fiscal balances to changes in 
exchange rates and interest rates can be highlighted. 
Turning to a forward-looking perspective, national budget plans and recent 
forecasts by the European Commission for 2022-23 are considered, and 
account is taken of the medium-term fiscal strategy, as reflected in the 
convergence programme. This includes an assessment of the projected attainment 
of the country’s medium-term budgetary objective, as foreseen in the Stability and 
Growth Pact, as well as of the outlook for the debt ratio on the basis of current fiscal 
policies. In the context of the COVID-19 pandemic, the general escape clause has 
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been activated and allows deviations from the medium-term budgetary objective as 
described in Box 2. In addition, long-term challenges to the sustainability of budgetary 
positions and broad areas for consolidation are emphasised, particularly those related 
to the issue of unfunded government pension systems in connection with 
demographic change and to contingent liabilities incurred by the government. 
Furthermore, in line with past practice, the analysis described above also covers most 
of the relevant factors identified in Article 2(3) of Regulation (EC) No 1467/97, as 
described in Box 2. 
With regard to exchange rate developments, the legal provisions and their 
application by the ECB are outlined in Box 3. 
Box 3  
Exchange rate developments 
1. Treaty provisions 
Article 140(1), third indent, of the Treaty requires the Convergence Report to examine the 
achievement of a high degree of sustainable convergence by reference to the fulfilment by each 
Member State of the following criterion: 
“the observance of the normal fluctuation margins provided for by the exchange-rate mechanism of 
the European Monetary System, for at least two years, without devaluing against the euro”. 
Article 3 of Protocol (No 13) on the convergence criteria stipulates that: 
“The criterion on participation in the Exchange Rate mechanism of the European Monetary System 
referred to in the third indent of Article 140(1) of the said Treaty shall mean that a Member State has 
respected the normal fluctuation margins provided for by the exchange-rate mechanism on the 
European Monetary System without severe tensions for at least the last two years before the 
examination. In particular, the Member State shall not have devalued its currency’s bilateral central 
rate against the euro on its own initiative for the same period”. 
2. Application of Treaty provisions 
With regard to exchange rate stability, the ECB examines whether the country has participated in 
ERM II (which superseded the ERM as of January 1999) for a period of at least two years prior to the 
convergence examination without severe tensions, in particular without devaluing against the euro. In 
cases of shorter periods of participation, exchange rate developments are described over a two-year 
reference period. 
The examination of exchange rate stability against the euro focuses on the exchange rate being close 
to the ERM II central rate, while also taking into account factors that may have led to an appreciation, 
which is in line with the approach taken in the past. In this respect, the width of the fluctuation band 
within ERM II does not prejudice the examination of the exchange rate stability criterion. 
Moreover, the issue of the absence of “severe tensions” is generally addressed by: (i) examining the 
degree of deviation of exchange rates from the ERM II central rates against the euro; (ii) using 
indicators such as exchange rate volatility vis-à-vis the euro and its trend, as well as short-term 
interest rate differentials vis-à-vis the euro area and their development; (iii) considering the role 
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played by foreign exchange interventions; and (iv) considering the role of international financial 
assistance programmes in stabilising the currency.
The reference period in this report is from 26 May 2020 to 25 May 2022. All bilateral exchange rates 
are official ECB reference rates (see Chapter 6).
In addition to ERM II participation and nominal exchange rate developments 
against the euro over the period under review, evidence relevant to the 
sustainability of the current exchange rate is briefly reviewed. This is derived 
from the development of the real effective exchange rates and the current, capital and 
financial accounts of the balance of payments. The evolution of gross external debt 
and the net international investment position over longer periods is also examined. 
The section on exchange rate developments further considers measures of the 
degree of a country’s integration with the euro area. This is assessed in terms of both
external trade integration (exports and imports) and financial integration. Finally, the 
section on exchange rate developments reports, if applicable, whether the country 
under examination has during the two-year reference period benefited from central 
bank liquidity assistance or balance of payments support, either bilaterally or 
multilaterally with the involvement of the IMF and/or the EU. Both actual and 
precautionary assistance are considered, including access to precautionary financing 
in the form of, for instance, the IMF’s Flexible Credit Line.
With regard to long-term interest rate developments, the legal provisions and 
their application by the ECB are outlined in Box 4. 
Box 4
Long-term interest rate developments 
1. Treaty provisions
Article 140(1), fourth indent, of the Treaty requires the Convergence Report to examine the 
achievement of a high degree of sustainable convergence by reference to the fulfilment by each 
Member State of the following criterion:
“the durability of convergence achieved by the Member State with a derogation and of its participation 
in the exchange-rate mechanism being reflected in the long-term interest-rate levels”. 
Article 4 of Protocol (No 13) on the convergence criteria stipulates that:
“The criterion on the convergence of interest rates referred to in the fourth indent of Article 140(1) of 
the said Treaty shall mean that, observed over a period of one year before the examination, a 
Member State has had an average nominal long-term interest rate that does not exceed by more than
two percentage points that of, at most, the three best performing Member States in terms of price 
stability. Interest rates shall be measured on the basis of long-term government bonds or comparable
securities, taking into account differences in national definitions”.
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2. Application of Treaty provisions 
In the context of this report, the ECB applies the Treaty provisions as outlined below. 
First, with regard to “an average nominal long-term interest rate” observed over “a period of one year 
before the examination”, the long-term interest rate has been calculated as an arithmetic average 
over the latest 12 months for which HICP data were available. The reference period considered in this 
report is from May 2021 to April 2022, in line with the reference period for the price stability criterion. 
Second, the notion of “at most, the three best performing Member States in terms of price stability”, 
which is used for the definition of the reference value, has been applied by using the unweighted 
arithmetic average of the long-term interest rates of the same three Member States included in the 
calculation of the reference value for the criterion on price stability (see Box 1). Over the reference 
period considered in this report, the long-term interest rates of the three countries with the lowest 
inflation rate included in the calculation of the reference value for the price stability criterion were 
0.3% (France), 0.2% (Finland) and 1.4% (Greece). As a result, the average rate is 0.6% and, adding 
2 percentage points, the reference value is 2.6%. Interest rates have been measured on the basis of 
available harmonised long-term interest rates, which were developed for the purpose of examining 
convergence (see Chapter 6). 
 
As mentioned above, the Treaty makes explicit reference to the “durability of 
convergence” being reflected in the level of long-term interest rates. Therefore, 
developments over the reference period from May 2021 to April 2022 are reviewed 
against the background of the path of long-term interest rates over the past ten years 
(or otherwise the period for which data are available) and the main factors underlying 
differentials vis-à-vis the average long-term interest rate prevailing in the euro area. 
During the reference period, the average euro area long-term interest rate may have 
partly reflected high country-specific risk premia in several euro area countries. 
Therefore, the euro area AAA long-term government bond yield (i.e. the long-term 
yield of the euro area AAA yield curve, which includes the euro area countries with an 
AAA rating) is also used for comparison purposes. As background to this analysis, this 
report also provides information about the size and development of the financial 
market. This is based on three different indicators (the outstanding amount of debt 
securities issued by non-financial corporations, stock market capitalisation and MFI 
credit to the domestic non-financial private sector), which, together, provide a 
measure of the size of financial markets. 
Finally, Article 140(1) of the Treaty requires this report to take account of 
several other relevant factors (see Box 5). In this respect, an enhanced economic 
governance framework in accordance with Article 121(6) of the Treaty entered into 
force on 13 December 2011 with the aim of ensuring a closer coordination of 
economic policies and the sustained convergence of EU Member States’ economic 
performances. Box 5 below briefly outlines these legislative provisions and the way in 
which the above-mentioned additional factors are addressed in the assessment of 
convergence conducted by the ECB. 
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Box 5
Other relevant factors
1. Treaty and other legal provisions
Article 140(1) of the Treaty requires that: “The reports of the Commission and the European Central 
Bank shall also take account of the results of the integration of markets, the situation and 
development of the balances of payments on current account and an examination of the development 
of unit labour costs and other price indices”.
In this respect, the ECB takes into account the legislative package on EU economic governance 
which entered into force on 13 December 2011. Building on the Treaty provisions under Article 
121(6), the European Parliament and the EU Council adopted detailed rules for the multilateral 
surveillance procedure referred to in Article 121(3) and (4) of the Treaty. These rules were adopted “in 
order to ensure closer coordination of economic policies and sustained convergence of the economic 
performances of the Member States” (Article 121(3)) in view of the “need to draw lessons from the 
first decade of functioning of the economic and monetary union and, in particular, for improved 
economic governance in the Union built on stronger national ownership”14. The legislative package
includes an enhanced surveillance framework (the macroeconomic imbalance procedure or MIP) 
aimed at preventing excessive macroeconomic and macro-financial imbalances by helping diverging
EU Member States to establish corrective plans before divergence becomes entrenched. The MIP, 
with both preventive and corrective arms, applies to all EU Member States, except those which, being 
under an international financial assistance programme, are already subject to closer scrutiny coupled 
with conditionality. The MIP includes an alert mechanism for the early detection of imbalances, based 
on a transparent scoreboard of indicators with alert thresholds for all EU Member States, combined 
with economic judgement. This judgement should take into account, among other things, nominal and 
real convergence inside and outside the euro area.15 When assessing macroeconomic imbalances,
this procedure should take due account of their severity and their potential negative economic and 
financial spillover effects which aggravate the vulnerability of the EU economy and threaten the 
smooth functioning of Economic and Monetary Union.16 
2. Application of Treaty provisions
In line with past practice, the additional factors referred to in Article 140(1) of the Treaty are reviewed 
in Chapter 5 under the headings of the individual criteria described in Boxes 1 to 4. For completeness, 
in Chapter 3 the scoreboard indicators are presented for the countries covered in this report (including 
in relation to the alert thresholds), thereby ensuring the provision of all available information relevant 
to the detection of macroeconomic and macro-financial imbalances that may be hampering the
achievement of a high degree of sustainable convergence as stipulated in Article 140(1) of the Treaty. 
Notably, EU Member States with a derogation that are subject to an excessive imbalance procedure 
can hardly be considered as having achieved a high degree of sustainable convergence as stipulated 
in Article 140(1) of the Treaty.
14  See recital 2 of Regulation (EU) No 1176/2011 of the European Parliament and of the Council of
16 November 2011 on the prevention and correction of macroeconomic imbalances (OJ L 306, 
23.11.2011, p. 25).
15  See Article 4(4) of Regulation (EU) No 1176/2011. 
16  See recital 17 of Regulation (EU) No 1176/2011. 
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2.2 Compatibility of national legislation with the Treaties 
2.2.1 Introduction 
Article 140(1) of the Treaty requires the ECB (and the European Commission) to 
report, at least once every two years or at the request of a Member State with a 
derogation, to the Council on the progress made by the Member States with a 
derogation in fulfilling their obligations regarding the achievement of economic and 
monetary union. These reports must include an examination of the compatibility 
between the national legislation of each Member State with a derogation, including the 
statutes of its NCB, and Articles 130 and 131 of the Treaty and the relevant Articles of 
the Statute. This Treaty obligation of Member States with a derogation is also referred 
to as ‘legal convergence’. 
When assessing legal convergence, the ECB is not limited to making a formal 
assessment of the letter of national legislation, but may also consider whether the 
implementation of the relevant provisions complies with the spirit of the Treaties and 
the Statute. The ECB is particularly concerned about any signs of pressure being put 
on the decision-making bodies of any Member State’s NCB which would be 
inconsistent with the spirit of the Treaty as regards central bank independence. The 
ECB also sees the need for the smooth and continuous functioning of the NCBs’ 
decision-making bodies. In this respect, the relevant authorities of a Member State 
have, in particular, the duty to take the necessary measures to ensure the timely 
appointment of a successor if the position of a member of an NCB’s decision-making 
body becomes vacant.17 The ECB will closely monitor any developments prior to 
making a positive final assessment concluding that a Member State’s national 
legislation is compatible with the Treaty and the Statute. 
Member States with a derogation and legal convergence 
Bulgaria, the Czech Republic, Croatia, Hungary, Poland, Romania and Sweden, 
whose national legislation is examined in this report, each have the status of a 
Member State with a derogation, i.e. they have not yet adopted the euro. Sweden was 
given the status of a Member State with a derogation by a decision of the Council in 
May 1998.18 As far as the other Member States are concerned, Articles 419 and 520 of 
 
17  Opinions CON/2010/37 and CON/2010/91. All ECB opinions are available on EUR-Lex. 
18  Council Decision 98/317/EC of 3 May 1998 in accordance with Article 109j(4) of the Treaty (OJ L 139, 
11.5.1998, p. 30). Note: The title of Decision 98/317/EC refers to the Treaty establishing the European 
Community (prior to the renumbering of the Articles of this Treaty in accordance with Article 12 of the 
Treaty of Amsterdam); this provision has been repealed by the Treaty of Lisbon. 
19  Act concerning the conditions of accession of the Czech Republic, the Republic of Estonia, the Republic 
of Cyprus, the Republic of Latvia, the Republic of Lithuania, the Republic of Hungary, the Republic of 
Malta, the Republic of Poland, the Republic of Slovenia and the Slovak Republic and the adjustments to 
the Treaties on which the European Union is founded (OJ L 236, 23.9.2003, p. 33). 
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the Acts concerning the conditions of accession provide that each of these Member 
States shall participate in the Economic and Monetary Union from the date of 
accession as a Member State with a derogation within the meaning of Article 139 of 
the Treaty. 
This report does not cover Denmark, which is a Member State with a special status 
and which has not yet adopted the euro. Protocol (No 16) on certain provisions relating 
to Denmark, annexed to the Treaties, provides that, in view of the notice given to the 
Council by the Danish Government on 3 November 1993, Denmark has an exemption 
and that the procedure for the abrogation of the derogation will only be initiated at the 
request of Denmark. As Article 130 of the Treaty applies to Denmark, Danmarks 
Nationalbank has to fulfil the requirements of central bank independence. The EMI’s 
Convergence Report of 1998 concluded that this requirement had been fulfilled. There 
has been no assessment of Danish convergence since 1998 due to Denmark’s special 
status. Until such time as Denmark notifies the Council that it intends to adopt the 
euro, Danmarks Nationalbank does not need to be legally integrated into the 
Eurosystem and no Danish legislation needs to be adapted. 
The aim of assessing legal convergence is to facilitate the Council’s decisions as to 
which Member States fulfil ‘their obligations regarding the achievement of economic 
and monetary union’ (Article 140(1) of the Treaty). In the legal domain, such conditions 
refer in particular to central bank independence and to the NCBs’ legal integration into 
the Eurosystem. 
Structure of the legal assessment
The legal assessment broadly follows the framework of the previous reports of the 
ECB and the EMI on legal convergence.21 
The compatibility of national legislation is considered in the light of legislation enacted 
before 25 March 2022. 
20  For Bulgaria and Romania, see Article 5 of the Act concerning the conditions of accession of the Republic
of Bulgaria and Romania and the adjustments to the Treaties on which the European Union is founded 
(OJ L 157, 21.6.2005, p. 203). For Croatia, see Article 5 of the Act concerning the conditions of accession 
of the Republic of Croatia and the adjustments to the Treaty on European Union, the Treaty on the 
Functioning of the European Union and the Treaty establishing the European Atomic Energy Community 
(OJ L 112, 24.4.2012, p. 21).
21  In particular the ECB’s Convergence Reports of June 2020 (on Bulgaria, the Czech Republic, Croatia,
Hungary, Poland, Romania and Sweden), May 2018 (on Bulgaria, the Czech Republic, Croatia, Hungary, 
Poland, Romania and Sweden), June 2016 (on Bulgaria, the Czech Republic, Croatia, Hungary, Poland, 
Romania and Sweden), June 2014 (on Bulgaria, the Czech Republic, Croatia, Lithuania, Hungary, 
Poland, Romania and Sweden), June 2013 (on Latvia), May 2012 (on Bulgaria, the Czech Republic, 
Latvia, Lithuania, Hungary, Poland, Romania and Sweden), May 2010 (on Bulgaria, the Czech Republic, 
Estonia, Latvia, Lithuania, Hungary, Poland, Romania and Sweden), May 2008 (on Bulgaria, the Czech 
Republic, Estonia, Latvia, Lithuania, Hungary, Poland, Romania, Slovakia and Sweden), May 2007 (on 
Cyprus and Malta), December 2006 (on the Czech Republic, Estonia, Cyprus, Latvia, Hungary, Malta, 
Poland, Slovakia and Sweden), May 2006 (on Lithuania and Slovenia), October 2004 (on the Czech 
Republic, Estonia, Cyprus, Latvia, Lithuania, Hungary, Malta, Poland, Slovenia, Slovakia and Sweden), 
May 2002 (on Sweden) and April 2000 (on Greece and Sweden), and the EMI’s Convergence Report of 
March 1998.
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2.2.2 Scope of adaptation 
Areas of adaptation 
For the purpose of identifying those areas where national legislation needs to be 
adapted, the following issues are examined: 
• compatibility with provisions on the independence of NCBs in the Treaty (Article 
130) and the Statute (Articles 7 and 14.2); 
• compatibility with provisions on confidentiality (Article 37 of the Statute); 
• compatibility with the prohibitions on monetary financing (Article 123 of the 
Treaty) and privileged access (Article 124 of the Treaty); 
• compatibility with the single spelling of the euro required by EU law; and 
• legal integration of the NCBs into the Eurosystem (in particular as regards 
Articles 12.1 and 14.3 of the Statute). 
‘Compatibility’ versus ‘harmonisation’ 
Article 131 of the Treaty requires national legislation to be ‘compatible’ with the 
Treaties and the Statute; any incompatibility must therefore be remedied. Neither the 
primacy of the Treaties and the Statute over national legislation nor the nature of the 
incompatibility affects the need to comply with this obligation. 
The requirement for national legislation to be ‘compatible’ does not mean that the 
Treaty requires ‘harmonisation’ of the NCBs’ statutes, either with each other or with 
the Statute. National particularities may continue to exist to the extent that they do not 
infringe the competence in monetary matters that is irrevocably conferred on the EU. 
Indeed, Article 14.4 of the Statute permits NCBs to perform functions other than those 
specified in the Statute, to the extent that they do not interfere with the objectives and 
tasks of the ESCB.22 Provisions authorising such additional functions in NCBs’ 
statutes are a clear example of circumstances in which differences may remain. 
Rather, the term ‘compatible’ indicates that national legislation and the NCBs’ statutes 
need to be adjusted to eliminate inconsistencies with the Treaties and the Statute and 
to ensure the necessary degree of integration of the NCBs into the ESCB. In 
particular, any provisions that infringe an NCB’s independence, as defined in the 
Treaty, and its role as an integral part of the ESCB, should be adjusted. It is therefore 
insufficient to rely solely on the primacy of EU law over national legislation to achieve 
this. 
The obligation in Article 131 of the Treaty only covers incompatibility with the Treaties 
and the Statute. However, national legislation that is incompatible with secondary EU 
 
22  As regards tasks and powers that have been partially conferred upon the ECB, any national legislation 
must be without prejudice to the tasks and powers conferred upon the ECB. See Opinion CON/2020/15. 
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legislation relevant for the areas of adaptation examined in this Convergence Report 
should be brought into line with such secondary legislation. The primacy of EU law 
does not affect the obligation to adapt national legislation. This general requirement 
derives not only from Article 131 of the Treaty but also from the case law of the Court 
of Justice of the European Union.23 
The Treaties and the Statute do not prescribe the manner in which national legislation 
should be adapted. This may be achieved by referring to the Treaties and the Statute, 
by incorporating provisions thereof and referring to their provenance, by removing any 
incompatibility, or by a combination of these methods. 
Furthermore, among other things as a tool for achieving and maintaining the 
compatibility of national legislation with the Treaties and the Statute, the ECB must be 
consulted by the EU institutions and by the Member States on draft legislative 
provisions in its fields of competence, pursuant to Articles 127(4) and 282(5) of the 
Treaty and Article 4 of the Statute. Council Decision 98/415/EC of 29 June 1998 on the 
consultation of the European Central Bank by national authorities regarding draft 
legislative provisions24 expressly requires Member States to take the measures 
necessary to ensure compliance with this obligation. 
2.2.3 Independence of NCBs
As far as central bank independence is concerned, national legislation in the Member 
States that joined the EU in 2004, 2007 or 2013 had to be adapted to comply with the 
relevant provisions of the Treaty and the Statute, and be in force on 1 May 2004, 1 
January 2007 and 1 July 2013 respectively.25 Sweden had to bring the necessary 
adaptations into force by the date of establishment of the ESCB on 1 June 1998. 
Central bank independence
In November 1995, the EMI established a list of features of central bank independence 
(later described in detail in its 1998 Convergence Report) which were the basis for 
assessing the national legislation of the Member States at that time, in particular the 
NCBs’ statutes. The concept of central bank independence includes various types of 
independence that must be assessed separately, namely: functional, institutional, 
personal and financial independence. Over the past few years there has been further 
refinement of the analysis of these aspects of central bank independence in the 
opinions adopted by the ECB. These aspects are the basis for assessing the level of 
convergence between the national legislation of the Member States with a derogation 
and the Treaties and the Statute. 
23  See, amongst others, Commission of the European Communities v French Republic, C-265/95,
EU:C:1997:595.
24  OJ L 189, 3.7.1998, p. 42. 
25  This also applies to the ESCB’s confidentiality regime; see Section 2.1.4 of this Convergence Report. 
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Functional independence 
Central bank independence is not an end in itself but is instrumental in achieving an 
objective that should be clearly defined and should prevail over any other objective. 
Functional independence requires each NCB’s primary objective to be stated in a 
clear and legally certain way and to be fully in line with the primary objective of price 
stability established by the Treaty. The pursuit of this objective is served by providing 
the NCBs with the necessary means and instruments for achieving this objective 
independently of any other authority. The Treaty’s requirement of central bank 
independence reflects the generally held view that the primary objective of price 
stability is best served by a fully independent institution with a precise definition of its 
mandate. Central bank independence is fully compatible with holding NCBs 
accountable for their decisions, which is an important aspect of enhancing confidence 
in their independent status. This entails transparency and dialogue with third parties. 
As regards timing, the Treaty is not clear about when the NCBs of Member States with 
a derogation must comply with the primary objective of price stability set out in Articles 
127(1) and 282(2) of the Treaty and Article 2 of the Statute. For those Member States 
that joined the EU after the date of the introduction of the euro in the EU, it is not clear 
whether this obligation should run from the date of accession or from the date of their 
adoption of the euro. While Article 127(1) of the Treaty does not apply to Member 
States with a derogation (see Article 139(2)(c) of the Treaty), Article 2 of the Statute 
does apply to such Member States (see Article 42.1 of the Statute). The ECB takes the 
view that the obligation of the NCBs to have price stability as their primary objective 
runs from 1 June 1998 in the case of Sweden, and from 1 May 2004, 1 January 2007 
and 1 July 2013 for the Member States that joined the EU on those dates. This is 
based on the fact that one of the guiding principles of the EU, namely price stability 
(Article 119 of the Treaty), also applies to Member States with a derogation. It is also 
based on the Treaty objective that all Member States should strive for macroeconomic 
convergence, including price stability, which is the intention behind the regular reports 
of the ECB and the European Commission. This conclusion is also based on the 
underlying rationale of central bank independence, which is only justified if the overall 
objective of price stability has primacy. 
The country assessments in this report are based on these conclusions as to the 
timing of the obligation of the NCBs of Member States with a derogation to have price 
stability as their primary objective. 
Institutional independence 
The principle of institutional independence is expressly referred to in Article 130 of the 
Treaty and Article 7 of the Statute. These two articles prohibit the NCBs and members 
of their decision-making bodies from seeking or taking instructions from EU institutions 
or bodies, from any government of a Member State or from any other body. In addition, 
they prohibit EU institutions, bodies, offices or agencies, and the governments of the 
Member States from seeking to influence those members of the NCBs’ 
decision-making bodies whose decisions may affect the fulfilment of the NCBs’ 
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ESCB-related tasks. For national legislation to mirror Article 130 of the Treaty and 
Article 7 of the Statute, it should reflect both prohibitions and not narrow the scope of 
their application.26 The recognition that central banks have such independence does 
not have the consequence of exempting them from every rule of law or of shielding 
them from any kind of legislation.27 
Whether an NCB is organised as a state-owned body, a special public law body or 
simply a public limited company, there is a risk that influence may be exerted by the 
owner on its decision-making in relation to ESCB-related tasks by virtue of such 
ownership.28 Such influence, whether exercised through shareholders’ rights or
otherwise, may affect an NCB’s independence and should therefore be limited by law.
The legal framework for central banking needs to provide a stable and long-term basis 
for a central bank’s functioning. A legal framework that permits frequent changes to 
the institutional set-up of an NCB, thus affecting its organisational or governance 
stability, could adversely affect that NCB’s institutional independence.29 
Institutional independence should also be respected in cases of emergency. Only 
where the conditions under Article 347 of the Treaty are met, may national authorities 
be justified in exercising, on a temporary and exceptional basis, powers that fall within 
the exclusive competence of the ESCB. The critical time for this assessment is when 
the measure is adopted. Due to the exceptional nature of Article 347 of the Treaty, 
Member States should refrain from adopting preventive legislation in the absence of 
the conditions prescribed by Article 347 of the Treaty.30 
Prohibition on giving instructions 
Rights of third parties to give instructions to NCBs, their decision-making bodies or 
their members are incompatible with the Treaty and the Statute as far as 
ESCB-related tasks are concerned. 
Any involvement of an NCB in the application of measures to strengthen financial 
stability must be compatible with the Treaty, i.e. NCBs’ functions must be performed in 
a manner that is fully compatible with their functional, institutional, and financial 
independence so as to safeguard the proper performance of their tasks under the 
Treaty and the Statute.31 To the extent that national legislation provides for a role of an 
NCB that goes beyond advisory functions and requires it to assume additional tasks, it 
must be ensured that these tasks will not affect the NCB’s ability to carry out its 
ESCB-related tasks from an operational and financial point of view.32 Additionally, the 
inclusion of NCB representatives in collegiate decision-making supervisory bodies or 
26  Opinion CON/2011/104. 
27  See paragraph 2.3 of Opinion CON/2019/15 and Commission v European Central Bank, C-11/00,
EU:C:2003:395, paragraphs 134 to 136.
28  Opinion CON/2019/23. 
29  See paragraph 2.2 of Opinion CON/2011/104 and paragraph 3.2.2 of Opinion CON/2017/34. 
30  See paragraph 2.2. of Opinion CON/2021/35. 
31  Opinion CON/2010/31. 
32  Opinion CON/2009/93. 
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other authorities would need to give due consideration to safeguards for the personal 
independence of the members of the NCB’s decision-making bodies.33 
Prohibition on approving, suspending, annulling or deferring decisions 
Rights of third parties to approve, suspend, annul or defer an NCB’s decisions are 
incompatible with the Treaty and the Statute as far as ESCB-related tasks are 
concerned.34 
Prohibition on censoring decisions on legal grounds 
A right for bodies other than independent courts to censor, on legal grounds, decisions 
relating to the performance of ESCB-related tasks is incompatible with the Treaty and 
the Statute, since the performance of these tasks may not be reassessed at the 
political level. A right of an NCB Governor to suspend the implementation of a decision 
adopted by the ESCB or by an NCB decision-making body on legal grounds and 
subsequently to submit it to a political body for a final decision would be equivalent to 
seeking instructions from third parties. 
Prohibition on participation in decision-making bodies of an NCB with a right to 
vote 
Participation by representatives of third parties in an NCB’s decision-making body with 
a right to vote on matters concerning the performance by the NCB of ESCB-related 
tasks is incompatible with the Treaty and the Statute, even if such vote is not decisive. 
Such participation even without the right to vote is incompatible with the Treaty and the 
Statute, if such participation interferes with the performance of ESCB-related tasks by 
that decision-making bodies or endangers compliance with the ESCB’s confidentiality 
regime.35 
Prohibition on ex ante consultation relating to an NCB’s decision 
An express statutory obligation for an NCB to consult third parties ex ante relating to 
an NCB’s decision provides third parties with a formal mechanism to influence the final 
decision and is therefore incompatible with the Treaty and the Statute. 
However, dialogue between an NCB and third parties, even when based on statutory 
obligations to provide information and exchange views, is compatible with central bank 
independence provided that: 
• this does not result in interference with the independence of the members of the 
NCB’s decision-making bodies; 
• the special status of Governors in their capacity as members of the ECB’s 
decision-making bodies is fully respected; and 
 
33  Opinion CON/2010/94. 
34  Opinion CON/2016/33. 
35  Opinions CON/2014/25 and CON/2015/57. 
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• confidentiality requirements resulting from the Statute are observed.36
Discharge provided for the duties of members of the NCB’s decision-making 
bodies 
Statutory provisions regarding the discharge provided by third parties (e.g. 
governments) regarding the duties of members of the NCB’s decision-making bodies 
(e.g. in relation to accounts) should contain adequate safeguards, so that such a 
power does not impinge on the capacity of the individual NCB member independently 
to adopt decisions in respect of ESCB-related tasks (or implement decisions adopted 
at ESCB level). Inclusion of an express provision to this effect in NCB statutes is 
recommended. 
Personal independence
The Statute’s provision on security of tenure for members of NCBs’ decision-making 
bodies further safeguards central bank independence. NCB Governors are members 
of the General Council of the ECB and become members of the Governing Council 
upon adoption of the euro by their Member States. NCB Governors cannot be 
regarded as representatives of a Member State when they perform their duties as 
members of the Governing Council or the General Council of the ECB.37 Article 14.2 
of the Statute provides that NCB statutes must, in particular, provide for a minimum 
term of office of five years for Governors. It also protects against Governors being 
arbitrarily relieved from their office by providing that they may only be relieved from 
office if they no longer fulfil the conditions required for performing their duties or if they 
[have been found guilty of serious misconduct. In such cases, Article 14.2 of the 
Statute provides for the possibility of recourse to the Court of Justice of the European 
Union, which has the power to annul the national decision taken to relieve a Governor 
from office.38 The suspension of a Governor may effectively amount to relieving a 
Governor from office for the purposes of Article 14.2 of the Statute.39 NCB statutes 
must comply with this provision as set out below. 
Article 130 of the Treaty prohibits national governments and any bodies from 
influencing the members of NCBs’ decision-making bodies in the performance of their 
tasks. In particular, Member States may not seek to influence the members of the 
NCB’s decision-making bodies by amending national legislation affecting their 
remuneration, which, as a matter of principle, should apply only for future 
appointments.40 
36  Opinion CON/2018/17. 
37  See LR Ģenerālprokuratūra, C-3/20, ECLI:EU:C:2021:969, paragraph 43. 
38  See Rimšēvičs v Latvia, C-202/18, EU:C:2019:139, paragraph 76. 
39  See Rimšēvičs v Latvia, C-202/18, EU:C:2019:139, paragraph 52, and Opinion CON/2011/9. 
40  See, for example, Opinions CON/2010/56, CON/2010/80, CON/2011/104, CON/2011/106 and 
CON/2021/9.
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Minimum term of office for Governors 
In accordance with Article 14.2 of the Statute, NCB statutes must provide for a 
minimum term of office of five years for a Governor. This does not preclude longer 
terms of office, while an indefinite term of office does not require adaptation of the 
statutes provided the grounds for the relieving a Governor from office are in line with 
those of Article 14.2 of the Statute. Shorter periods cannot be justified even if only 
applied during a transitional period.41 National legislation which provides for a 
compulsory retirement age should ensure that the retirement age does not interrupt 
the minimum term of office provided by Article 14.2 of the Statute, which prevails over 
any compulsory retirement age, if applicable to a Governor.42 When an NCB’s 
statutes are amended, the amending law should safeguard the security of tenure of 
the Governor and of other members of decision-making bodies who are involved in the 
performance of ESCB-related tasks.43 
Grounds for relieving Governors from office 
NCB statutes must ensure that Governors may not be dismissed for reasons other 
than those mentioned in Article 14.2 of the Statute. The purpose of the requirement 
under that Article is to prevent the authorities involved in the appointment of 
Governors, particularly the relevant government or parliament, from arbitrarily 
dismissing a Governor. NCB statutes should either refer to Article 14.2 of the Statute, 
incorporate its provisions and refer to their provenance, delete any incompatibility with 
the grounds for relieving from office laid down in Article 14.2, or omit any mention of 
grounds for relieving from office (since Article 14.2 is directly applicable).44 Once 
elected or appointed, Governors may not be relieved from office under conditions 
other than those mentioned in Article 14.2 of the Statute even if they have not yet 
taken up their duties. As the conditions under which a Governor may be relieved from 
office are autonomous concepts of Union law, their application and interpretation do 
not depend on national contexts.45 Ultimately, it is for the Court of Justice of the 
European Union, in accordance with the powers conferred on it by the second 
subparagraph of Article 14.2 of the Statute, to verify that a decision taken to relieve a 
Governor of a national central bank from office is justified by sufficient indications that 
they have engaged in serious misconduct capable of justifying such a measure.46 
Security of tenure and grounds for relieving from office of members of NCBs’ 
decision-making bodies, other than Governors, who are involved in the 
performance of ESCB-related tasks 
Applying the same rules for the security of tenure and grounds for relieving of 
Governors from office to other members of the decision-making bodies of NCBs 
involved in the performance of ESCB-related tasks will also safeguard the personal 
 
41  Opinion CON/2018/23. 
42  Opinion CON/2012/89. 
43  Opinions CON/2018/17, CON/2019/19 and CON/2019/36. 
44  Opinion CON/2018/53. 
45  See Opinion CON/2019/36 and the Opinion of Advocate General Kokott in Rimšēvičs v Latvia, C-202/18, 
EU:C:2018:1030, paragraph 77. 
46  See Rimšēvičs v Latvia, C-202/18, EU:C:2019:139, paragraph 96. 
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independence of those persons.47 The provisions of Article 14.2 of the Statute are not 
restricted to the security of tenure of office to Governors, and Article 130 of the Treaty 
and Article 7 of the Statute refer to “members of the decision-making bodies” of NCBs,
rather than to Governors specifically. This applies in particular where a Governor is 
“first among equals” with colleagues with equivalent voting rights or where such other 
members are involved in the performance of ESCB-related tasks. 
Right of judicial review 
Members of the NCBs’ decision-making bodies must have the right to submit any 
decision to relieve them from their office to an independent court of law, in order to limit 
the potential for political discretion in evaluating the grounds for such a decision. 
Article 14.2 of the Statute stipulates that NCB Governors who have been dismissed 
from office may refer such a decision to the Court of Justice of the European Union. 
National legislation should either refer to the Statute or remain silent on the right to 
refer such a decision to the Court of Justice of the European Union (as Article 14.2 of 
the Statute is directly applicable). The Court of Justice of the European Union has the 
power to annul the national measure of dismissal if it is found to be contrary to Union 
law.48 
National legislation should also provide for a right of review by the national courts of a 
decision to dismiss any other member of the decision-making bodies of the NCB 
involved in the performance of ESCB-related tasks. This right can either be a matter of 
general law or can it take the form of a specific provision. Even though this right may 
be available under the general law, for reasons of legal certainty it could be advisable 
to provide specifically for such a right of review. 
Safeguards against conflicts of interest 
Personal independence also entails ensuring that no conflict of interest arises 
between the duties of members of NCB decision-making bodies involved in the 
performance of ESCB-related tasks in relation to their respective NCBs (and of 
Governors in relation to the ECB) and any other functions which such members of 
decision-making bodies may have and which may jeopardise their personal 
independence.49 As a matter of principle, membership of a decision-making body 
involved in the performance of ESCB-related tasks is incompatible with the exercise of 
other functions that might create a conflict of interest. In particular, members of such 
decision-making bodies may not hold an office or have an interest that may influence 
their activities, whether through office in the executive or legislative branches of the 
state or in regional or local administrations, or through involvement in a business 
organisation. Particular care should be taken to prevent potential conflicts of interest 
on the part of non-executive members of decision-making bodies. 
47  Opinions CON/2004/35, CON/2005/26, CON/2006/32, CON/2006/44, CON/2007/6, CON/2019/19 and 
CON/2019/24.
48  See Rimšēvičs v Latvia, C-202/18, EU:C:2019:139, paragraph 76. 
49  In this regard, Member States are free to set the conditions required for the appointment of the members
of the decision-making bodies of their NCBs, provided that they do not conflict with the features of central
bank independence flowing from the Treaties. See Opinions CON/2018/23, CON/2020/19 and 
CON/2021/9.
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Financial independence 
The overall independence of an NCB would be jeopardised if it could not 
autonomously avail itself of sufficient financial resources to fulfil its mandate, i.e. to 
perform the ESCB-related tasks required of it under the Treaty and the Statute.50 
Member States may not put their NCBs in a position where they have insufficient 
financial resources and inadequate net equity51 to carry out their ESCB or 
Eurosystem-related tasks, as applicable. It should be noted that Articles 28.1 and 30.4 
of the Statute provide for the possibility of the ECB making further calls on the NCBs to 
contribute to the ECB’s capital and to make further transfers of foreign reserves.52 
Moreover, Article 33.2 of the Statute provides53 that, in the event of a loss incurred by 
the ECB which cannot be fully offset against the general reserve fund, the ECB’s 
Governing Council may decide to offset the remaining loss against the monetary 
income of the relevant financial year in proportion to and up to the amounts allocated 
to the NCBs. The principle of financial independence means that compliance with 
these provisions requires an NCB to be able to perform its functions unimpaired. 
Additionally, the principle of financial independence requires an NCB to have sufficient 
means not only to perform its ESCB-related tasks but also its national tasks (e.g. 
supervision of the financial sector, financing its administration and own operations, 
provision of Emergency Liquidity Assistance54). 
For all the reasons mentioned above, financial independence also implies that an NCB 
should always be sufficiently capitalised. In particular, any situation should be avoided 
whereby for a prolonged period of time an NCB’s net equity is below the level of its 
statutory capital or is even negative, including where losses beyond the level of capital 
and the reserves are carried over.5556 Any such situation may negatively impact on the 
NCB’s ability to perform its ESCB-related tasks but also its national tasks. Moreover, 
such a situation may affect the credibility of the Eurosystem’s monetary policy. 
Therefore, the event of an NCB’s net equity becoming less than its statutory capital or 
even negative would require that the respective Member State provides the NCB with 
an appropriate amount of capital at least up to the level of the statutory capital within a 
reasonable period of time so as to comply with the principle of financial independence. 
As concerns the ECB, the relevance of this issue has already been recognised by the 
Council by adopting Council Regulation (EC) No 1009/2000 of 8 May 2000 concerning 
capital increases of the European Central Bank.57 It enabled the Governing Council of 
the ECB to decide on an actual increase of the ECB’s capital to sustain the adequacy 
 
50  Opinion CON/2021/7. 
51  Opinions CON/2014/24, CON/2014/27, CON/2014/56 and CON/2017/17. 
52  Article 30.4 of the Statute only applies within the Eurosystem. 
53  Article 33.2 of the Statute only applies within the Eurosystem. 
54  Opinions CON/2016/55, CON/2020/11 and CON/2020/13. 
55  Opinion CON/2020/13. 
56  Opinion CON/2018/17. 
57  OJ L 115, 16.5.2000, p. 1. 
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of the capital base to support the operations of the ECB;58 NCBs should be financially 
able to respond to such ECB decision. 
The concept of financial independence should be assessed from the perspective of 
whether any third party is able to exercise either direct or indirect influence not only 
over an NCB’s tasks but also over its ability to fulfil its mandate, both operationally in 
terms of manpower, and financially in terms of appropriate financial resources. The 
aspects of financial independence set out below are particularly relevant in this 
respect.59 These are the features of financial independence where NCBs are most 
vulnerable to outside influence. 
Determination of budget 
If a third party has the power to determine or influence an NCB’s budget, this is 
incompatible with financial independence unless the law provides a safeguard clause 
so that such a power is without prejudice to the financial means necessary for carrying 
out the NCB’s ESCB-related tasks.60 
The accounting rules 
The accounts should be drawn up either in accordance with general accounting rules 
or in accordance with rules specified by an NCB’s decision-making bodies. If, instead, 
such rules are specified by third parties, the rules must at least take into account what 
has been proposed by the NCB’s decision-making bodies. 
The annual accounts should be adopted by the NCB’s decision-making bodies, 
assisted by independent accountants, and may be subject to ex post approval by third 
parties (e.g. the government or parliament). The NCB’s decision-making bodies 
should be able to decide on the calculation of the profits independently and 
professionally. 
Where an NCB’s operations are subject to the control of a state audit office or similar 
body charged with controlling the use of public finances, the scope of the control 
should be clearly defined by the legal framework,61 should be without prejudice to the 
activities of the NCB’s independent external auditors62 and further, in line with the 
principle of institutional independence, it should comply with the prohibition on giving 
instructions to an NCB and its decision-making bodies and should not interfere with 
the NCB’s ESCB-related tasks.63 The state audit should be done on a non-political, 
independent and purely professional basis.64 
58  Decision ECB/2010/26 of 13 December 2010 on the increase of the ECB’s capital (OJ L 11, 15.1.2011,
p. 53).
59  The main formative ECB opinions in this area are: Opinions CON/2002/16, CON/2003/22, CON/2003/27, 
CON/2004/1, CON/2006/38, CON/2006/47, CON/2007/8, CON/2008/13, CON/2008/68 and 
CON/2009/32.
60  Opinion CON/2019/12. 
61  Opinion CON/2019/19. 
62  For the activities of the independent external auditors of the NCBs see Article 27.1 of the Statute. 
63  Opinions CON/2011/9, CON/2011/53, CON/2015/57 and CON/2018/17. 
64  Opinions CON/2015/8, CON/2015/57, CON/2016/24, CON/2016/59 and CON/2018/17. 
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Distribution of profits, NCBs’ capital and financial provisions 
With regard to profit allocation, an NCB’s statutes may prescribe how its profits are to 
be allocated. In the absence of such provisions, decisions on the allocation of profits 
should be taken by the NCB’s decision-making bodies on professional grounds, and 
should not be subject to the discretion of third parties unless there is an express 
safeguard clause stating that this is without prejudice to the financial means necessary 
for carrying out the NCB’s ESCB-related tasks as well as national tasks.65 
Profits may be distributed to the State budget only after any accumulated losses from 
previous years have been covered66 and financial provisions deemed necessary to 
safeguard the real value of the NCB’s capital and assets have been created. 
Temporary or ad hoc legislative measures amounting to instructions to the NCBs in 
relation to the distribution of their profits are not permissible.67 Similarly, a tax on an 
NCB’s unrealised capital gains would also impair the principle of financial 
independence.68 
A Member State may not impose reductions of capital on an NCB without the ex ante 
agreement of the NCB’s decision-making bodies, which must aim to ensure that it 
retains sufficient financial means to fulfil its mandate under Article 127(2) of the Treaty 
and the Statute as a member of the ESCB. For the same reason, any amendment to 
the profit distribution rules of an NCB should only be initiated and decided in close 
cooperation with the NCB, which is best placed to assess its required level of reserve 
capital.69 As regards financial provisions or buffers, NCBs must be free to 
independently create financial provisions to safeguard the real value of their capital 
and assets. Member States may also not hamper NCBs from building up their reserve 
capital to a level which is necessary for a member of the ESCB to fulfil its tasks.70 
Financial liability for supervisory authorities 
Most Member States place their financial supervisory authorities within their NCB. 
This is unproblematic if such authorities are subject to the NCB’s independent 
decision-making. However, if the law provides for separate decision-making by such 
supervisory authorities, it is important to ensure that decisions adopted by them do not 
endanger the finances of the NCB as a whole. In such cases, national legislation 
should enable the NCB to have ultimate control over any decision by the supervisory 
authorities that could affect an NCB’s independence, in particular its financial 
independence.71 
Autonomy in staff matters 
Member States may not impair an NCB’s ability to employ and retain the qualified staff 
necessary for the NCB to perform independently the tasks conferred on it by the 
 
65  Opinions CON/2017/17 and CON/2018/17. 
66  Opinions CON/2009/85 and CON/2017/17. 
67  Opinions CON/2009/26 and CON/2013/15. 
68  Opinions CON/2009/59 and CON/2009/63. 
69  Opinions CON/2009/53, CON/2009/83 and CON/2019/21. 
70  Opinions CON/2009/26,CON/2012/69 and CON/2020/13. 
71  Opinion CON/2021/7. 
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Treaty and the Statute.72 Also, an NCB may not be put into a position where it has 
limited control or no control over its staff, or where the government of a Member State 
can influence its policy on staff matters.73 Any amendment to the legislative provisions 
on the remuneration for members of an NCB’s decision-making bodies and its 
employees should be decided in close and effective cooperation with the NCB,74 
taking due account of its views, to ensure the ongoing ability of the NCB to 
independently carry out its tasks.75 Autonomy in staff matters extends to issues 
relating to staff pensions. Further, amendments that lead to reductions in the 
remuneration for an NCB's staff should not interfere with that NCB’s powers to 
administer its own financial resources, including the funds resulting from any reduction 
in salaries that it pays.76 
Ownership and property rights 
Rights of third parties to intervene or to issue instructions to an NCB in relation to the 
property held by an NCB are incompatible with the principle of financial independence. 
2.2.4 Confidentiality
The obligation of professional secrecy for ECB and NCB staff as well as for the 
members of the ECB and NCB governing bodies under Article 37 of the Statute may 
give rise to similar provisions in NCBs’ statutes or in the Member States’ legislation. 
The primacy of Union law and rules adopted thereunder also means that national laws 
on access by third parties to documents should comply with relevant Union law 
provisions, including Article 37 of the Statute, and may not lead to infringements of the 
ESCB’s confidentiality regime.77 The access of a state audit office or similar body to 
an NCB’s confidential information and documents must be limited to what is necessary 
for the performance of the statutory tasks of the body that receives the information and 
must be without prejudice to the ESCB’s independence and the ESCB’s confidentiality
regime to which the members of NCBs’ decision-making bodies and staff are 
subject.78 NCBs should ensure that such bodies protect the confidentiality of 
information and documents disclosed at a level corresponding to that applied by the 
NCBs. 
2.2.5 Prohibition on monetary financing and privileged access
On the monetary financing prohibition and the prohibition on privileged access, the 
national legislation of the Member States that joined the EU in 2004, 2007 or 2013 had 
to be adapted to comply with the relevant provisions of the Treaty and the Statute and 
72  Opinion CON/2019/19. 
73  Opinions CON/2008/9, CON/2008/10 and CON/2012/89. 
74  Opinion CON/2019/19. 
75  Opinions CON/2010/42, CON/2010/51, CON/2010/56, CON/2010/69, CON/2010/80, CON/2011/104,
CON/2011/106, CON/2012/6, CON/2012/86 and CON/2014/7.
76  Opinion CON/2014/38. 
77  Opinion CON/2021/16. 
78  Opinions CON/2015/8 and CON/2015/57. 
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be in force on 1 May 2004, 1 January 2007 and 1 July 2013 respectively. Sweden had 
to bring the necessary adaptations into force by 1 January 1995. 
Prohibition on monetary financing 
Article 123(1) of the Treaty prohibits overdraft facilities or any other type of credit 
facility with the ECB or with the NCBs in favour of EU institutions, bodies, offices or 
agencies, central governments, regional, local or other public authorities, other bodies 
governed by public law, or public undertakings of Member States. 
It also prohibits the purchase directly from these public sector entities by the ECB or 
NCBs of debt instruments. The Treaty contains one exemption from this monetary 
financing prohibition: it does not apply to publicly-owned credit institutions which, in 
the context of the supply of reserves by central banks, must be given the same 
treatment as private credit institutions (Article 123(2) of the Treaty). Moreover, the 
ECB and the NCBs may act as fiscal agents for the public sector bodies referred to 
above (Article 21.2 of the Statute). The precise scope of application of the monetary 
financing prohibition is further clarified by Council Regulation (EC) No 3603/93 of 13 
December 1993 specifying definitions for the application of the prohibitions referred to 
in Articles 104 and 104b (1) of the Treaty,79 according to which the prohibition includes 
any financing of the public sector’s obligations vis-à-vis third parties. 
The monetary financing prohibition is of essential importance to ensuring that the 
primary objective of monetary policy (namely to maintain price stability) is not 
impeded. Furthermore, central bank financing of the public sector lessens the 
pressure for fiscal discipline. Therefore the prohibition must be interpreted extensively 
in order to ensure its strict application, subject only to the limited exemptions 
contained in Article 123(2) of the Treaty and Regulation (EC) No 3603/93. Thus, even 
if Article 123(1) of the Treaty refers specifically to ‘credit facilities’, i.e. with the 
obligation to repay the funds, the prohibition applies a fortiori to other forms of funding, 
i.e. without the obligation to repay. 
The ECB’s general stance on the compatibility of national legislation with the 
prohibition has primarily been developed within the framework of consultations of the 
ECB by Member States on draft national legislation under Articles 127(4) and 282(5) 
of the Treaty.80 
National legislation referring to the monetary financing prohibition 
In cases where national legislative provisions mirror Article 123 of the Treaty or 
Regulation (EC) No 3603/93, they may not narrow the scope of application of the 
monetary financing prohibition or extend the exemptions available under EU law. For 
example, national legislation providing for the financing by the NCB of a Member 
State’s financial commitments to international financial institutions or to third countries 
 
79  OJ L 332, 31.12.1993, p. 1. Articles 104 and 104b(1) of the Treaty establishing the European Community 
are now Articles 123 and 125(1) of the Treaty on the Functioning of the European Union. 
80  See Convergence Report 2008, footnote 13, containing a list of formative EMI/ECB opinions in this area 
adopted between May 1995 and March 2008. 
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is, in principle, incompatible with the monetary financing prohibition. As an exemption, 
Regulation (EC) No 3603/93 allows for the financing by the NCBs of obligations falling 
upon the public sector vis-à-vis the IMF provided that it results in foreign claims which 
have all the characteristics of reserve assets.81 The relevant characteristics that 
determine the reserve asset quality of the claims concern their availability on demand 
to meet balance of payments financing needs and other related purposes, which 
implies that the credit quality and liquidity of the claims must be ensured.82 
Financing of the public sector or of public sector obligations to third parties 
National legislation may not require an NCB to finance either the performance of 
functions by other public sector bodies or the public sector’s obligations vis-à-vis third 
parties. This is equally applicable to the conferral of new tasks upon NCBs. For this 
purpose, it is necessary to assess on a case-by-case basis, whether the task to be 
conferred upon an NCB qualifies as a central bank task or a government task, i.e. a 
task within the responsibility of the government.83 In other words, sufficient 
safeguards must be in place to ensure that no circumventions of the objective of the 
monetary financing prohibition occur. The Governing Council has endorsed criteria for 
determining what may be seen as falling within the scope of a public sector’s 
obligation within the meaning of Regulation (EC) No 3603/93 or, in other words, what 
constitutes a government task.84 To ensure compliance with the monetary financing 
prohibition, a new task entrusted to an NCB must be fully and adequately remunerated 
if it is: (a) not a central bank task or an action that facilitates the performance of a 
central bank task; or (b) linked to a government task and performed in the 
government's interest.85 Important criteria for qualifying a new task as a government 
task are: (a) its atypical nature; (b) the fact that it is discharged on behalf of and in the 
exclusive interest of the government; and (c) its impact on the institutional, financial 
and personal independence of the NCB. In particular, a task may be qualified as a 
government task if the performance of the new task meets one of the following 
conditions: (a) it creates inadequately addressed conflicts of interests with existing 
central bank tasks; (b) it is disproportionate to the NCB's financial or organisational 
capacity; (c) it does not fit into the NCB's institutional set-up; (d) it harbours substantial 
financial risks; and (e) it exposes the members of the NCB decision-making bodies to 
political risks that are disproportionate and that may also negatively impact on them in 
terms of their personal independence.86 
Some of the new tasks conferred on NCBs that the ECB considered to be government 
tasks are: (a) tasks relating to financing resolution funds or financial arrangements as 
well as deposit guarantee or investor compensation schemes;87 (b) tasks relating to 
81  Recital 14 and Article 7 of Regulation (EC) No 3603/93. See, for example, Opinions CON/2016/21,
CON/2017/4, CON/2020/37 and CON/2021/23.
82  See Opinion CON/2021/39. 
83  Such an assessment may not be necessary if the task to be conferred on the NCB only complements an 
existing function of the NCB and does not qualify as a genuinely new task.
84  See, for example, Opinion CON/2016/54. 
85  Opinions CON/2011/30, CON/2015/36, CON/2015/46 and Opinion CON/2021/29. 
86  See, for example, Opinion CON/2015/22. 
87  See the section entitled ‘Financial support for resolution funds or financial arrangements and deposit
insurance or investor compensation schemes’ for some specific cases.
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the establishment of a central register of bank account numbers;88 (c) tasks of a credit 
mediator;89 (d) tasks relating to the collection, maintenance and processing of data 
that supports the calculation of insurance premium transfers;90 (e) tasks relating to the 
protection of competition in the mortgage loan market;91 (f) tasks relating to the 
provision of resources to bodies that are independent of the NCBs and operate as an 
extension of the government;92 (g) tasks of an information authority for the purposes 
of facilitating cross-border debt recovery in civil and commercial matters;93 (h) tasks 
relating to the establishment of an insurance claims database;94 (i) tasks related to 
carrying out scientific analyses on behalf and for the benefit of government entities;95 
and (j) tasks relating to national defence preparedness going beyond the internal 
contingency planning tasks of a central bank.96 By contrast, central bank tasks may 
be, inter alia, supervisory tasks97 or tasks relating to those supervisory tasks, such as 
those relating to consumer protection in the area of financial services98 or compliance 
of credit institutions with loan restructuring requirements,99 supervision over 
credit-acquiring companies100 or financial leasing companies,101 supervision of 
consumer credit providers and intermediaries,102 licensing and supervision of 
microcredit providers,103 supervision of credit reference agencies,104 supervision of 
administrators of interest rate benchmarks,105 supervisory tasks to ensure compliance 
with Union legislation in the field of investment services and products,106 tasks relating 
to the oversight of payment schemes,107 tasks relating to the supervision of rules 
related to the Single Euro Payments Area,108 tasks relating to supervision of the 
issuance of covered bonds by credit institutions,109 tasks relating to the application 
and enforcement of Union legislation concerning payment accounts,110 administrative 
resolution tasks or certain tasks relating to the management of deposit guarantee or 
 
88  Opinions CON/2015/36, CON/2015/46, CON/2016/49, CON/2016/57 and CON/2018/57. 
89  Opinion CON/2015/12. 
90  Opinion CON/2016/45. 
91  Opinion CON/2016/54. 
92  Opinion CON/2017/19. 
93  Opinion CON/2017/32. 
94  Opinion CON/2018/43. 
95  Opinion CON/2021/29. 
96  Opinions CON/2020/2 and CON/2021/35. 
97  Opinion CON/2021/9. 
98  Opinions CON/2007/29, CON/2016/31, CON/2017/3 and CON/2017/12. 
99  Opinion CON/2019/27. 
100  Opinion CON/2015/45. 
101  Opinion CON/2016/31. 
102  Opinions CON/2015/54, CON/2016/34 and CON/2017/3. 
103  Opinion CON/2019/07. 
104  Opinion CON/2019/02. 
105  Opinion CON/2017/52. 
106  Opinions CON/2018/2 and CON/2018/5. 
107  Opinions CON/2016/38 and CON/2020/23. 
108  Opinion CON/2021/34. 
109  Opinion CON/2021/34. 
110  Opinion CON/2017/2. 
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investor protection schemes111, or tasks relating to the operation and management of 
credit registers.112 
In addition, no bridge financing may be provided by an NCB to enable a Member State 
to honour its obligations in respect of State guarantees of bank liabilities.113 Also, the 
distribution of central bank profits which have not been fully realised, accounted for 
and audited does not comply with the monetary financing prohibition. To comply with 
the monetary financing prohibition, the amount distributed to the State budget 
pursuant to the applicable profit distribution rules cannot be paid, even partially, from 
the NCB’s reserve capital. Therefore, profit distribution rules should leave unaffected 
the NCB’s reserve capital. Moreover, when NCB assets are transferred to the State, 
they must be remunerated at market value and the transfer should take place at the 
same time as the remuneration.114 
Similarly, intervention in the performance of other Eurosystem tasks, such as the 
management of foreign reserves, by introducing taxation of theoretical and unrealised 
capital gains is not permitted since this would result in a form of central bank credit to 
the public sector through the advanced distribution of future and uncertain profits.115 
Assumption of public sector liabilities 
National legislation which requires an NCB to take over the liabilities of a previously 
independent public body, as a result of a national reorganisation of certain tasks and 
duties (for example, in the context of a transfer to the NCB of certain supervisory tasks 
previously carried out by the state or independent public authorities or bodies), without 
fully insulating the NCB from all financial obligations resulting from the prior activities 
of such a body, would be incompatible with the monetary financing prohibition.116 
Along the same lines, national legislation that requires an NCB to obtain approval from 
the government prior to taking resolution actions under a broad range of 
circumstances, but which does not limit the NCB's liability to its own administrative 
acts, would be incompatible with the monetary financing prohibition.117 In the same 
vein, national legislation that requires an NCB to pay compensation for damages, to 
the extent that it results in that NCB assuming the liability of the state, would not be in 
line with the monetary financing prohibition.118 
Financial support for credit and/or financial institutions 
National legislation which provides for financing by an NCB, granted independently 
and at their full discretion, of credit institutions other than in connection with central 
banking tasks (such as monetary policy, payment systems or temporary liquidity 
111  Opinion CON/2021/9. This is further qualified under the sub-section below on ‘Financial support for 
resolution funds or financial arrangements and deposit insurance or investor compensation schemes’.
112  Opinion CON/2016/42. 
113  Opinion CON/2012/4. 
114  Opinions CON/2011/91 and CON/2011/99. 
115  Opinions CON/2009/59 and CON/2009/63. 
116  Opinion CON/2013/56. 
117  Opinion CON/2015/22. 
118  Opinions CON/2019/20 and CON/2021/7. 
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support operations), in particular the support of insolvent credit and/or other financial 
institutions, would be incompatible with the monetary financing prohibition. 
This applies, in particular, to the support of insolvent credit institutions. The rationale is 
that by financing an insolvent credit institution, an NCB would be assuming a 
government task.119 The same concerns apply to the Eurosystem financing of a credit 
institution which has been recapitalised to restore its solvency by way of a direct 
placement of state-issued debt instruments where no alternative market-based 
funding sources exist (hereinafter “recapitalisation bonds”), and where such bonds are 
to be used as collateral. In such case of a state recapitalisation of a credit institution by 
way of direct placement of recapitalisation bonds, the subsequent use of the 
recapitalisation bonds as collateral in central bank liquidity operations raises monetary 
financing concerns.120 Emergency liquidity assistance, granted by an NCB 
independently and at its full discretion to a solvent credit institution on the basis of 
collateral security in the form of a State guarantee, has to meet the following criteria: (i) 
it must be ensured that the credit provided by the NCB is as short term as possible; (ii) 
there must be systemic stability aspects at stake; (iii) there must be no doubts as to the 
legal validity and enforceability of the State guarantee under applicable national law; 
and (iv) there must be no doubts as to the economic adequacy of the State guarantee, 
which should cover both principal and interest on the loans.121 
To this end, inserting references to Article 123 of the Treaty in national legislation 
should be considered. 
Financial support for resolution funds or financial arrangements and deposit 
insurance or investor compensation schemes 
The financing by an NCB of a resolution fund or a deposit guarantee fund that qualifies 
as a ‘body governed by public law’ within the meaning of Article 123(1) of the Treaty is 
not compatible with the monetary financing prohibition. A body is ‘governed by public 
law’ if it has all of the following characteristics: (a) it is established for the specific 
purpose of meeting needs in the general interest, not having an industrial or 
commercial character; (b) it has legal personality; and (c) it is closely dependent on the 
public sector entities referred to in Article 123(1) of the Treaty. A close dependence on 
those public sector entities is presumed when a body is financed, for the most part, by 
them; or is subject to management supervision by them; or has an administrative, 
managerial or supervisory board, more than half of whose members are appointed by 
them.122 
While administrative resolution tasks are generally considered as related to those 
referred to in Article 127(5) of the Treaty, and even if the financing is not provided to a 
‘body governed by public law’, the financing of any resolution fund or financial 
arrangement is not in line with the monetary financing prohibition.123 Where an NCB 
 
119  Opinion CON/2013/5. 
120  Opinions CON/2012/50, CON/2012/64, and CON/2012/71. 
121  Opinion CON/2012/4, footnote 42 referring to further relevant Opinions in this field. See also Opinions 
CON/2016/55 and CON/2017/1. 
122  Opinions CON/2020/24 and CON/2021/17. 
123  Opinions CON/2015/22, CON/2016/28 and CON/2019/16. 
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acts as resolution authority, it should not, under any circumstances, assume or finance 
any obligation of either a bridge institution or an asset management vehicle.124 To this 
end, national legislation should clarify that the NCB will not assume or finance any of 
these entities’ obligations.125 
The Deposit Guarantee Schemes Directive126 and the Investor Compensation 
Schemes Directive127 provide that the costs of financing deposit guarantee schemes 
and investor compensation schemes must be borne, respectively, by credit institutions 
and investment firms themselves. With the exception of financing a ‘body governed by
public law’, national legislation which provides for the financing by an NCB of a 
national deposit insurance scheme for credit institutions or a national investor 
compensation scheme for investment firms would be compatible with the monetary 
financing prohibition only if it were short term, addressed urgent situations, systemic 
stability aspects were at stake, and decisions were at the NCB’s discretion.128 To this 
end, inserting references to Article 123 of the Treaty in national legislation should be 
considered. When exercising its discretion to grant a loan, the NCB must ensure that it 
is not de facto taking over a government task.129 In particular, central bank support for 
deposit guarantee schemes should not amount to a systematic pre-funding 
operation.130 
Fiscal agency function 
Article 21.2 of the Statute establishes that the ‘ECB and the national central banks 
may act as fiscal agents’ for ‘Union institutions, bodies, offices or agencies, central 
governments, regional local or other public authorities, other bodies governed by 
public law, or public undertakings of Member States.’ The purpose of Article 21.2 of 
the Statute is, following transfer of the monetary policy competence to the 
Eurosystem, to clarify that NCBs may continue to provide the fiscal agent service 
traditionally provided to governments and other public entities without infringing the 
monetary financing prohibition. In addition, Regulation (EC) No 3603/93 establishes a 
number of explicit and narrowly drafted exemptions from the monetary financing 
prohibition relating to the fiscal agency function, as follows: (i) intra-day credits to the 
public sector are permitted provided that they remain limited to the day and that no 
extension is possible;131 (ii) crediting the public sector’s account with cheques issued
by third parties before the drawee bank has been debited is permitted if a fixed period 
of time corresponding to the normal period for the collection of cheques by the NCB 
concerned has elapsed since receipt of the cheque, provided that any float which may 
arise is exceptional, is of a small amount and averages out in the short term;132 and 
124  Opinions CON/2011/103, CON/2012/99, CON/2015/3 and CON/2015/22. 
125  Opinions CON/2015/33, CON/2015/35 and CON/2016/60. 
126  Recital 27 of Directive 2014/49/EU of the European Parliament and of the Council of 16 April 2014 on
deposit guarantee schemes (OJ L 173, 12.6.2014, p. 149).
127  Recital 23 of Directive 97/9/EC of the European Parliament and of the Council of 3 March 1997 on
investor-compensation schemes (OJ L 84, 26.3.1997, p. 22). 
128  Opinions CON/2020/24 and CON/2021/17. 
129  Opinions CON/2011/83 and CON/2015/52. 
130  Opinion CON/2011/84. 
131  Article 4 of Regulation (EC) No 3603/93 and Opinion CON/2013/2. 
132  Article 5 of Regulation (EC) No 3603/93. 
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(iii) the holding of coins issued by and credited to the public sector is permitted where 
the amount of such assets remains at less than 10 % of coins in circulation.133 
National legislation on the fiscal agency function should be compatible with EU law in 
general, and with the monetary financing prohibition in particular.134 Taking into 
account the express recognition in Article 21.2 of the Statute of the provision of fiscal 
agency services, which is a legitimate function traditionally performed by NCBs, the 
provision by central banks of fiscal agency services complies with the monetary 
financing prohibition, provided that such services remain within the field of the fiscal 
agency function and do not constitute central bank financing of public sector 
obligations vis-à-vis third parties or central bank crediting of the public sector outside 
the narrowly defined exceptions specified in Regulation (EC) No 3603/93.135 National 
legislation that enables an NCB to hold government deposits and to service 
government accounts does not raise concerns about compliance with the monetary 
financing prohibition as long as such provisions do not enable the extension of credit, 
including overnight overdrafts. However, there would be a concern about compliance 
with the monetary financing prohibition if, for example, national legislation were to 
enable the remuneration of deposits or current account balances above, rather than at 
or below, market rates. Remuneration that is above market rates constitutes a de facto 
credit, contrary to the objective of the prohibition on monetary financing, and might 
therefore undermine the prohibition’s objectives. It is essential for any remuneration of 
an account to reflect market parameters and it is particularly important to correlate the 
remuneration rate of the deposits with their maturity.136 Moreover, the provision 
without remuneration by an NCB of fiscal agent services does not raise monetary 
financing concerns, provided they are core fiscal agent services.137 
Prohibition on privileged access 
Article 124 of the Treaty provides that ‘[a]ny measure, not based on prudential 
considerations, establishing privileged access by Union institutions, bodies, offices or 
agencies, central governments, regional, local or other public authorities, other bodies 
governed by public law, or public undertakings of Member States to financial 
institutions, shall be prohibited.’ As with the monetary financing prohibition, the 
prohibition of privileged access aims to encourage the Member States to follow a 
sound budgetary policy, not allowing monetary financing of public deficits or privileged 
access by public authorities to the financial markets to lead to excessively high levels 
of debt or excessive Member State deficits.138 
 
133  Article 6 of Regulation (EC) No 3603/93. 
134  Opinion CON/2013/3. 
135  Opinions CON/2009/23, CON/2009/67 and CON/2012/9. 
136  See, among others, Opinions CON/2010/54, CON/2010/55 and CON/2013/62. 
137  Opinion CON/2012/9. 
138  See, to that effect, Smaranda Bara and Others v Casa Naţională de Asigurări de Sănătate and Others, 
C-201/14, EU:C:2015:638, paragraph 22; and Peter Gauweiler and Others v Deutscher Bundestag, 
C-62/14, EU:C:2015:400, paragraph 100. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 235 – 
Convergence Report, June 2022 37 
Under Article 1(1) of Council Regulation (EC) No 3604/93,139 privileged access is 
understood as any law, regulation or other binding legal instrument adopted in the 
exercise of public authority which: (a) obliges financial institutions to acquire or to hold 
liabilities of EU institutions or bodies, central governments, regional, local or other 
public authorities, other bodies governed by public law or public undertakings of 
Member States, or (b) confers tax advantages that only benefit financial institutions or 
financial advantages that do not comply with the principles of a market economy, in 
order to encourage those institutions to acquire or hold such liabilities. 
As public authorities, NCBs may not take measures granting privileged access to 
financial institutions by the public sector if such measures are not based on prudential 
considerations. Furthermore, the rules on the mobilisation or pledging of debt 
instruments enacted by the NCBs must not be used as a means of circumventing the 
prohibition on privileged access.140 Member States’ legislation in this area may not 
establish such privileged access. 
Article 2 of Regulation (EC) No 3604/93 defines ‘prudential considerations’ as those 
which underlie national laws, regulations or administrative actions based on, or 
consistent with, EU law and designed to promote the soundness of financial 
institutions so as to strengthen the stability of the financial system as a whole and the 
protection of the customers of those institutions. Prudential considerations seek to 
ensure that banks remain solvent with regard to their depositors.141 In the area of 
prudential supervision, EU secondary legislation has established a number of 
requirements to ensure the soundness of credit institutions.142 A ‘credit institution’ has
been defined as an undertaking whose business is to receive deposits or other 
repayable funds from the public and to grant credits for its own account.143 
Additionally, credit institutions, commonly referred to as ‘banks’, require an 
authorisation by a competent Member State authority to provide services.144 
Although minimum reserves might be seen as a part of prudential requirements, they 
are part of an NCB’s operational framework and used as a monetary policy tool in 
most economies, including in the euro area.145 In this respect, paragraph 2 of Annex I 
to Guideline ECB/2014/60146 states that the Eurosystem’s minimum reserve system
primarily pursues the aims of stabilising the money market interest rates and creating 
139  Council Regulation (EC) No 3604/93 of 13 December 1993 specifying definitions for the application of the 
prohibition of privileged access referred to in Article 104a of the Treaty [establishing the European 
Community] (OJ L 332, 31.12.1993, p. 4). Article 104a of the Treaty establishing the European 
Community is now Article 124 of the Treaty.
140  Article 3(2) of and recital 10 of Regulation (EC) No 3604/93. 
141  Opinion of Advocate General Elmer in Société civile immobilière Parodi v Banque H. Albert de Bary et
Cie., C-222/95, EU:C:1997:345, paragraph 24. 
142  Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on
prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 
648/2012 (OJ L 176, 27.06.2013, p. 1) and Directive 2013/36/EU of the European Parliament and of the 
Council of 26 June 2013 on access to the activity of credit institutions and the prudential supervision of 
credit institutions and investment firms, amending Directive 2002/87/EC and repealing Directives 
2006/48/EC and 2006/49/EC (OJ L 176, 27.06.2013, p. 338).
143  Article 4(1)(1) of Regulation (EU) No 575/2013. 
144  Article 8 of Directive 2013/36/EU. 
145  This is supported by Article 3(2) and recital 9 of Regulation (EC) No 3604/93. 
146  Guideline (EU) 2015/510 of the European Central Bank of 19 December 2014 on the implementation of
the Eurosystem monetary policy framework (General Documentation Guideline) (ECB/2014/60) (OJ L 
91, 2.4.2015, p. 3).
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(or enlarging) a structural liquidity shortage.147 The ECB requires credit institutions 
established in the euro area to hold the required minimum reserves (in the form of 
deposits) on account with their NCB.148 
This report focuses on the compatibility both of national legislation or rules adopted by 
NCBs and of the NCBs’ statutes with the Treaty prohibition on privileged access. 
However, this report is without prejudice to an assessment of whether laws, 
regulations, rules or administrative acts in Member States are used under the cover of 
prudential considerations as a means of circumventing the prohibition on privileged 
access. Such an assessment is beyond the scope of this report. 
2.2.6 Single spelling of the euro 
Article 3(4) of the Treaty on European Union lays down that the ‘Union shall establish 
an economic and monetary union whose currency is the euro’. In the texts of the 
Treaties in all the authentic languages written using the Roman alphabet, the euro is 
consistently identified in the nominative singular case as ‘euro’. In the Greek alphabet 
text, the euro is spelled ‘ευρώ’ and in the Cyrillic alphabet text the euro is spelled 
‘евро’.149 Consistent with this, Council Regulation (EC) No 974/98 of 3 May 1998 on 
the introduction of the euro150 makes it clear that the name of the single currency must 
be the same in all the official languages of the EU, taking into account the existence of 
different alphabets. The Treaties thus require a single spelling of the word ‘euro’ in the 
nominative singular case in all EU and national legislative provisions, taking into 
account the existence of different alphabets. 
In view of the exclusive competence of the EU to determine the name of the single 
currency, any deviations from this rule are incompatible with the Treaties and should 
be eliminated.151 While this principle applies to all national legislation, the assessment 
in the country chapters focuses on the NCBs’ statutes and the euro changeover laws. 
 
147  The higher the reserve requirement is set, the fewer funds banks will have to loan out, leading to lower 
money creation. 
148  See: Article 19 of the Statute; Council Regulation (EC) No 2531/98 of 23 November 1998 concerning the 
application of minimum reserves by the European Central Bank (OJ L 318, 27.11.1998, p. 1); Regulation 
(EC) No 1745/2003 of the European Central Bank of 12 September 2003 on the application of minimum 
reserves (ECB/2003/9) (OJ L 250, 2.10.2003, p. 10); and Regulation (EU) No 1071/2013 of the European 
Central Bank of 24 September 2013 concerning the balance sheet of the monetary financial institutions 
sector (ECB/2013/33) (OJ L 297, 7.11.2013, p. 1). 
149  The ‘Declaration by the Republic of Latvia, the Republic of Hungary and the Republic of Malta on the 
spelling of the name of the single currency in the Treaties’, annexed to the Treaties, states that; ‘Without 
prejudice to the unified spelling of the name of the single currency of the European Union referred to in 
the Treaties as displayed on banknotes and on coins, Latvia, Hungary and Malta declare that the spelling 
of the name of the single currency, including its derivatives as applied throughout the Latvian, Hungarian 
and Maltese text of the Treaties, has no effect on the existing rules of the Latvian, Hungarian or Maltese 
languages’. 
150  OJ L 139, 11.5.1998, p. 1. 
151  Opinion CON/2012/87. 
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2.2.7 Legal integration of NCBs into the Eurosystem 
Provisions in national legislation (in particular an NCB’s statutes, but also other 
legislation) which would prevent the performance of Eurosystem-related tasks or 
compliance with the ECB’s decisions are incompatible with the effective operation of 
the Eurosystem once the Member State concerned has adopted the euro. National 
legislation therefore has to be adapted to ensure compatibility with the Treaty and the 
Statute in respect of Eurosystem-related tasks. To comply with Article 131 of the 
Treaty, national legislation had to be adjusted to ensure its compatibility by the date of 
establishment of the ESCB (as regards Sweden) and by 1 May 2004, 1 January 2007 
and 1 July 2013 (as regards the Member States that joined the EU on these dates). 
Nevertheless, statutory requirements relating to the full legal integration of an NCB 
into the Eurosystem need only enter into force at the moment that full integration 
becomes effective, i.e. the date on which the Member State with a derogation adopts 
the euro. 
The main areas examined in this report are those in which statutory provisions may 
hinder NCBs’ compliance with the Eurosystem’s requirements. These include 
provisions (a) that could prevent NCBs from taking part in implementing the single 
monetary policy, as defined by the ECB’s decision-making bodies, or (b) that could 
hinder a Governor from fulfilling their duties as a member of the ECB’s Governing 
Council, or (c) that do not respect the ECB’s prerogatives, or (d) that do not recognise 
that the exclusive competence for ESCB-related tasks in Member States whose 
currency is the euro is irrevocably conferred on the Union,152 or (e) pursuant to which 
NCBs in the performance of their ESCB-related tasks are bound by decisions of 
national authorities that conflict with legal acts of the ECB. Distinctions are made 
between economic policy objectives, tasks, financial provisions, exchange rate policy 
and international cooperation. Finally, other areas where NCBs’ statutes may need to 
be adapted are mentioned. 
Economic policy objectives 
The full integration of an NCB into the Eurosystem requires its statutory objectives to 
be compatible with the ESCB’s objectives, as laid down in Article 2 of the Statute. 
Among other things, this means that statutory objectives with a ‘national flavour’ – for 
example, where statutory provisions refer to an obligation to conduct monetary policy 
within the framework of the general economic policy of the Member State concerned – 
need to be adapted. Furthermore, an NCB’s secondary objectives must be consistent 
and not interfere with its obligation to support the general economic policies in the EU 
with a view to contributing to the achievement of the objectives of the EU as laid down 
in Article 3 of the Treaty on European Union, which is itself an objective expressed to 
be without prejudice to maintaining price stability.153 
 
152  Opinion CON/2020/2. 
153  Opinions CON/2010/30 and CON/2010/48. 
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Tasks 
The tasks of an NCB of a Member State whose currency is the euro are predominantly 
determined by the Treaty and the Statute, given that NCB’s status as an integral part 
of the Eurosystem. In order to comply with Article 131 of the Treaty, provisions on 
tasks in an NCB’s statutes therefore need to be compared with the relevant provisions 
of the Treaty and the Statute, and any incompatibility must be removed.154 This 
applies to any provision that, after adoption of the euro and integration into the 
Eurosystem, constitutes an impediment to carrying out ESCB-related tasks and in 
particular to provisions which do not respect the ESCB’s powers under Chapter IV of 
the Statute. 
Any national legislative provisions relating to monetary policy must recognise that the 
EU’s monetary policy is to be carried out through the Eurosystem.155 An NCB’s 
statutes may contain provisions on monetary policy instruments. Such provisions 
should be comparable to those in the Treaty and the Statute, and any incompatibility 
must be removed in order to comply with Article 131 of the Treaty. 
Monitoring fiscal developments is a task that an NCB carries out on a regular basis to 
assess properly the stance to be taken in monetary policy. NCBs may also present 
their views on relevant fiscal developments on the basis of their monitoring activity and 
the independence of their advice, with a view to contributing to the proper functioning 
of the European Monetary Union. The monitoring of fiscal developments by an NCB 
for monetary policy purposes should be based on the full access to all relevant public 
finance data. Accordingly, the NCBs should be granted unconditional, timely and 
automatic access to all relevant public finance statistics. However, an NCB’s role 
should not go beyond monitoring activities that result from or are linked – directly or 
indirectly – to the discharge of their monetary policy mandate.156 A formal mandate for 
an NCB to assess forecasts and fiscal developments implies a function for the NCB in 
(and a corresponding responsibility for) fiscal policymaking which may risk 
undermining the discharge of the Eurosystem’s monetary policy mandate and the 
NCB’s independence.157 
In the context of the national legislative initiatives to address the turmoil in the financial 
markets, the ECB has emphasised that any distortion in the national segments of the 
euro area money market should be avoided, as this may impair the implementation of 
the single monetary policy. In particular, this applies to the extension of State 
guarantees to cover interbank deposits.158 
Member States must ensure that national legislative measures addressing liquidity 
problems of businesses or professionals, for example their debts to financial 
institutions, do not have a negative impact on market liquidity. In particular, such 
 
154  See, in particular, Articles 127 and 128 of the Treaty and Articles 3 to 6 and 16 of the Statute. 
155  First indent of Article 127(2) of the Treaty. 
156  Opinions CON/2012/105, CON/2013/90 and CON/2013/91. 
157  For example, national legislative provisions transposing Council Directive 2011/85/EU of 8 November 
2011 on requirements for budgetary frameworks of the Member States (OJ L 306, 23.11.2011, p. 41). See 
Opinions CON/2013/90 and CON/2013/91. 
158  Opinions CON/2009/99, CON/2011/79 and CON/2017/1. 
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measures may not be inconsistent with the principle of an open market economy, as 
reflected in Article 3 of the Treaty on European Union, as this could hinder the flow of 
credit, materially influence the stability of financial institutions and markets and 
therefore affect the performance of Eurosystem tasks.159 
National legislative provisions assigning the exclusive right to issue banknotes to the 
NCB must recognise that, once the euro is adopted, the ECB’s Governing Council has 
the exclusive right to authorise the issue of euro banknotes, pursuant to Article 128(1) 
of the Treaty and Article 16 of the Statute, while the right to issue euro banknotes 
belongs to the ECB and the NCBs. National legislative provisions enabling the 
government to influence issues such as the denominations, production, volume or 
withdrawal of euro banknotes must also either be repealed or recognition must be 
given to the ECB’s powers with regard to euro banknotes, as set out in the provisions 
of the Treaty and the Statute. Irrespective of the division of responsibilities in relation 
to coins between governments and NCBs, the relevant provisions must recognise the 
ECB’s power to approve the volume of issue of euro coins once the euro is adopted. A 
Member State may not consider currency in circulation as its NCB’s debt to the 
government of that Member State, as this would defeat the concept of a single 
currency and be incompatible with the requirements of Eurosystem legal 
integration.160 
With regard to foreign reserve management,161 any Member State that has adopted 
the euro and which does not transfer its official foreign reserves162 to its NCB is in 
breach of the Treaty. In addition, any right of a third party – for example, the 
government or parliament – to influence an NCB’s decisions with regard to the 
management of the official foreign reserves would be inconsistent with the third indent 
of Article 127(2) of the Treaty. Furthermore, NCBs have to provide the ECB with 
foreign reserve assets in proportion to their shares in the ECB’s subscribed capital. 
This means that there must be no legal obstacles to NCBs transferring foreign reserve 
assets to the ECB. 
With regard to statistics, although regulations adopted under Article 34.1 of the Statute 
in the field of statistics do not confer any rights or impose any obligations on Member 
States that have not adopted the euro, Article 5 of the Statute, which concerns the 
collection of statistical information, applies to all Member States, regardless of 
whether they have adopted the euro. Accordingly, Member States whose currency is 
not the euro are under an obligation to design and implement, at national level, all 
measures they consider appropriate to collect the statistical information needed to 
fulfil the ECB’s statistical reporting requirements163 and to make timely preparations in 
the field of statistics in order for them to become Member States whose currency is the 
euro.164 National legislation laying down the framework for cooperation between the 
 
159  Opinion CON/2010/8. 
160  Opinion CON/2008/34. 
161  Third indent of Article 127(2) of the Treaty. 
162  With the exception of foreign-exchange working balances, which Member State governments may retain 
pursuant to Article 127(3) of the Treaty. 
163  In this regard, national legislation should ensure consistency with the reporting requirements set out in 
Union legislation. See Opinion CON/2020/29. 
164  Opinion CON/2013/88. 
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NCBs and national statistical offices should guarantee the NCBs' independence in the 
performance of their tasks within the ESCB's statistical framework.165 
Financial provisions 
The financial provisions in the Statute comprise rules on financial accounts,166 
auditing,167 capital subscription,168 the transfer of foreign reserve assets169 and the 
allocation of monetary income.170 NCBs must be able to comply with their obligations 
under these provisions and therefore any incompatible national provisions must be 
repealed. 
Exchange rate policy 
A Member State with a derogation may retain national legislation which provides that 
the government is responsible for the exchange rate policy of that Member State, with 
a consultative and/or executive role being granted to the NCB. However, by the time 
that a Member State adopts the euro, such legislation must reflect the fact that 
responsibility for the euro area’s exchange rate policy has been transferred to the EU 
level in accordance with Articles 138 and 219 of the Treaty. 
International cooperation 
For the adoption of the euro, national legislation must be compatible with Article 6.1 of 
the Statute, which provides that in the field of international cooperation involving the 
tasks entrusted to the Eurosystem, the ECB decides how the ESCB is represented. 
National legislation allowing an NCB to participate in international monetary 
institutions must make such participation subject to the ECB’s approval (Article 6.2 of 
the Statute). 
Miscellaneous 
In addition to the above issues, for certain Member States there are other areas where 
national provisions need to be adapted (for example in the area of clearing and 
payment systems and the exchange of information). 
 
165  Opinions CON/2015/5 and CON/2015/24. 
166  Article 26 of the Statute. 
167  Article 27 of the Statute. 
168  Article 28 of the Statute. 
169  Article 30 of the Statute. 
170  Article 32 of the Statute. 
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3 The state of economic convergence
This chapter provides a horizontal overview. Some factors relevant for the overall 
assessment are not covered here, but in Chapters 4 and 5. 
Mainly owing to challenging economic conditions, limited progress has been 
made as regards compliance with the convergence criteria since the ECB’s 
2020 Convergence Report (Table 3.1). In five of the seven countries examined in the 
report, HICP inflation is well above the reference value, as was the case in 2020. 
Since April 2020 the 12-month averages of long-term interest rate differentials versus 
the euro area has declined slightly in one country and remained virtually flat in three of 
the seven countries considered in the report, while it has increased – albeit to quite 
different extents – in the other three countries. The long-term interest rate was above 
the reference value in two countries and well above it in one country, compared with 
only one country above the reference value in 2020. Two countries (Bulgaria and 
Croatia) joined the exchange rate mechanism (ERM II) in July 2020. The currencies of 
some countries examined in this report have experienced sizeable fluctuations against 
the euro over the last few years and some currencies have recorded a significant 
depreciation since Russia’s invasion of Ukraine on 24 February 2022. No progress 
has been made on reducing fiscal imbalances in most of the countries on account of 
the substantial deterioration in economic activity triggered by the COVID-19 pandemic 
and the fiscal measures adopted to mitigate its impact.  
At the end of February 2022, the energy, commodity, foreign exchange and 
global capital markets experienced significant shocks originating from the 
Russia-Ukraine conflict. Such disturbances are likely to have had a particularly 
sizeable impact on central and eastern European countries. In particular, inflation has 
further increased owing to rising energy and commodity prices. As seen in recent 
inflation developments, price pressures are also increasingly broad-based and 
inflation could remain elevated and higher than previously expected in the coming 
months, driven by war-induced commodity price increases, broadening price 
pressures and further aggravated supply bottlenecks. The future magnitude of the 
impact of the Russia-Ukraine conflict on the countries under review and more 
generally on the EU economy is largely uncertain at this stage and will depend not 
least on the duration of the war and on the policy responses made. Global supply 
chains, in which the EU is highly integrated, were already under pandemic-induced 
stress and the war may result in permanent supply chain reconfiguration, affecting 
economic prospects and price levels in the medium term. The overall transmission of 
the war shock will vary across the countries under review, depending on trade and 
financial linkages, exposure to commodity price increases and the strength of the 
pre-existing inflation surge. 
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Table 3.1 
Overview table of economic indicators of convergence 
 
Price 
stability 
Government budgetary developments and 
projections Exchange rate 
Long-term 
interest 
rate 6) 
HICP 
inflation 1) 
Country in 
excessive 
deficit 2), 3) 
General 
government 
surplus (+)/ 
deficit (-) 4) 
General 
government 
debt 4) 
Currency 
participating 
in ERM II 3) 
Exchange 
rate 
vis-à-vis 
the euro 5) 
Bulgaria 2020 1.2 No -4.0 24.7 Yes 0.0 0.3 
 2021 2.8 No -4.1 25.1 Yes 0.0 0.2 
 2022 5.9 No -3.7 25.3 Yes 0.0 0.5 
Czech Republic 2020 3.3 No -5.8 37.7 No -3.1 1.1 
 2021 3.3 No -5.9 41.9 No 3.1 1.9 
 2022 6.2 No -4.3 42.8 No 3.9 2.5 
Croatia 2020 0.0 No -7.3 87.3 Yes -1.6 0.8 
 2021 2.7 No -2.9 79.8 Yes 0.1 0.4 
 2022 4.7 No -2.3 75.3 Yes -0.2 0.8 
Hungary 2020 3.4 No -7.8 79.6 No -8.0 2.2 
 2021 5.2 No -6.8 76.8 No -2.1 3.1 
 2022 6.8 No -6.0 76.4 No -3.1 4.1 
Poland 2020 3.7 No -6.9 57.1 No -3.4 1.5 
 2021 5.2 No -1.9 53.8 No -2.7 1.9 
 2022 7.0 No -4.0 50.8 No -1.5 3.0 
Romania 2020 2.3 Yes -9.3 47.2 No -2.0 3.9 
 2021 4.1 Yes -7.1 48.8 No -1.7 3.6 
 2022 6.4 Yes -7.5 50.9 No -0.5 4.7 
Sweden 2020 0.7 No -2.7 39.6 No 1.0 0.0 
 2021 2.7 No -0.2 36.7 No 3.2 0.3 
 2022 3.7 No -0.5 33.8 No -3.0 0.4 
Reference value 7)  4.9  -3.0 60.0   2.6 
Sources: European Commission (Eurostat, Directorate-General for Economic and Financial Affairs) and European System of Central 
Banks. 
1) Average annual percentage change. Data for 2022 refer to the period from May 2021 to April 2022. 
2) Refers to whether a country was subject to an EU Council decision on the existence of an excessive deficit for at least part of the year. 
3) The information for 2022 refers to the period up to the cut-off date for statistics (25 May 2022). 
4) As a percentage of GDP. Data for 2022 are taken from the European Commission’s Spring 2022 Economic Forecast. 
5) Annual percentage change. A positive (negative) number denotes appreciation (depreciation) vis-à-vis the euro. Data for 2022 refer to 
the period from 1 January 2022 to 25 May 2022. 
6) Average annual interest rate. Data for 2022 refer to the period from May 2021 to April 2022. 
7) The reference values for HICP inflation and long-term interest rates refer to the period from May 2021 to April 2022; for the general 
government balance and debt, the reference values referred to in Article 126(2) of the Treaty are specified in the related Protocol (No 12) 
on the excessive deficit procedure. 
After the publication of the previous Convergence Report in 2020, the EU 
experienced a longer than initially expected COVID-19 shock, which led to a 
significant drop-in economic activity in 2020, from which all the countries under 
review rebounded strongly. More recently, however, the outbreak of the 
Russia-Ukraine conflict in February 2022 has weighed on economic activity and 
is clouding economic prospects for at least 2022. The onset of the COVID-19 
pandemic in March 2020 resulted in a large drop in economic activity in the second 
quarter of 2020 in all the countries under review. However, the phasing out of 
containment measures and the introduction of major fiscal, prudential and monetary 
policy measures to offset the economic damage from the pandemic bolstered the 
rebound in economic activity in subsequent quarters. Despite supply side bottlenecks, 
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economic activity recovered strongly in the seven countries under review in 2021, 
mainly driven by robust domestic demand and dynamic labour market developments. 
In Croatia, a strong export performance was also a factor. The situation in the labour 
market rapidly improved when restrictions linked to the COVID-19 pandemic were 
eased, supported by the policy measures implemented by the authorities. As a result, 
labour market conditions have remained tight in most cases. In some countries, further 
progress has been made towards correcting external imbalances and reducing 
dependence on external funding. This has enhanced the resilience of those countries. 
However, significant macroeconomic and financial vulnerabilities persist, albeit to 
differing degrees depending on the country. If not adequately addressed in countries 
with lower GDP per capita, such vulnerabilities are likely to slow their convergence 
progress over the long term, including in response to adverse external shocks. Since 
early 2022 the Russia-Ukraine conflict has weighed on economic activity and 
prospects, while adding inflationary pressures through higher energy and commodity 
prices. Commodity prices have increased strongly and vulnerabilities stemming from a 
high dependence on imported energy and some other inputs from a single country 
(such as Russia) have come to the fore. 
Regarding the price stability criterion, the 12-month average inflation rate was 
well above the reference value of 4.9% in five of the seven countries examined 
in the report (Chart 3.1). Bulgaria, the Czech Republic, Hungary, Poland and 
Romania recorded inflation rates well above the reference value, while rates were 
below the reference rate in Croatia and well below in Sweden. In the 2020 
Convergence Report, Bulgaria, the Czech Republic, Hungary, Poland and Romania, 
recorded inflation rates well above the reference value applicable at that time, which 
was 1.8%. 
Chart 3.1 
HICP inflation 
(average annual percentage changes) 
 
 
Source: Eurostat. 
At the time of publication of this report, only Romania is subject to an excessive 
deficit procedure. Although four of the countries under review exceeded the 
1.6
0.9
2.6
2.9
3.7 3.7
2.8
1.1
3.7
4.7
5.9
6.2 6.4
6.8 7.0
4.4
0
1
2
3
4
5
6
7
8
SE HR BG CZ RO HU PL Euro area
Memo item
2020 Convergence Report (April 2019 - March 2020)
2022 Convergence Report (May 2021 - April 2022)
Reference value 2020 Convergence Report (1.8%)
Reference value 2022 Convergence Report (4.9%)
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deficit reference value in 2021, no new excessive deficit procedures were 
opened. In the wake of the COVID-19 crisis, budget deficits increased sharply in all 
countries in 2020 and, except in Sweden, remained at elevated levels in 2021. 
Compared to the previous year, the budget balance improved in 2021 in all countries 
except Bulgaria and the Czech Republic. Nonetheless, four of the countries under 
review recorded budgets deficits above the 3% reference value in 2021, with the 
highest deficits being recorded in Hungary and Romania at 6.8% and 7.1% of GDP 
respectively (Chart 3.2). Moreover, the reference value was also exceeded by 
Bulgaria and the Czech Republic, which recorded deficits of 4.1% and 5.9% of GDP 
respectively. In 2022 the deficit-to-GDP ratio is expected to improve in four countries, 
according to the European Commission’s Spring 2022 Economic Forecast, and it is 
expected to remain above the 3% reference value in all countries except Croatia and 
Sweden. In 2023 a further improvement in the budget balance is expected in six 
countries, but it is expected to continue to exceed the reference value in the Czech 
Republic, Hungary, Poland and Romania. Regarding the debt criterion, in Bulgaria 
and Sweden, the debt ratio was 25.1% and 36.7% of GDP respectively in 2021 (Chart 
3.3). In the Czech Republic, Poland and Romania, the debt ratio was between 40% 
and 60% of GDP. Croatia and Hungary were the only countries with a general 
government debt-to-GDP ratio above the 60% reference value in 2021, as was also 
the case in 2019. In both countries the debt ratios were on a diminishing trajectory 
from 2014 to 2019 and were approaching 60% of GDP at a satisfactory pace until the 
end of 2019. As a result of the COVID-19 pandemic, debt ratios in both countries rose 
by about 15 percentage points of GDP in 2020, before falling again in 2021. An 
assessment of government debt sustainability over the medium term is particularly 
important in a context in which the Stability and Growth Pact’s general escape clause 
has been applied over the past three consecutive years, i.e. 2020, 2021 and 2022. 
Moreover, it is also expected to remain in place in 2023. The European Commission 
concluded in May 2022 that the government deficit criterion had not been fulfilled in 
Bulgaria, the Czech Republic and Hungary based on their outcomes in 2021, as well 
as in Poland based on its planned deficit in 2022, and that the debt criterion had not 
been fulfilled in Hungary. However, taking into account the exceptional uncertainty 
created by the continued extraordinary macroeconomic and fiscal impact of the 
COVID-19 pandemic, together with the invasion of Ukraine by Russia, the 
Commission did not propose opening new excessive deficit procedures at that stage. 
Nevertheless, it stated that it would reassess the relevance of proposing to open 
excessive deficit procedures in autumn 2022. Romania is subject to an excessive 
deficit procedure, which was launched in April 2020 and was kept in abeyance on the 
basis of the achievement of the required headline deficit target and fiscal effort in 
2021. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 245 – 
 
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47 
Chart 3.2 
General government surplus (+) or deficit (-) 
(percentages of GDP) 
  
Source: Eurostat. 
Note: Data for 2019 have been revised slightly since the 2020 Convergence Report. 
Chart 3.3 
General government gross debt 
(percentages of GDP) 
  
Source: Eurostat. 
Note: Data for 2019 have been revised slightly since the 2020 Convergence Report. 
As regards the exchange rate criterion, on 10 July 2020 the ERM II parties 
decided, by mutual agreement, to include the Bulgarian lev and the Croatian 
kuna in ERM II, and the two currencies therefore participated in ERM II for most 
of the two-year reference period from 26 May 2020 to 25 May 2022. The Bulgarian 
lev was included in ERM II at a central rate of 1.95583 levs per euro, while the 
Croatian kuna was included at a central rate of 7.53450 kuna per euro.171 Both 
currencies participate with the standard fluctuation band of ±15%. Bulgaria joined the 
 
171  For the purpose of this report exchange rates are quoted in units of national currency per euro. Thus a 
decrease in the exchange rate corresponds to an appreciation of the currency against the euro, whereas 
an increase in the exchange rate corresponds to a depreciation of the currency against the euro with the 
corresponding percentage changes indicating the degree of appreciation or depreciation of the currency. 
-4.3
-2.1
0.3
2.1
0.2
-0.7
0.6
-7.1 -6.8
-5.9
-4.1
-2.9
-1.9
-0.2
-8
-6
-4
-2
0
2
4
RO HU CZ BG HR PL SE
2019
2021
Reference value (-3%)
20.0
34.9
30.1
35.3
45.6
65.5
71.1
25.1
36.7
41.9
48.8 53.8
76.8 79.8
0
20
40
60
80
100
BG SE CZ RO PL HU HR
2019
2021
Reference value (60%)
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48 
exchange rate mechanism with its existing currency board in place as a unilateral 
commitment, thus placing no additional obligations on the ECB. The agreement on 
participation in ERM II was based on a number of policy commitments made by the 
Bulgarian and Croatian authorities (some of which were already fulfilled by the time of 
the inclusion of their currencies in ERM II – “prior commitments”) with the aim of 
achieving a high degree of sustainable economic convergence by the time of euro 
adoption. The ECB and the European Commission have monitored the effective 
implementation of these commitments, acting within their respective areas of 
competence as provided for by the Treaties and secondary legislation. As regards 
Croatia, all deliverables envisaged in the ERM II “post-entry commitments” have been 
completed, while for Bulgaria they are broadly on track. However, further progress 
needs to be made to address outstanding shortcomings in the area of anti-money 
laundering (AML) in Croatia, as identified in the recent report by the Council of 
Europe’s Committee of Experts on the Evaluation of Anti-Money Laundering 
Measures and the Financing of Terrorism (MONEYVAL). Over the two-year reference 
period the Bulgarian lev did not exhibit any deviation from its central rate, while the 
Croatian kuna displayed a low degree of volatility and traded close to its central rate. 
Since the kuna’s inclusion in ERM II in July 2020, and over the entire reference period, 
the maximum upward deviation from the central rate has been 1.0%, while the 
maximum downward deviation has amounted to 0.8%. These deviations are 
significantly smaller than the standard fluctuation band of ERM II. Among the 
currencies not participating in ERM II, the Romanian leu displayed very low volatility, 
while the remaining currencies were subject to relatively high volatility over most of the 
reference period. 
Chart 3.4 
Bilateral exchange rates vis-à-vis the euro 
(index: average of May 2020 = 100; daily data; 26 May 2020 - 25 May 2022) 
 
 
Source: ECB. 
Note: An upward (downward) movement indicates appreciation (depreciation) of the currency. 
With regard to the convergence of long-term interest rates, two of the seven 
countries under review recorded long-term interest rates above the reference 
value, which was 2.6%. One country recorded a long-term interest rate well 
84
88
92
96
100
104
108
112
116
05/20 07/20 09/20 11/20 01/21 03/21 05/21 07/21 09/21 11/21 01/22 03/22
Bulgarian lev              
Czech koruna               
Croatian kuna              
Hungarian forint           
Polish zloty
Romanian leu
Swedish krona
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 247 – 
Convergence Report, June 2022 49 
above the reference value (Chart 3.5). Interest rates were above the reference value 
in Poland and Hungary, and well above it in Romania. The lowest values – all below 
1% – were recorded in Bulgaria, Croatia and Sweden. By comparison, in the 2020 
Convergence Report, only Romania had a long-term interest rate above the reference 
value, which at that time was 2.9%. 
Chart 3.5
Long-term interest rates 
(percentages, annual averages) 
Sources: Eurostat and ECB. 
When considering compliance with the convergence criteria, sustainability is 
essential. Convergence must be achieved on a lasting basis and not just at a given 
point in time. The first decade of Economic and Monetary Union (EMU) showed that 
weak fundamentals, an excessively loose macroeconomic stance and inadequate 
statistical capacity at the country level and overly optimistic expectations about 
convergence in real incomes pose risks not only for the countries concerned but also 
for the smooth functioning of the euro area as a whole. The second decade showed 
that economic convergence can be challenging and take a long time if initial 
macroeconomic imbalances are large, adjustment and reform processes are difficult 
and resilience to adverse shocks is weak. Compliance with the numerical 
convergence criteria at a single point in time is, by itself, not a guarantee of smooth 
membership of the euro area. Countries joining the euro area should therefore 
demonstrate the sustainability of their convergence processes and their capacity to 
live up to the ongoing commitments and challenges which euro adoption represents, 
taking into account that risk-sharing mechanisms within EMU are incomplete. This is 
in the country’s own interest, as well as in the interest of the euro area.
To achieve sustainable convergence, lasting policy adjustments are required in 
many of the countries under review. A prerequisite for sustainable convergence is 
macroeconomic stability, a supportive business environment with efficient economic 
structures and public institutions and, in particular, a sound fiscal policy. A high degree 
of flexibility in product and labour markets is essential to cope with macroeconomic 
shocks. A stability culture needs to exist, with well-anchored inflation expectations 
-0.1
0.3
0.9
1.5
2.2
2.3
4.4
0.20.4
0.5
0.8
2.5
3.0
4.1
4.7
0.4
-1
0
1
2
3
4
5
SE BG HR CZ PL HU RO Euro area
Memo item
2020 Convergence Report (April 2019 - March 2020)
2022 Convergence Report (May 2021 - April 2022)
Reference value 2020 Convergence Report (2.9%)
Reference value 2022 Convergence Report (2.6%)
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50 
helping to achieve an environment of price stability. Favourable conditions for the 
efficient use of capital and labour in the economy are needed to enhance total factor 
productivity and long-run economic growth. A high degree of economic integration 
with the euro area is needed to achieve the synchronisation of business cycles. 
Moreover, appropriate macroprudential policies need to be in place to prevent the 
build-up of macroeconomic and financial imbalances, such as excessive asset price 
increases and socially costly boom-bust credit cycles. An appropriate framework for 
the supervision of financial institutions also needs to be in place. For countries subject 
to in-depth reviews by the European Commission in the framework of the 
Macroeconomic Imbalance Procedure, it is essential that they address imbalances in 
their economies. Finally, the strength of the institutional environment, including a 
country’s ability to implement economic adjustment and sound structural policies, is a 
major factor in economic integration and convergence. The Next Generation EU 
(NGEU) package represents a unique opportunity to accelerate the process of 
convergence with the euro area, with swift and effective implementation being crucial 
for its success. 
3.1 The price stability criterion 
In April 2022 five of the seven countries under review recorded a 12-month 
average inflation rate well above the reference value of 4.9% for the price 
stability criterion. With the outbreak of the COVID-19 pandemic, inflation 
decelerated significantly in the euro area in 2020, before rising sharply in 2021, largely 
driven by base effects, strong increases in energy prices, particularly at the end of 
2021, supply bottlenecks triggered by the pandemic and strong increases in global 
demand for goods. Since the previous Convergence Report, in most of the countries 
under review inflation has followed a similar pattern, but between May 2021 and April 
2022 inflation was higher in Bulgaria, the Czech Republic, Hungary, Poland and 
Romania, reflecting higher food and energy prices as well as the tightness of the 
labour market. Against this background, these five countries recorded inflation rates 
well above the reference value, while inflation rates were below the reference value in 
Croatia and well below it in Sweden. Since early 2022 the conflict between Russia and 
Ukraine has added inflationary pressures through higher energy and commodity 
prices and by adding strains to already stretched supply chains. Consequently, 
inflation further increased in all countries under review at the beginning of 2022, albeit 
to different degrees. 
Over the past ten years, both the average rate and the volatility of inflation have 
varied significantly across the countries examined (Chart 3.6). Over this period, 
Hungary and Romania recorded average HICP inflation rates above 2.0%. In the 
Czech Republic the average inflation rate was 2.0%, and in Poland it was slightly 
below that level. In Bulgaria, Croatia and Sweden inflation has averaged around 1.0%. 
Over the same period, inflation has fluctuated over a relatively wide range in all the 
countries under review, except Sweden. In countries with positive inflation differentials 
vis-à-vis the euro area, limited progress has been made towards convergence over 
the past decade. Meanwhile, the evolution of inflation differentials vis-à-vis the euro 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 249 – 
Convergence Report, June 2022 51 
area over the reference period from May 2020 to April 2022 was heterogeneous 
across the countries under review. 
Chart 3.6
Long-term HICP developments and outlook 
(annual percentage changes)
Sources: Eurostat, European Commission (Directorate-General for Economic and Financial Affairs) and ECB. 
Notes: Solid lines depict annual percentage changes in the monthly HICP. In the shaded area, projections of annual HICP inflation from 
the European Commission’s Spring 2022 Economic Forecast are shown. 
Longer-term price developments mirrored a more volatile macroeconomic 
environment in many countries. Looking at the past decade, heterogeneous price 
developments across the countries under review in 2012 partly reflected differences in 
the strength of the economic recovery and country-specific measures related to 
administered prices following the abrupt economic downturn in that year. However, in 
2013 inflation embarked on a downward trend in all countries under review, reaching 
historical lows and often even negative rates. This broad-based movement mainly 
reflected developments in global commodity prices, low imported inflationary 
pressures and persistent spare capacity in some countries. The developments in 
global commodity prices have had a particularly pronounced impact on the central and 
eastern European economies, given the relatively large weights of energy and food in 
their HICP baskets. In some of the countries under review, reductions in administered 
prices and indirect taxes or a strengthening of the nominal effective exchange rate 
also exerted downward pressure on inflation. Against this backdrop, monetary policy 
conditions were loosened considerably. From 2017 inflation accelerated significantly, 
owing to the strengthening of economic activity, solid domestic demand and rising 
energy and commodity prices, prompting a tightening of the monetary policy stance in 
some of the countries under review. In 2019 and at the beginning of 2020, despite 
external headwinds and lower energy prices, inflation remained elevated in most 
countries considered in the report, driven by robust domestic demand, increasingly 
tight labour market conditions and food prices. The outbreak of the COVID-19 
pandemic in March 2020 resulted in a large drop in economic activity in the second 
quarter of 2020 in all the countries under review. Inflation slowed significantly in some 
countries, while it remained particularly resilient in others, reflecting higher food and 
services prices as well as the tightness of the labour market. However, the relaxation 
-4
-2
0
2
4
6
8
10
12
14
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2022 2023
BG
CZ
HR
HU
PL
RO
SE
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52 
of containment measures and the introduction of major fiscal, prudential and monetary 
policy measures by the national authorities to offset the economic damage wrought by 
the COVID-19 pandemic bolstered the subsequent rebound in economic activity. In 
this context, inflation increased significantly in all countries under review in 2021, 
largely driven by sharp increases in energy prices, particularly at the end of 2021, and 
by the supply-demand mismatches triggered by the pandemic and the 
macroeconomic policy responses. Since early 2022 the conflict between Russia and 
Ukraine has added to the inflationary pressures. A number of central banks strongly 
increased their main policy rates on several occasions in the course of 2021 and early 
2022. 
Inflation is expected to remain elevated in the coming quarters before gradually 
declining over the forecast horizon in all the countries under review. However, 
the forecasts are subject to considerable uncertainty given the current 
circumstances. Over the longer term there are concerns about the 
sustainability of inflation convergence in most of the countries examined. 
According to the European Commission’s Spring 2022 Economic Forecast, inflation is 
expected to significantly increase in all the countries under review in 2022, before 
declining in 2023 owing to lower energy and commodity prices and the easing of 
supply bottlenecks. However, inflation is expected to remain high in Bulgaria, the 
Czech Republic, Hungary, Poland and Romania over the forecast horizon and 
significantly above 2.0% in Croatia and Sweden. The risks to the inflation outlook are 
tilted to the upside in all the countries under review, as inflationary pressures 
stemming from the Russia-Ukraine conflict could last longer than previously expected 
and could also trigger an upward shift in wage growth and inflation expectations. 
Looking further ahead, since GDP per capita and price levels are still lower than in the 
euro area in all the central and eastern European countries under review, the 
catching-up process is likely to result in positive inflation differentials vis-à-vis the euro 
area, unless counteracted by a rise in the nominal exchange rate. 
An environment that is conducive to sustainable price stability in the countries 
covered in this report requires stability-oriented economic policies, structural 
reforms and measures to safeguard financial stability. Achieving or maintaining 
an environment supportive of price stability will crucially depend on the 
implementation of further structural reforms and the functioning of labour markets. 
Looking forward, an important factor will be how wages react to high realised inflation 
and how they reflect labour productivity growth and take into account labour market 
conditions and developments in competitor countries (Chart 3.7). Continued reform 
effort is needed to further improve the functioning of labour and product markets and 
to maintain favourable conditions for economic expansion and employment growth. To 
this end, measures to support stronger governance and further improvements in the 
quality of institutions are essential. Given the limited room for manoeuvre in monetary 
policy, especially for the two countries in ERM II, it is imperative that other policy areas 
support the capacity of these economies to maintain price stability, cope with 
country-specific shocks and avoid the build-up of macroeconomic imbalances. 
Financial sector and supervisory policies should be aimed at further safeguarding 
financial stability. In order to further bolster confidence in the financial system, the 
national competent authorities should continue to improve their supervisory practices 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 251 – 
Convergence Report, June 2022 53 
by, among other things, following the applicable recommendations of the relevant 
international and European bodies and by collaborating closely with national 
supervisors of other EU Member States within the supervisory colleges. 
Chart 3.7
Cumulative HICP and nominal unit labour cost (ULC) growth in 2012-21 
(percentage points) 
Source: Eurostat. 
Notes: The chart shows cumulative ULC growth on the y-axis and cumulative HICP growth on the x-axis. The solid line represents the 
bisector. HICP growth is computed from monthly data aggregated to average annual data. The blue dot depicts the euro area aggregate, 
the yellow dots depict the seven countries under review (labelled) and the orange dots depict the remaining Member States (unlabelled). 
3.2 The government budgetary position criterion
At the time of publication of this report, only Romania is subject to an excessive 
deficit procedure. The deficit in Romania exceeded the 3% of GDP reference value 
in 2019 and an excessive deficit procedure was opened in April 2020. The procedure 
is being kept in abeyance on the basis of the achievement of the required headline 
deficit target and fiscal effort in 2021. The deadline for correction of the excessive 
deficit is 2024. The fiscal deficit-to-GDP ratios of four countries exceeded the 
reference value in 2021. The deficits were well above the reference value in Bulgaria 
and the Czech Republic, amounting to 4.1% and 5.9% of GDP respectively, and 
significantly above the reference value in Hungary and Romania, amounting to 6.8% 
and 7.1% of GDP respectively. The deficit in Croatia remained just below the 
reference value at 2.9% of GDP and the deficit in Poland was well below it at 1.9% of 
GDP. Sweden remained close to a balanced budget, posting a deficit of 0.2% of GDP. 
The fiscal balance in 2021 was below its 2019 level in all countries covered in 
this report on account of the economic impact of the COVID-19 pandemic and 
the fiscal policy measures taken in response to it. In 2020 the budget balance 
deteriorated in all countries as the COVID-19 crisis led to a substantial deterioration in 
economic activity and fiscal measures were adopted to mitigate its impact. While the 
deficit-to-GDP ratio only exceeded the 3% reference value in Romania in 2019, it rose 
above this level in six countries in 2020. In 2021 the budget balances improved in all 
countries except Bulgaria and the Czech Republic as the economies recovered and 
BG
CZ
HR
HU
PL
RO
SE
EA
-30
-15
0
15
30
45
60
75
-30 -15 0 15 30 45 60 75
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54 
parts of the fiscal support measures were withdrawn. The further deterioration in 
Bulgaria is due to strong current expenditure growth, while the deterioration in the 
Czech Republic is related to a reform of personal income tax. 
For 2022 the European Commission forecasts that the deficit-to-GDP ratio will 
remain below the 3% reference value only in Croatia and Sweden. Owing to a 
further improvement in economic activity and the withdrawal of most of the remaining 
fiscal support measures, the government balance is projected to increase in four 
countries. However, while it is expected to remain below the 3% reference value in 
Croatia and Sweden, it is projected to remain above it in Bulgaria and Poland, well 
above it in the Czech Republic and Hungary, and significantly above it in Romania. 
In 2021 the debt ratio was above 60% of GDP in Croatia and Hungary, while in 
the other countries under review the debt levels were below or well below this 
threshold (Table 3.1 and Chart 3.3). The government debt-to-GDP ratio in 2021 was 
above its 2019 level in all countries under review, mostly on account of the COVID-19 
crisis. The debt ratio increased by 13.5 percentage points of GDP in Romania, 11.8 in 
the Czech Republic, 11.3 in Hungary, 8.7 in Croatia, 8.2 in Poland, 5.1 in Bulgaria and 
1.8 in Sweden. Taking a longer perspective, between 2012 and 2021 the government 
debt-to-GDP ratio increased strongly in Romania (by 11.7 percentage points) and 
Croatia (by 10.4 percentage points) and increased significantly in Bulgaria (by 8.5 
percentage points), while it declined in the other countries. 
For 2022 the European Commission projects an increase in debt-to-GDP ratios 
in three countries. While the debt ratio is expected to decline in four countries, it is 
projected to increase moderately in Bulgaria and the Czech Republic and notably in 
Romania. The Commission’s projections indicate that the debt ratio will remain below 
or well below the 60% reference value in all countries in 2022, with the exception of 
Croatia and Hungary. 
Even though the European Commission assessed that several countries had 
not fulfilled the deficit and debt criteria in 2021, it decided not to initiate new 
excessive deficit procedures. On 23 May 2022, the European Commission 
published a report prepared in accordance with Article 126(3) of the Treaty based on 
data validated by Eurostat on 22 April 2021.172 It found that in 2021 the budget deficit 
was above and not close to the 3% of GDP reference value in Bulgaria, the Czech 
Republic and Hungary. Moreover, it found that Poland was planning a deficit above 
and not close to the reference value in 2022. The excess over the reference value was 
considered to be exceptional, as defined by the Treaty, in all countries under review, 
and was not expected to be temporary in the Czech Republic, Hungary or Poland. 
Overall, the analysis suggested that the deficit criterion was not fulfilled by Bulgaria, 
the Czech Republic, Hungary and Poland. Moreover, the European Commission 
found that the general government gross debt had exceeded the 60% of GDP 
reference value at the end of 2021 in Croatia and Hungary, and that of those two 
countries only Croatia had complied with the debt reduction benchmark. 
Consequently, the Commission’s analysis suggested that the debt criterion had not 
 
172  Report prepared in accordance with Article 126(3) of the Treaty on the Functioning of the European 
Union (COM (2022) 630 final). 
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55 
been fulfilled by Hungary. Nevertheless, in the Commission’s view, the need to comply 
with the debt reduction benchmark was not warranted under the current exceptional 
economic conditions, as it would imply too demanding a frontloaded fiscal effort that 
risked jeopardising growth. Moreover, the Commission’s report stressed that the 
COVID-19 pandemic had continued to have an extraordinary macroeconomic and 
fiscal impact that, together with the invasion of Ukraine by Russia, had created 
exceptional uncertainty, including for designing a detailed fiscal adjustment path. 
Beyond this, the pandemic and the related severe economic downturn had led to the 
general escape clause of the Stability and Growth Pact being activated and to the 
Council recommendations of 20 July 2020, in which the Council recommended that all 
Member States take all necessary measures to effectively address the COVID-19 
pandemic, sustain the economy and support the ensuing recovery. Therefore, the 
European Commission stated in its Communication of 23 May 2022173 that it did not 
propose opening new excessive deficit procedures at that stage, but would reassess 
the relevance of proposing to open excessive deficit procedures in autumn 2022. 
Looking ahead, while fiscal policy should remain agile in its response to the 
evolving pandemic situation, and given the geopolitical situation, it is essential 
for the countries examined in this report to achieve and/or maintain sound and 
sustainable fiscal positions. Romania, which is subject to an excessive deficit 
procedure, should ensure compliance with the rules of the Stability and Growth Pact 
and correct its excessive deficit by 2024. The other countries should return their 
budget balances to below the 3% reference value as soon as the pandemic situation 
allows and build the buffers needed to allow automatic stabilisers to work. Moreover, 
Croatia and Hungary, whose debt-to-GDP ratios exceed the reference value, should 
ensure that their ratio is declining sufficiently to ensure that fiscal buffers are available 
for any future downturn. An assessment of government debt sustainability over the 
medium term is particularly important in a context in which the Stability and Growth 
Pact’s general escape clause has been applied over the past three consecutive years, 
i.e. 2020, 2021 and 2022. Moreover, it is expected to remain in place in 2023. 
Moreover, for 2023 the Commission has provided guidance on fiscal policies in the EU 
that is largely qualitative and different from the numerical fiscal requirements that the 
Stability and Growth Pact would usually entail. This also reflects an ongoing review of 
the economic governance framework, which may lead to a reformed Stability and 
Growth Pact. In the absence of numerical fiscal adjustment requirements, an 
assessment of fiscal sustainability over the medium term should put particular 
emphasis on the ability of countries to correct fiscal imbalances. Generally, further 
consolidation would make it easier to deal with the budgetary challenges related to 
adverse demographic developments. Strong national fiscal frameworks that are fully 
in line with EU rules and implemented effectively should support fiscal consolidation 
and limit slippages in public expenditure, while helping to prevent a re-emergence of 
macroeconomic imbalances. Overall, fiscal strategies should be consistent with 
comprehensive structural reforms to increase potential growth and employment. The 
 
173  European Commission, 2022 European Semester - Spring Package (COM (2022) 600 final). 
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56 
NGEU programme needs to be implemented effectively in order to support the 
recovery and to adjust to the structural changes that are under way.174 
3.3 The exchange rate criterion 
At the time of publication of this report, the Bulgarian lev and the Croatian kuna 
are participating in ERM II. The currencies of the other Member States under review 
operate under different exchange rate regimes. 
On 10 July 2020 the ERM II parties decided, by mutual agreement, to include the 
Bulgarian lev in ERM II and it therefore participated in ERM II for most of the 
two-year reference period from 26 May 2020 to 25 May 2022. The Bulgarian lev 
was included in ERM II at a central rate of 1.95583 levs per euro with a standard 
fluctuation band of ±15%. Bulgaria joined the exchange rate mechanism with its 
existing currency board in place as a unilateral commitment, thus placing no additional 
obligations on the ECB. The agreement on participation in ERM II was based on a 
number of policy commitments made by the Bulgarian authorities (some of which were 
already fulfilled by the time of the inclusion of the lev in ERM II) with the aim of 
achieving a high degree of sustainable economic convergence by the time of euro 
adoption. The ECB and the European Commission have monitored the effective 
implementation of these commitments, acting within their respective areas of 
competence as provided for by the Treaties and secondary legislation. Over the 
reference period the lev did not exhibit any deviation from the central rate. 
On 10 July 2020 the ERM II parties decided, by mutual agreement, to include the 
Croatian kuna in ERM II and it therefore participated in ERM II for most of the 
two-year reference period from 26 May 2020 to 25 May 2022. The Croatian kuna 
was included in ERM II at a central rate of 7.53450 kuna per euro with a standard 
fluctuation band of ±15%. The agreement on participation in ERM II was based on a 
number of policy commitments made by the Croatian authorities (some of which were 
already fulfilled by the time of the inclusion of the kuna in ERM II) with the aim of 
achieving a high degree of sustainable economic convergence by the time of euro 
adoption. The ECB and the European Commission have monitored the effective 
implementation of these commitments, acting within their respective areas of 
competence as provided for by the Treaties and secondary legislation. 
Notwithstanding that all deliverables envisaged in the ERM II post-entry commitments 
have been completed, further progress needs to be made to address the outstanding 
shortcomings in the area of AML identified in the recent report by the Council of 
Europe’s MONEYVAL Committee. Over the reference period, the exchange rate of the 
Croatian kuna displayed a low degree of volatility and traded close to its central rate. 
The deviations from the central rate were significantly smaller than the standard 
fluctuation band of ERM II. 
The currencies not participating in ERM II traded under flexible or managed 
floating exchange rate regimes, most of them amid relatively high exchange 
 
174  The potential economic impact of NGEU is analysed in “The economic impact of Next Generation EU: a 
euro area perspective”, Occasional Paper Series, No 291, ECB, April 2022. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 255 – 
Convergence Report, June 2022 57 
rate volatility. The Romanian leu, which traded under a managed floating exchange 
rate regime, exhibited a very low degree of volatility, while the other currencies not 
participating in ERM II traded under flexible exchange rate regimes and were subject 
to a relatively high degree of exchange rate volatility. 
3.4 The long-term interest rate criterion 
Over the reference period, two of the seven countries under review recorded 
average long-term interest rates that were above the 2.6% reference value and 
one country was just above. The countries with the lowest average long-term 
interest rates were Sweden, Bulgaria, and Croatia at 0.4%, 0.5% and 0.8% 
respectively. The Czech Republic recorded an average interest rate just below the 
reference value at 2.5%, while Poland and Hungary remained above at 3.0% and 
4.1% respectively. In Romania the average interest rate was well above the 2.6% 
reference value at 4.7%. Starting in the final quarter of 2021, there was a 
non-negligible increase in the 12-month average of long-term interest rates in almost 
all the countries owing to increased inflationary pressures and the impact of the 
Russia-Ukraine conflict. The future dynamics of long-term interest rates are quite 
difficult to gauge, given the high level of uncertainty about the duration of the original 
shock and its impact on price developments and economic activity. 
Since the 2020 Convergence Report, long-term interest rate spreads vis-à-vis 
the euro area average have widened in all of the countries under review. This is 
the result of the impact of the pandemic on fiscal and monetary policy, as well as the 
cyclical position of some countries compared to the euro area, a faster rebound in 
economic activity and stronger upward price pressures. Nonetheless, a significant 
degree of heterogeneity persists in long-term interest rate differentials across the 
countries under review, reflecting differences both in the countries’ cyclical positions 
and in financial markets’ assessments of their external and internal vulnerabilities, 
including developments in budgetary performance and the prospects for sustainable 
convergence. In April 2022, in Sweden and Bulgaria the long-term interest rate was 
above the level in the euro area, by 10 basis points and 20 basis points respectively. 
Sweden is a developed economy whose financial system is highly integrated with the 
euro area, while Bulgaria’s banking system is predominantly owned by euro 
area-based banks and the central bank operates a currency board which de facto 
imports euro area monetary conditions. The Czech Republic, Hungary, Poland and 
Romania experienced the largest increases in the interest rate differential over the 
review period, ranging from 170 basis points to 350 basis points. Among the countries 
under review, Hungary and Romania were the countries with the largest interest rate 
differential, both at 520 basis points at the end of the reference period.  
3.5 Other relevant factors
According to the European Commission, most of the countries under review 
had made progress in addressing imbalances in their economies until this 
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58 
correction process was interrupted by the COVID-19 shock. In its Alert 
Mechanism Report 2022 the European Commission refers in particular to the 
reduction in debt-to-GDP ratios amid favourable macroeconomic conditions in 2021. 
The European Commission concluded that in-depth reviews were warranted in 
Croatia, Romania and Sweden. As regards Croatia, the Commission found that 
imbalances relating to high levels of external, private and government debt in the 
context of low potential growth continued to subside in 2021, returning to their 
favourable pre-pandemic trends. For Romania, the Commission found that the country 
entered the COVID-19 crisis with vulnerabilities linked to a widening current account 
deficit, a deteriorating external position and significant cost competitiveness losses. 
With the COVID-19 crisis, government debt has increased, albeit from low levels. In 
the case of Sweden, the Commission found that, the country entered the COVID-19 
crisis with vulnerabilities linked to risks stemming from overvalued house price levels 
coupled with high and continuously rising household debt. With the COVID-19 crisis, 
private debt ratios, house prices and the unemployment rate have increased. Although 
the European Commission classified the other countries under review in this report as 
having no imbalances, those countries also face various challenges. 
The external positions of most countries under review have stabilised in recent 
years. The macroeconomic imbalance procedure (MIP) scoreboard shows that 
three-year average current account balances remained in surplus in 2020 and 2021 in 
almost all the countries under review, with the exception of Hungary, which recorded a 
modest deficit, and Romania, where the deficit increased further (Table 3.2). 
In almost all the countries under review, negative net international investment 
positions as a share of GDP have diminished but remain at high levels. The net 
foreign liabilities of the central and eastern European countries are mainly in foreign 
direct investment, which is assessed as constituting a more stable form of financing. In 
2021 the net international investment position was beyond the indicative threshold of 
-35% of GDP in Hungary, Poland and Romania. Net foreign liabilities were smallest in 
the Czech Republic (15.6% of GDP) and Bulgaria (19.8%), while Sweden recorded a 
positive net international investment position (17.8% of GDP). 
In terms of price and cost competitiveness, between 2019 and 2021 
HICP-deflated real effective exchange rates appreciated to different degrees in 
most of the countries examined, with Sweden being the only exception. The 
three-year growth rate of unit labour costs, which in the years before the COVID-19 
pandemic stood at very high levels in almost all of the countries under review, 
decreased but still exceeded the indicative threshold of 12% in Bulgaria, the Czech 
Republic and Hungary. Over the five-year period from 2016 to 2021, gains in export 
market shares were recorded in a majority of countries. 
House prices continued to increase in all countries under review. Developments 
in EU housing markets, which were already buoyant before the COVID-19 pandemic, 
picked up pace in 2020 and 2021, with various countries displaying risks of 
overvaluation. This raises concerns, particularly where household debt is high or rising 
fast. In some countries under review, house prices accelerated further and reached 
their fastest growth rates since the global financial crisis. In the Czech Republic, 
Hungary and Sweden, house prices increased at a pace beyond the indicative 
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threshold of 6% in 2021. The growth in house prices was driven by a variety of factors 
fuelling demand and constraining supply. Housing market prospects remain 
dependent on uncertainties related to the pandemic and the macroeconomic outlook. 
Table 3.2
Scoreboard for the surveillance of macroeconomic imbalances
Table 3.2a – External imbalances and competitiveness indicators 
Current account 
balance 1)
Net international 
investment 
position 2)
Real effective 
exchange rate, 
HICP-deflated 3) 
Export 
market share 4)
Nominal unit 
labour costs 5)
Bulgaria 2019 2.0 -30.2 4.7 15.1 20.4 
2020 0.9 -27.1 6.9 15.6 20.4 
2021 0.5 -19.8 3.8 12.1 18.9 
Czech Republic 2019 0.8 -19.8 8.7 4.8 14.6 
2020 0.9 -16.3 5.6 8.2 19.3 
2021 0.5 -15.6 5.0 -1.1 15.0 
Croatia 2019 2.8 -46.7 1.6 22.1 2.8
2020 1.6 -47.8 0.4 -0.4 13.7 
2021 2.1 -33.9 -1.5 8.3 6.4
Hungary 2019 0.5 -49.1 0.4 5.0 11.8
2020 -0.5 -48.9 -4.9 7.6 13.9 
2021 -1.5 -44.8 -4.1 0.0 14.7 
Poland 2019 -0.4 -49.8 2.7 24.7 8.2
2020 0.7 -44.3 1.0 36.2 14.0 
2021 0.9 -39.9 -0.4 26.1 11.2
Romania 2019 -4.2 -43.6 0.2 17.4 26.3 
2020 -4.8 -47.9 3.4 19.9 20.8 
2021 -5.6 -45.7 1.0 10.7 1.5
Sweden 2019 3.7 16.2 -8.3 -2.9 7.1
2020 4.8 14.1 -4.8 4.0 9.6
2021 5.7 17.8 2.1 -0.6 6.8
Threshold -4.0/+6.0 -35.0 +/-11.0 -6.0 +12.0
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60 
Table 3.2b – Internal imbalances and unemployment indicators 
Sources: European Commission (Eurostat, Directorate-General for Economic and Financial Affairs) and European System of Central Banks. 
Note: This table includes data available as at 25 May 2022, i.e. the cut-off date for this report, and therefore differs from the scoreboard published in the Alert 
Mechanism Report 2022, which was published in November 2021. 
1) As a percentage of GDP, three-year average. 
2) As a percentage of GDP. 
3) Three-year percentage change relative to 41 other industrial countries. A positive value indicates a loss of competitiveness. 
4) Five-year percentage change. 
5) Three-year percentage change. 
6) Year-on-year percentage change. 
7) Three-year average. 
8) Three-year percentage point change. 
A relatively long period of credit expansion prior to the financial crisis left the 
private non-financial sector with high – though moderately declining – levels of 
accumulated debt in some of the countries under review. This continues to 
constitute a key vulnerability in those countries, although private credit growth has 
moderated and does not exceed the indicative threshold of 14% in any of the countries 
under review. Sweden, however, continued to record a particularly high stock of 
private sector debt, exceeding 200% of GDP in 2020. 
Financial sector policies in the countries under review should be aimed at 
ensuring that the financial sector makes a sound contribution to sustainable 
economic growth and price stability, and supervisory policies should be geared 
towards ensuring a financially healthy and resilient banking system, which is a 
precondition for joining the Single Supervisory Mechanism (SSM). In order to 
further support confidence in the financial system, the national competent authorities 
  
Internal imbalances Unemployment indicators 
House prices,
consumptiondeflated 6) 
Private sector 
credit flow, 
consolidated 2) 
Private  
sector debt, 
consolidated 2) 
Financial 
sector 
liabilities 6) 
General 
government 
debt 2)
Unemployment  
rate 7) 
Activity  
rate 8) 
Long-term
unemployment 8) 
Youth
unemployment 8) 
Bulgaria 2019 3.9 5.6 91.3 5.8 20.0 6.2 4.5 -2.1 -8.2 
 2020 5.2 . . . 24.7 5.8 0.9 -1.1 1.3 
 2021 4.9 . . . 25.1 5.5 0.6 -0.5 0.0 
Czech 
Republic 
2019 6.2 1.4 78.6 4.6 30.1 2.4 1.7 -1.1 -4.9 
2020 5.5 2.3 81.9 3.3 37.7 2.3 0.5 -0.4 0.0 
2021 16.1 . . . 41.9 2.5 0.0 0.1 1.4 
Croatia 2019 7.8 1.1 88.3 6.7 71.1 8.8 0.9 -4.3 -14.9 
 2020 7.3 1.3 98.0 7.3 87.3 7.5 0.7 -2.5 -6.5 
 2021 4.5 . . . 79.8 7.3 2.4 -0.7 -1.9 
Hungary 2019 11.8 3.9 67.1 36.7 65.5 3.6 2.6 -1.3 -1.5 
 2020 1.6 7.7 76.1 55.6 79.6 3.7 1.9 -0.6 2.0 
 2021 8.6 11.6 78.4 14.5 76.8 3.8 2.1 -0.2 3.6 
Poland 2019 6.1 3.6 73.9 4.3 45.6 4.1 2.1 -1.5 -7.9 
 2020 7.1 1.6 75.6 11.5 57.1 3.5 1.4 -0.9 -4.0 
 2021 3.7 3.8 71.1 13.6 53.8 3.3 3.4 -0.1 0.1 
Romania 2019 -1.9 2.0 46.7 10.2 35.3 5.4 3.2 -1.3 -4.9 
 2020 2.2 1.3 48.4 13.3 47.2 5.4 2.3 -0.5 -1.6 
 2021 -1.1 3.7 47.2 14.4 48.8 5.5 3.2 0.2 0.5 
Sweden 2019 0.4 10.0 198.7 11.7 34.9 6.8 0.8 -0.3 1.2 
 2020 3.0 12.6 212.5 10.7 39.6 7.3 0.0 -0.1 6.2 
 2021 8.1 16.9 218.0 11.3 36.7 8.1 0.5 0.9 7.9 
Threshold  +6.0 +14.0 +133.0 +16.5 +60.0 +10.0 -0.2 0.5 2.0 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 259 – 
Convergence Report, June 2022 61 
should continue to improve their supervisory practices by, among other things, 
following the applicable recommendations of the relevant international and European 
bodies and by closely collaborating with national supervisors of other EU Member 
States within the supervisory colleges. With the entry into force of the close 
cooperation frameworks with Българска народна банка (Bulgarian National Bank)
and Hrvatska narodna banka on 1 October 2020, the ECB assumed responsibility for 
(i) the direct supervision of the significant institutions in the two countries, (ii) the
common procedures for all supervised entities, and (iii) the oversight of less significant
institutions, which continue to be supervised by their national supervisors. Since
establishing close cooperation with Българска народна банка (Bulgarian National
Bank) and Hrvatska narodna banka, the ECB has worked closely with them to ensure
their smooth integration into the SSM.
Unemployment rates continued on a declining path in almost all countries 
under review, supported by furlough schemes and other policy measures 
implemented by governments during the pandemic. Over the review period, the 
unemployment rate has declined further in most countries except Sweden and 
remains below the indicative threshold of 10% in all reviewed countries. The Czech 
Republic, Hungary and Poland have recorded historically low unemployment rates 
and some countries are increasingly facing labour shortages in certain segments of 
the labour market. 
The strength of the institutional environment is another important factor in the 
analysis of the sustainability of economic integration and convergence. Low 
quality of institutions and weak governance may reflect, for example, weaknesses in 
the business environment, an inefficient public administration, tax evasion, corruption, 
a lack of social inclusion, a lack of transparency, a lack of judicial independence and/or 
poor access to online services. In several countries, enhancing institutional quality 
would contribute to removing the existing rigidities and impediments to the efficient 
use and allocation of production factors, thereby strengthening long-term growth 
capacity. By hampering potential output growth, a weak institutional environment may 
also undermine a country’s debt-servicing ability and make economic adjustment 
more difficult. It may also affect a country’s ability to implement necessary policy 
measures. 
Except in Sweden, the quality of institutions and governance is relatively weak 
in all the countries under review – especially in Bulgaria, Romania, Croatia and 
Hungary. This can pose risks for economic resilience and the sustainability of 
convergence. Specific institutional indicators broadly confirm an overall picture of poor 
quality institutions and governance in most countries, although with some notable 
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62 
differences (Charts 3.8 and 3.9).175 In this respect, Bulgaria, Romania, Croatia and 
Hungary are among the countries facing the greatest challenges within the EU. 
Chart 3.8 
Overview of EU country rankings in terms of institutional quality 
 
Sources: Worldwide Governance Indicators 2021 (World Bank), The Global Competitiveness Report 2019 (World Economic Forum) and 
Corruption Perceptions Index 2021 (Transparency International). 
Notes: Countries are ranked from one (best performing in the EU) to 27 (worst performing in the EU) and ordered according to their 
average position in the latest rankings. 
 
175  Measuring institutional quality remains difficult and fraught with controversy. 
On one hand, perception-based indicators can have some merit when compared with other indicators. 
One advantage of perception-based surveys resides in their catch-all nature, whereas more specific 
measures may provide highly distorted information. Also, while the absolute value of perception-based 
indicators may be questionable, they are useful for cross-country comparisons, unless it is clear that 
there is a systematic bias against one or more specific countries. Moreover, indicators that are based 
solely on the content of laws, but not on detailed knowledge of their actual implementation, can be 
misleading. Furthermore, as no institutional model may be presumed to be preferable ex ante, 
perception-based surveys may prevent the emergence of measurement biases when gauging the 
various dimensions of economic governance directly. 
On the other hand, perception-based surveys also produce distortions. For instance, they may be heavily 
influenced by a recent episode or poorly designed questions. 
Given the respective weaknesses and comparative advantages of perception-based (e.g. corruption) 
and more objective (e.g. competitiveness) institutional indicators, Charts 3.8 and 3.9 present both types 
of indicators. 
Moreover, as regards EU countries, the institutional focus has only gained analytical and policy 
prominence in recent years. There is thus, generally speaking, still ample scope for measurement 
improvements. Finally, cross-country approaches to an issue as complex as institutional quality or good 
governance are necessarily somewhat insufficient and clearly need to be complemented with more 
country-specific and longer-term assessments. At the same time, measurement difficulties should not 
lead to a down-playing of these crucially important determinants of long-term prosperity, social fairness 
and well-being. 
0
5
10
15
20
25
30
FI DK SE NL LU DE AT IE EE FR BE PT ES LT SI CZ IT MT LV PL SK CY HU GR HR RO BG
Range of ranks (latest)
Average of ranks (2008)
Average of ranks (latest)
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 261 – 
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Chart 3.9
EU country rankings in terms of institutional quality by individual indicator
Sources: Worldwide Governance Indicators 2021 (World Bank), The Global Competitiveness Report 2019 (World Economic Forum) and 
Corruption Perceptions Index 2021 (Transparency International). 
Note: Countries are ranked from one (best performing in the EU) to 27 (worst performing in the EU) and ordered according to their 
average position in the latest rankings. 
Wide-ranging structural reforms are required in most of the countries under 
review to improve economic growth and competitiveness. Improving local 
institutions, governance and the business environment, along with further progress in 
the reform and privatisation of state-owned enterprises and the efficient absorption of 
EU funds, would help to speed up productivity growth. This would in turn contribute to 
increasing competition in key regulated sectors (e.g. energy and transport), lowering 
barriers to entry and encouraging much-needed private investment. 
Finally, institutional features relating to the quality of statistics are also 
essential to support a smooth convergence process. This applies to, among other 
things, the legal independence of the national statistical authority, its administrative 
supervision and budget autonomy, its legal mandate for data collection and legal 
provisions governing statistical confidentiality, which are described in more detail in 
Chapter 6. 
0
5
10
15
20
25
30
FI DK SE NL LU DE AT IE EE FR BE PT ES LT SI CZ IT MT LV PL SK CY HU GR HR RO BG
Worldwide Governance Indicators (2021)
Corruption Perceptions Index 2021 (Transparency International)
The Global Competitiveness Report 2019 (World Economic Forum)
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4 Country summaries 
4.1 Bulgaria 
In April 2022 the 12-month average rate of HICP inflation in Bulgaria was 5.9%, 
i.e. well above the reference value of 4.9% for the criterion on price stability. 
This rate is expected to increase gradually over the coming months, driven mainly by 
the higher commodity prices, broadening price pressures and further aggravation of 
supply bottlenecks resulting from the Russia-Ukraine war. Over the past ten years it 
has fluctuated within a relatively wide range, from -1.7% to 5.9%, and the average for 
that period was subdued, standing at 0.9%. Looking ahead, there are concerns about 
the sustainability of inflation convergence in Bulgaria over the longer term. The 
catching-up process is likely to result in positive inflation differentials vis-à-vis the euro 
area, since GDP per capita and price levels are still significantly lower in Bulgaria than 
in the euro area. In order to prevent the build-up of excessive price pressures and 
macroeconomic imbalances, the catching-up process must be supported by 
appropriate policies. 
Bulgaria’s general government budget deficit was well above the 3% reference 
value in 2021, while its debt-to-GDP ratio was well below the 60% reference 
value. Bulgaria has been subject to the preventive arm of the Stability and Growth 
Pact since 2012. In May 2022, the European Commission found that the general 
government deficit in 2021 was above and not close to the reference value of 3% of 
GDP. The excess over the reference value was considered to be exceptional and 
temporary. This notwithstanding, taking into account the exceptional uncertainty 
created by the continued extraordinary macroeconomic and fiscal impact of the 
COVID-19 pandemic, together with the invasion of Ukraine by Russia, the 
Commission did not propose opening new excessive deficit procedures at that stage. 
From 2012 to 2019, prior to the COVID-19 crisis, Bulgaria comfortably met both the 
deficit criterion (with one exception in 2014) and the debt criterion. The European 
Commission’s Spring 2022 Economic Forecast foresees an improvement in the fiscal 
position as of 2022 as a result of the combined effect of the gradual phasing-out of 
fiscal measures implemented during the crisis and an improvement in economic 
activity, with the budget balance still being expected to remain above 3% of GDP in 
2022, before falling below it in 2023. The European Commission’s latest assessment 
of fiscal sustainability indicated that Bulgaria faced medium risks to fiscal sustainability 
over the medium and long term. While fiscal policy should remain agile in its response 
to the evolving pandemic situation and given the geopolitical situation, efficient and 
well-targeted measures, as well as prudent and growth-friendly fiscal policies, are 
essential for safeguarding sound public finances in the future. 
On 10 July 2020 the ERM II parties decided, by mutual agreement, to include the 
Bulgarian lev in ERM II, and it therefore participated in ERM II for most of the 
two-year reference period from 26 May 2020 to 25 May 2022. The Bulgarian lev 
was included in ERM II at a central rate of 1.95583 levs per euro with a standard 
fluctuation band of ±15%. Bulgaria joined the exchange rate mechanism with its 
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existing currency board in place, as a unilateral commitment, thus placing no 
additional obligations on the ECB. The agreement on participation in ERM II was 
based on a number of policy commitments by the Bulgarian authorities, some of which 
had already been met when the lev was included in ERM II, with the aim of achieving a 
high degree of sustainable economic convergence by the time of the adoption of the 
euro. The ECB and the European Commission have been monitoring the effective 
implementation of these commitments, acting within their respective areas of 
competence as provided for by the Treaties and secondary legislation. Over the 
reference period the lev did not exhibit any deviation from the central rate. In July 2020 
Българска народна банка (Bulgarian National Bank) entered a precautionary swap 
line arrangement with the ECB, under which it could borrow up to €2 billion in
exchange for Bulgarian levs in order to address possible euro liquidity needs of 
Bulgarian financial institutions owing to the pandemic. As this arrangement helped to 
reduce the potential risk of financial vulnerabilities, it may also have further supported 
the stability of the exchange rate over the reference period. 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in Bulgaria stood at 0.5% on average and were thus well below the 2.6% 
reference value for the interest rate convergence criterion. Long-term interest 
rates in Bulgaria have decreased since 2012, with 12-month average rates declining 
from 5.3% to 0.5%. 
Achieving an environment that is conducive to sustainable convergence in 
Bulgaria requires stability-oriented economic policies and wide-ranging 
structural reforms. With regard to macroeconomic imbalances, the European 
Commission did not select Bulgaria for an in-depth review in its Alert Mechanism 
Report 2022. The sustainability of convergence and economic resilience would benefit 
from wide-ranging reforms to enhance structural resilience, the business environment, 
financial stability, institutional quality and governance. The convergence in banking 
supervision achieved under the close cooperation framework ensures the application 
of uniform supervisory standards and thus contributes to safeguarding financial 
stability. With the entry into force of that framework between the ECB and Българска
народна банка (Bulgarian National Bank) on 1 October 2020, the ECB became 
responsible for the direct supervision of five significant institutions and for the 
oversight of 13 less significant institutions in Bulgaria. 
Bulgarian law does not comply with all the requirements for central bank 
independence, the monetary financing prohibition and legal integration into the 
Eurosystem. Bulgaria is an EU Member State with a derogation and must therefore 
comply with all adaptation requirements under Article 131 of the Treaty. 
4.2 Czech Republic
In April 2022 the 12-month average rate of HICP inflation in the Czech Republic 
was 6.2%, i.e. well above the reference value of 4.9% for the criterion on price 
stability. This rate is expected to increase gradually over the coming months, driven 
mainly by the higher commodity prices, broadening price pressures and further 
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aggravation of supply bottlenecks resulting from the Russia-Ukraine war. Over the 
past ten years it has fluctuated within a relatively wide range, from 0.2% to 6.2%, and 
the average for the period was moderate, standing at 2.0%. Looking ahead, there are 
some concerns about the sustainability of inflation convergence in the Czech Republic 
over the longer term. The catching-up process may result in positive inflation 
differentials vis-à-vis the euro area, since GDP per capita and price levels are still 
relatively lower in Czech Republic than in the euro area, unless this is counteracted by 
an appreciation of the nominal exchange rate. In order to prevent the build-up of 
excessive price pressures and macroeconomic imbalances, the catching-up process 
must be supported by targeted economic policies. 
The Czech Republic’s general government budget deficit was well above the 3% 
reference value in 2021, while its debt-to-GDP ratio was below the 60% 
reference value. The Czech Republic has been subject to the preventive arm of the 
Stability and Growth Pact since 2014. In May 2022, the European Commission found 
that the general government deficit in 2021 was above and not close to the reference 
value of 3% of GDP. The excess over the reference value was considered to be 
exceptional but not temporary. This notwithstanding, taking into account the 
exceptional uncertainty created by the continued extraordinary macroeconomic and 
fiscal impact of the COVID-19 pandemic, together with the invasion of Ukraine by 
Russia, the Commission did not propose opening new excessive deficit procedures at 
that stage. In the period prior to the COVID-19 crisis, the deficit and debt criteria were 
comfortably met. While the European Commission’s Spring 2022 Economic Forecast 
foresees an improvement in the fiscal position as of 2022 as a result of the combined 
effect of the improved economic activity and the partial phasing-out of fiscal measures 
implemented during the crisis, the budget deficit is still expected to remain above 3% 
of GDP until the end of the forecast horizon in 2023. The European Commission’s 
latest assessment of fiscal sustainability found that the Czech Republic faced medium 
fiscal sustainability risks over the medium term. Over the long term, it was found to 
face high risks, primarily linked to budgetary pressures stemming from population 
ageing and the initial budgetary position. While fiscal policy should remain agile in its 
response to the evolving pandemic situation and given the geopolitical situation, 
efficient and well-targeted measures, as well as prudent and growth-friendly fiscal 
policies, are essential for safeguarding sound public finances in the future. 
In the two-year reference period from 26 May 2020 to 25 May 2022, the Czech 
koruna did not participate in ERM II, but traded under a flexible exchange rate 
regime. The exchange rate of the Czech koruna exhibited, on average, a relatively 
high degree of volatility over the reference period. On 25 May 2022 the exchange rate 
stood at 24.6480 korunas per euro, i.e. 9.6% stronger than its average level in May 
2020. 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in the Czech Republic stood at 2.5% on average and were thus just below the 
2.6% reference value for the interest rate convergence criterion. Long-term 
interest rates in the Czech Republic have decreased since 2012, with 12-month 
average rates declining from 3.5% to 2.5%. 
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Maintaining sustainable convergence in the Czech Republic requires targeted 
economic policies, including structural reforms, that are geared towards 
fostering price and macroeconomic stability. With regard to macroeconomic 
imbalances, the European Commission did not select the Czech Republic for an 
in-depth review in its Alert Mechanism Report 2022. Medium to long-term 
vulnerabilities relate to the sustainability of the country’s current growth model and to a
disorderly reallocation of capital and capacity across the economy, which could 
suffocate growth in sectors that have been particularly hard hit by the pandemic. 
Economic and financial policies should aim to achieve broad efficiency gains and 
enhance productivity by appropriately reallocating capital. To this end, it will be 
important to strengthen administrative and institutional capacity (e.g. in areas such as 
governance and insolvency) and address inefficiencies in the business environment 
that weigh on potential growth by hindering innovation and the development of new 
business. Labour and skill shortages should also be addressed with targeted 
structural policies and investments, and small and medium-sized enterprises should 
have easier access to equity finance and venture capital in order to enhance the 
country’s growth potential. In order to further bolster confidence in the financial 
system, the national competent authorities should continue to improve their 
supervisory practices, among other things, by following the applicable 
recommendations from the relevant international and European bodies, and by 
collaborating closely with other national supervisors of EU Member States within the 
respective supervisory colleges. 
Czech law does not comply with all the requirements for central bank 
independence, the monetary financing prohibition and legal integration into the 
Eurosystem. The Czech Republic is an EU Member State with a derogation and must 
therefore comply with all adaptation requirements under Article 131 of the Treaty. 
4.3 Croatia
In April 2022 the 12-month average rate of HICP inflation in Croatia was 4.7%, 
i.e. below the reference value of 4.9% for the criterion on price stability. This rate
is expected to increase gradually over the coming months, driven mainly by the higher
commodity prices, broadening price pressures and further aggravation of supply
bottlenecks resulting from the Russia-Ukraine war. Over the past ten years it has
fluctuated within a relatively wide range, from -0.8% to 4.7%, and the average for that
period was subdued, standing at 1.1%. Looking ahead, there are concerns about the
sustainability of inflation convergence in Croatia over the longer term. The catching-up
process is likely to result in positive inflation differentials vis-à-vis the euro area, since
GDP per capita and price levels are still lower in Croatia than in the euro area. In order
to prevent the build-up of excessive price pressures and macroeconomic imbalances,
the catching-up process must be supported by appropriate policies.
Croatia’s general government budget balance was just below the 3% deficit 
reference value in 2021, while its debt ratio was above the 60% reference value 
but on a downward trajectory. Croatia has been subject to the preventive arm of the 
Stability and Growth Pact since June 2017. Since the general government 
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deficit-to-GDP ratio was below the reference value of 3% in 2021 and is projected to 
remain below it in 2022, the deficit criterion was fulfilled. The debt ratio was 79.8% of 
GDP in 2021, but that represented a decline of around 7.5 percentage points relative 
to the peak value of 87.3% of GDP that had been recorded in 2020 and respected the 
debt reduction benchmark, thus implying compliance with the debt criterion. The 
deficit criterion was met and the debt ratio declined in Croatia over the period 2017-19. 
For 2020, however, the European Commission found in June 2021 that the general 
government deficit was above and not close to the reference value of 3% of GDP. The 
excess over the reference value was considered to be exceptional, but not temporary. 
Moreover, Croatia’s general government debt exceeded the 60% of GDP reference 
value and did not diminish at a satisfactory pace. This notwithstanding, taking into 
account the high uncertainty, the agreed fiscal policy response to the COVID-19 crisis 
and the Council recommendations of 20 July 2020, the Commission considered that at 
that juncture a decision on whether to place Member States under the excessive 
deficit procedure should not be taken. The European Commission’s Spring 2022 
Economic Forecast indicates continued compliance with the deficit and debt criteria of 
the Stability and Growth Pact. The European Commission’s latest assessment of 
fiscal sustainability suggested that Croatia faced medium debt sustainability risks over 
the medium term, as well as over the long term. While fiscal policy should remain agile 
given the geopolitical situation, efficient and well-targeted measures, as well as 
prudent and growth-friendly fiscal policies, together with the implementation of the 
envisaged fiscal reforms under the Recovery and Resilience Plan, are essential for 
safeguarding sound public finances and putting the debt ratio on a long-lasting 
downward path. 
On 10 July 2020 the ERM II parties decided, by mutual agreement, to include the 
Croatian kuna in ERM II, and it therefore participated in ERM II for most of the 
two-year reference period from 26 May 2020 to 25 May 2022. The Croatian kuna 
was included in ERM II at a central rate of 7.53450 kuna per euro with a standard 
fluctuation band of ±15%. The agreement on participation in ERM II was based on a 
number of policy commitments by the Croatian authorities, some of which had already 
been met when the kuna was included in ERM II, with the aim of achieving a high 
degree of sustainable economic convergence by the time of the adoption of the euro. 
The ECB and the European Commission have been monitoring the effective 
implementation of these commitments, acting within their respective areas of 
competence as provided for by the Treaties and secondary legislation. Over the 
reference period the exchange rate of the Croatian kuna against the euro displayed a 
low degree of volatility and traded close to its central rate. The deviations from the 
central rate were significantly smaller than the standard fluctuation band within ERM II. 
On 25 May 2022 the exchange rate stood at 7.5355 kuna per euro, i.e. virtually at the 
level of its central rate within ERM II. In April 2020 Hrvatska narodna banka entered a 
precautionary swap line arrangement with the ECB under which it could borrow up to 
€2 billion in exchange for Croatian kuna in order to address possible euro liquidity 
needs of Croatian financial institutions owing to the pandemic. As this arrangement 
helped to reduce the potential risk of financial vulnerabilities, it may also have further 
supported the stability of the exchange rate over the reference period. 
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Over the reference period from May 2021 to April 2022, long-term interest rates 
in Croatia stood at 0.8% on average and thus remained below the 2.6% 
reference value for the interest rate convergence criterion. Long-term interest 
rates in Croatia have decreased since 2012, with 12-month average rates declining 
from slightly below 7% to below 1.0%. 
Achieving an environment that is conducive to sustainable convergence in 
Croatia requires stability-oriented economic policies and wide-ranging 
structural reforms. With regard to macroeconomic imbalances, the European 
Commission selected Croatia for an in-depth review in its Alert Mechanism Report 
2022, which highlighted that imbalances relating to high levels of external, private and 
government debt in the context of low potential growth continued to subside in 2021. 
Croatia would benefit from structural reforms aimed at improving the institutional and 
business environment, boosting competition in product markets, reducing mismatches 
in the labour market and labour supply constraints, and enhancing the efficiency of the 
public administration and the judicial system. With the entry into force of the close 
cooperation framework between the ECB and Hrvatska narodna banka on 1 October 
2020, the ECB became responsible for the direct supervision of eight significant 
institutions and for the oversight of 15 less significant institutions in Croatia. 
Croatian law is compatible with the Treaties and the Statute as required under 
Article 131 of the Treaty. 
4.4 Hungary 
In April 2022 the 12-month average rate of HICP inflation in Hungary was 6.8%, 
i.e. well above the reference value of 4.9% for the criterion on price stability. 
This rate is expected to increase gradually over the coming months, driven mainly by 
the higher commodity prices, broadening price pressures and further aggravation of 
supply bottlenecks resulting from the Russia-Ukraine war. Over the past ten years it 
has fluctuated within a relatively wide range, from -0.3% to 6.8%, and the average for 
that period was elevated at 2.5%. Looking ahead, there are concerns about the 
sustainability of inflation convergence in Hungary over the longer term. The 
catching-up process is likely to result in positive inflation differentials vis-à-vis the euro 
area, since GDP per capita and price levels are still lower in Hungary than in the euro 
area, unless this is counteracted by an appreciation in the nominal exchange rate. In 
order to prevent the build-up of excessive price pressures and macroeconomic 
imbalances, the catching-up process must be supported by appropriate policies. 
Hungary’s general government budget deficit was well above the 3% reference 
value in 2021 and its debt was above the 60% reference value. Hungary has been 
subject to the preventive arm of the Stability and Growth Pact since 2013. For 2021, 
the European Commission found that the general government deficit was above and 
not close to the reference value of 3% of GDP. The excess over the reference value 
was considered to be exceptional, but not temporary. Moreover, Hungary’s general 
government debt exceeded the 60% of GDP reference value and did not diminish at a 
satisfactory pace. This notwithstanding, taking into account the exceptional 
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uncertainty created by the continued extraordinary macroeconomic and fiscal impact 
of the COVID-19 pandemic, together with the invasion of Ukraine by Russia, the 
Commission did not propose opening new excessive deficit procedures at that stage. 
The European Commission’s Spring 2022 Economic Forecast points to an 
improvement in Hungary’s deficit after the sharp deterioration seen in 2020 and 2021, 
but the deficit is projected to remain well above 3% of GDP in 2023. The European 
Commission’s latest assessment of fiscal sustainability indicated that Hungary was at 
medium risk of fiscal stress over the medium term and at high risk over the long term, 
with population ageing posing a challenge to the sustainability of public finances. 
While fiscal policy should remain agile in its response to the evolving pandemic 
situation and given the geopolitical situation, efficient and well-targeted measures, as 
well as prudent and growth-friendly fiscal policies, are essential for safeguarding 
sound public finances and putting the debt ratio on a long-lasting downward path. 
In the two-year reference period from 26 May 2020 to 25 May 2022, the 
Hungarian forint did not participate in ERM II, but traded under a flexible 
exchange rate regime. The exchange rate of the Hungarian forint against the euro 
exhibited, on average, a high degree of volatility over the reference period. On 25 May 
2022 the exchange rate stood at 388.25 forints per euro, i.e. 10.7% weaker than its 
average level in May 2020. In June 2020 the Magyar Nemzeti Bank entered a repo line 
arrangement with the ECB under which it could borrow up to €4 billion against 
adequate euro-denominated collateral to provide euro liquidity to Hungarian financial 
institutions in order to address possible needs owing to the pandemic. As this 
arrangement helped to reduce the potential risk of financial vulnerabilities, it may also 
have had an impact on exchange rate developments over the reference period. 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in Hungary stood at 4.1% on average and were thus above the 2.6% reference 
value for the interest rate convergence criterion. Long-term interest rates in 
Hungary have been on a downward path since 2012, with 12-month average rates 
declining from around 8% to around 4%. 
Achieving an environment that is conducive to sustainable convergence in 
Hungary requires stability-oriented economic policies and wide-ranging 
structural reforms. With regard to macroeconomic imbalances, the European 
Commission did not select Hungary for an in-depth review in its Alert Mechanism 
Report 2022. However, on 27 April 2022 the European Commission, under the 
general regime of conditionality for the protection of the Union budget, sent a written 
notification to the Hungarian authorities about concerns over respect for the rule of 
law, which may result in a suspension of or reduction in the disbursement of EU funds. 
Hungary would benefit from structural reforms aimed at improving the quality of public 
institutions and administration, as well as from the implementation of adequate 
product market policies. In order to further bolster confidence in the financial system, 
the national competent authorities should continue to improve their supervisory 
practices, among other things, by following the applicable recommendations from the 
relevant international and European bodies, and by collaborating closely with other 
national supervisors of EU Member States within the supervisory colleges. 
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Hungarian law does not comply with all the requirements for central bank 
independence, the prohibition of monetary financing, the requirements for the 
single spelling of the euro and legal integration into the Eurosystem. Hungary is 
an EU Member State with a derogation and must therefore comply with all adaptation 
requirements under Article 131 of the Treaty. 
4.5 Poland
In April 2022 the 12-month average rate of HICP inflation in Poland was 7.0%, 
i.e. well above the reference value of 4.9% for the criterion on price stability.
This rate is expected to increase gradually over the coming months, driven mainly by
the higher commodity prices, broadening price pressures and further aggravation of
supply bottlenecks resulting from the Russia-Ukraine war. Over the past ten years it
has fluctuated within a relatively wide range, from -0.7% to 7.0%, while the average for
that period was moderate, standing at 1.7%. Looking ahead, there are concerns about
the sustainability of inflation convergence in Poland over the longer term. The
catching-up process is likely to result in positive inflation differentials vis-à-vis the euro
area, since GDP per capita and price levels are still lower in Poland than in the euro
area, unless this is counteracted by an appreciation in the nominal exchange rate. In
order to prevent the build-up of excessive price pressures and macroeconomic
imbalances, the catching-up process must be supported by appropriate policies.
Poland’s general government budget balance was well below the 3% deficit 
reference value in 2021, and the debt ratio was below the 60% reference value. 
Poland has been subject to the preventive arm of the Stability and Growth Pact since 
2015. In the subsequent period to 2019, the deficit criterion was met and the debt ratio 
declined. In 2021, the general government budget balance recorded a deficit of 1.9% 
of GDP. However, the European Commission’s Spring 2022 Economic Forecast
foresees a notable deterioration in the budget balance in 2022, with the deficit 
standing above the 3% reference value on account of the costs to aid Ukrainian 
refugees, higher interest expenses, temporary relief measures against high energy 
and food inflation, and lower revenues from the income tax reform. In May 2022, the 
European Commission considered Poland’s planned excess over the reference value 
to be exceptional but not temporary. However, taking into account the exceptional 
uncertainty created by the continued extraordinary macroeconomic and fiscal impact 
of the COVID-19 pandemic, together with the invasion of Ukraine by Russia, the 
Commission did not propose opening new excessive deficit procedures at that stage. 
In June 2021, the European Commission had found that the general government 
deficit in 2020 was above and not close to the reference value of 3% of GDP, while the 
debt-to-GDP ratio remained below the 60% threshold. This notwithstanding, the 
Commission did not open an excessive deficit procedure due to the exceptional 
situation determined by the COVID-19 pandemic. The deficit fell in 2021 as most 
emergency measures had expired, hence the government debt-to-GDP ratio declined 
to 53.8%. Meanwhile, the public debt ratio is projected to improve notably and remain 
below the 60% reference value. The European Commission’s latest assessment of
fiscal sustainability suggests that Poland faces medium risks to fiscal sustainability in 
the medium and long term owing to budgetary pressures stemming from population 
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ageing and the unfavourable initial budgetary position. While fiscal policy should 
remain agile in its response to the evolving pandemic situation and given the 
geopolitical situation, efficient and well-targeted measures, as well as prudent and 
growth-friendly fiscal policies, are essential for safeguarding sound public finances in 
the future. 
In the two-year reference period from 26 May 2020 to 25 May 2022, the Polish 
zloty did not participate in ERM II, but traded under a flexible exchange rate 
regime. The exchange rate of the Polish zloty against the euro exhibited, on average, 
a relatively high degree of volatility over the reference period. On 25 May 2022 the 
exchange rate stood at 4.6210 zlotys per euro, i.e. 2.1% weaker than its average level 
in May 2020. At the end of March 2022 Narodowy Bank Polski entered a swap line 
arrangement with the ECB under which it could borrow up to €10 billion against zlotys 
in order to address potential euro liquidity needs in the Polish financial system. As this 
arrangement helped to reduce the potential risk of financial vulnerabilities, it may also 
have had an impact on exchange rate developments over the end of the reference 
period. 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in Poland stood at3.0% on average and were thus above the reference value of 
2.6% for the interest rate convergence criterion. Long-term interest rates in Poland 
have decreased since 2012, with 12-month average rates declining from 
approximately 6% to 3%. 
Achieving an environment that is conducive to sustainable convergence in 
Poland requires stability-oriented economic policies, targeted structural 
reforms and policy measures that safeguard financial stability. With regard to 
macroeconomic imbalances, the European Commission did not select Poland for an 
in-depth review in its Alert Mechanism Report 2022. It is essential to preserve the 
currently strong financial position of the banking sector in order to maintain foreign 
investor confidence and to ensure its sound contribution to economic growth. This 
should be supported by well-targeted structural reforms aimed at reducing frictions in 
labour markets, boosting competition in product markets and speeding up innovation 
and infrastructure modernisation. In order to further bolster confidence in the financial 
system, the national competent authorities should continue to improve their 
supervisory practices, among other things, by following the applicable 
recommendations from the relevant international and European bodies, and by 
collaborating closely with other national supervisors of EU Member States within the 
supervisory colleges. 
Polish law does not comply with all the requirements for central bank 
independence, confidentiality, the monetary financing prohibition and legal 
integration into the Eurosystem. Poland is an EU Member State with a derogation 
and must therefore comply with all adaptation requirements under Article 131 of the 
Treaty. 
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4.6 Romania 
In April 2022 the 12-month average rate of HICP inflation in Romania was 6.4%, 
i.e. well above the reference value of 4.9% for the criterion on price stability. 
This rate is expected to increase gradually over the coming months, driven mainly by 
the higher commodity prices, broadening price pressures and further aggravation of 
supply bottlenecks resulting from the Russia-Ukraine war. Over the past ten years it 
has fluctuated within a relatively wide range, from -1.7% to 6.4%, and the average for 
that period was moderate, standing at 2.2%. Looking ahead, there are concerns about 
the sustainability of inflation convergence in Romania over the longer term. The 
catching-up process is likely to result in positive inflation differentials vis-à-vis the euro 
area, since GDP per capita and price levels are still lower in Romania than in the euro 
area, unless this is counteracted by an appreciation of the nominal exchange rate. In 
order to prevent the build-up of excessive price pressures and reduce macroeconomic 
imbalances, the catching-up process must be supported by appropriate policies. 
While Romania’s deficit ratio was significantly above the 3% reference value in 
2021, its excessive deficit procedure, which was launched in April 2020, is 
being kept in abeyance. Since April 2020, Romania has been subject to an 
excessive deficit procedure, as its fiscal position exceeded the 3% reference value in 
2019. Its headline deficit stood at 7.1% of GDP in 2021, better than the recommended 
target, and the required fiscal effort was achieved. Therefore, the excessive deficit 
procedure is being kept in abeyance. According to the European Commission’s Spring 
2022 Economic Forecast, the targets for the period 2022-24 are not expected to be 
met unless policy changes are made, pointing to the need for a medium-term 
consolidation strategy and corresponding corrective measures. While the debt ratio is 
below the 60% of GDP threshold, it has been increasing since 2019. The European 
Commission’s latest assessment of fiscal sustainability points to low sustainability 
risks in the short term, high sustainability risks in the medium term, and medium 
sustainability risks in the long term, with Romania needing to address the challenges 
of its ageing population. While fiscal policy should remain agile in its response to the 
evolving pandemic situation and given the geopolitical situation, efficient and 
well-targeted measures, as well as prudent and growth-friendly fiscal policies in line 
with the provisions of the Stability and Growth Pact, are essential to safeguard the 
sustainability of public finances over the medium term. 
Over the reference period from 26 May 2020 to 25 May 2022, the Romanian leu 
did not participate in ERM II, but traded under a flexible exchange rate regime 
involving a managed floating of the currency’s exchange rate. The exchange rate 
of the Romanian leu exhibited, on average, a very low degree of volatility over the 
reference period. On 25 May 2022 it stood at 4.9416 lei per euro, i.e. 2.2% weaker 
than its average level in May 2020. In June 2020 Banca Naţională a României entered 
a repo line arrangement with the ECB under which it could borrow up to €4.5 billion 
against high quality euro-denominated collateral to provide euro liquidity to Romanian 
financial institutions in order to address possible liquidity needs owing to the 
pandemic. As this arrangement helped to reduce the potential risk of financial 
vulnerabilities, it may also have had an impact on exchange rate developments over 
the reference period. 
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Over the reference period from May 2021 to April 2022, long-term interest rates 
in Romania stood at 4.7% on average and were thus well above the 2.6% 
reference value for the interest rate convergence criterion. Long-term interest 
rates in Romania have decreased since 2012, with 12-month average rates declining 
from slightly more than 7% to around 4.5%. 
Achieving an environment that is conducive to sustainable convergence in 
Romania requires stability-oriented economic policies and wide-ranging 
structural reforms. With regard to macroeconomic imbalances, the European 
Commission selected Romania for an in-depth review in its Alert Mechanism Report 
2022, highlighting issues related to its external position and cost competitiveness. 
Although Romania has made good progress on meeting the conditions for economic 
convergence since the early 2010s, there are still concerns about low productivity 
levels. The relatively weak quality of the country’s institutions and governance, as well 
as its weak business environment, continue to hamper its growth potential. In addition, 
effective absorption of EU funds remains key to fostering economic growth in the 
medium term and to guiding the economy in the upcoming green and digital transition. 
Reform efforts aimed at fighting corruption, improving competition and enhancing the 
predictability of the country’s tax, judicial, regulatory and administrative systems are 
also needed. In order to further bolster confidence in the financial system, the national 
competent authorities should continue to improve their supervisory practices, among 
other things, by following the applicable recommendations from the relevant 
international and European bodies, and by collaborating closely with other national 
supervisors of EU Member States within the supervisory colleges. 
Romanian law does not comply with all the requirements for central bank 
independence, the monetary financing prohibition and legal integration into the 
Eurosystem. Romania is an EU Member State with a derogation and must therefore 
comply with all adaptation requirements under Article 131 of the Treaty. 
4.7 Sweden 
In April 2022 the 12-month average rate of HICP inflation in Sweden was 3.7%, 
i.e. well below the reference value of 4.9% for the criterion on price stability. 
This rate is expected to increase gradually over the coming months, driven mainly by 
the higher commodity prices, broadening price pressures and further aggravation of 
supply bottlenecks resulting from the Russia-Ukraine war. Over the past ten years it 
has fluctuated within a range from 0.2% to 3.7%, and the average for that period was 
subdued, standing at 1.2%. Sweden’s GDP per capita is already above that of the 
euro area as a whole and so it is not faced with challenges related to the catching-up 
process. Looking ahead, monetary policy and the stability-oriented institutional 
framework should continue to support the achievement of price stability in Sweden. 
Sweden’s general government budget deficit was well below the 3% reference 
value in 2021 and its debt-to-GDP ratio was well below the 60% reference value. 
Sweden has never been subject to an excessive deficit procedure. The European 
Commission’s Spring 2022 Economic Forecast indicates compliance with the 
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requirements of the Stability and Growth Pact. The European Commission’s latest 
assessment of fiscal sustainability suggests that Sweden faces low risks over the 
medium and long term. While fiscal policy should remain agile in its response to the 
evolving pandemic situation and given the geopolitical situation, efficient and 
well-targeted measures, as well as continued compliance with the medium-term 
objective over the coming years, will ensure that Sweden’s track record of sound 
public finances is further enhanced. 
In the two-year reference period from 26 May 2020 to 25 May 2022, the Swedish 
krona did not participate in ERM II, but traded under a flexible exchange rate 
regime. The exchange rate of the Swedish krona against the euro exhibited, on 
average, a relatively high degree of volatility over the two years. On 25 May 2022 it 
stood at 10.5419 kronor per euro, i.e. 0.5% stronger than its average level in May 
2020. Over the reference period Sveriges Riksbank maintained a swap agreement 
with the ECB for borrowing up to €10 billion in exchange for Swedish kronor, which 
had been in place since 20 December 2007 with the aim of facilitating the functioning 
of financial markets and providing euro liquidity to them if needed. As this agreement 
helped to reduce the potential risk of financial vulnerabilities, it may also have had an 
impact on the exchange rate of the Swedish krona against the euro over the reference 
period. 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in Sweden stood at 0.4% on average and thus remained well below the 2.6% 
reference value for the interest rate convergence criterion. Long-term interest 
rates in Sweden have decreased since 2012, with 12-month average rates declining 
from around 2% to around 0.5%. 
Maintaining an environment that is conducive to sustainable convergence in 
Sweden requires the continuation of stability-oriented economic policies, 
targeted structural reforms and measures to safeguard financial stability. 
Despite the significant impact of the pandemic on the real economy, residential 
property prices in Sweden have risen sharply since spring 2020, mainly on the back of 
increased demand. This price upturn seems to deviate significantly from historical 
fundamentals such as mortgage rates or household disposable income. The 
European Commission selected Sweden for an in-depth review in its Alert Mechanism 
Report 2022, in particular because of the macroeconomic imbalances stemming from 
the housing market. In order to further bolster confidence in the financial system, the 
national competent authorities should continue to improve their supervisory practices, 
among other things, by following the applicable recommendations from the relevant 
international and European bodies, and by collaborating closely with other national 
supervisors of EU Member States within the supervisory colleges. 
Swedish law does not comply with all the requirements for central bank 
independence, the monetary financing prohibition and legal integration into the 
Eurosystem. Sweden is an EU Member State with a derogation and must therefore 
comply with all adaptation requirements under Article 131 of the Treaty. Pursuant to 
the Treaty, Sweden has been under the obligation to adopt national legislation with a 
view to integration into the Eurosystem since 1 June 1998. As yet no legislative action 
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has been taken by the Swedish authorities to remedy the incompatibilities described in 
this and previous reports. 
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5 Examination of economic convergence 
in individual countries
5.1 Bulgaria
5.1.1 Price developments
In April 2022 the 12-month average rate of HICP inflation in Bulgaria was 5.9%, 
i.e. well above the reference value of 4.9% for the criterion on price stability
(Chart 5.1.1). This rate is expected to increase gradually over the coming months,
driven mainly by the higher commodity prices, broadening price pressures and further
aggravation of supply bottlenecks resulting from the Russia-Ukraine war.
Over the past ten years the 12-month average rate of HICP inflation has 
fluctuated within a relatively wide range, from -1.7% to 5.9%, and the average 
for that period was subdued, standing at 0.9%. From 2012 the average annual rate 
of inflation declined gradually, before bottoming out at -1.7% in 2015. This drop in 
inflation was driven by falling commodity prices, an appreciation in the effective 
exchange rate of the lev and domestic factors, such as cuts in administered prices. 
After a prolonged period in negative territory, inflation turned positive again in 2017. 
Robust economic growth and decreasing unemployment, together with a longer-term 
decline in the working age population, as well as administrative and policy factors, 
resulted in sharply rising nominal wages and unit labour costs, though at a slower rate 
than before the financial crisis. In 2018, 2019 and the first quarter of 2020 HICP 
inflation rose further, owing to upward pressure from both strong domestic demand on 
the back of robust wage growth and hikes in food and services prices. Thereafter, the 
contraction of the Bulgarian economy as a result of the coronavirus (COVID-19) 
pandemic and declines in oil and energy prices kept HICP inflation at low levels, 
averaging 1.2% in 2020. Rising international energy and food prices, changes in 
administered prices and the rebound in economic activity and private consumption 
then pushed up prices in the first half of 2021. From September of that year inflation 
accelerated sharply, owing to high electricity, fuel and gas prices and the associated 
direct and indirect effects (Table 5.1.1). 
In the first four months of 2022 the average annual rate of HICP inflation stood 
at 9.7%. In April it reached 12.1%, its highest level in 13 years. This increase can be 
attributed to significant upward pressure from the surge in international prices for food 
and energy products (oil, natural gas and electricity) owing, in part, to Russia’s 
invasion of Ukraine. Other inflationary factors include the higher prices for imported 
non-energy industrial goods (in the context of global increases in transportation costs 
and supply bottlenecks) and strong domestic demand on the back of robust wage 
growth. To prevent further increases in electricity and heating prices for households, 
the Bulgarian Parliament imposed a moratorium on retail price changes on 
15 December 2021 until the end of March 2022. Prior to that, the Government had 
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implemented a compensation scheme for industrial end users by partially subsidising 
firms’ electricity consumption. The lump sum payment per megawatt-hour was 
introduced in October 2021 and increased over time. 
Inflation is expected to stay elevated in the coming months, before declining 
gradually. However, the forecasts are subject to considerable uncertainty in the 
light of the Russia-Ukraine war. Over the longer term there are concerns about 
the sustainability of inflation convergence in Bulgaria. According to the European 
Commission’s Spring 2022 Economic Forecast, the average annual rate of inflation 
will rise to around 11.9% in 2022, before falling to 5.0% in 2023. This outlook is based 
on the expectation that double-digit energy inflation will persist over the forecast 
horizon and pass through to headline inflation. HICP inflation in 2022 and 2023 will be 
largely determined by developments in international food prices, by the magnitude of 
the direct and indirect effects of high energy prices and by how the national regulator 
decides to adjust retail prices based on the expected evolution of wholesale prices. 
Risks to the medium-term inflation outlook are tilted to the upside, as supply 
bottlenecks and higher energy prices could continue for longer than projected. 
Moreover, persistent labour shortages in some sectors may result in higher than 
expected wage growth, thus exerting upward pressure on inflation. Looking further 
ahead, there are concerns about the sustainability of inflation convergence in Bulgaria 
over the longer term, also taking into account the marked increase in unit labour costs 
and labour market tightness. Although the COVID-19 crisis has not hampered 
Bulgaria’s reform momentum, also in the context of the post-entry commitments the 
country made upon joining ERM II, the catching-up process is likely to result in positive 
inflation differentials vis-à-vis the euro area, since GDP per capita and price levels are 
still significantly lower in Bulgaria than in the euro area. In order to prevent the build-up 
of excessive price pressures and macroeconomic imbalances, the catching-up 
process must be supported by appropriate policies. In particular, while hourly labour 
costs in Bulgaria are still the lowest in the EU, growth in wages needs to be consistent 
with that in productivity, among other things, in order to safeguard price 
competitiveness and the country’s attractiveness to foreign investors. Moreover, as 
Bulgaria has opted for a currency board and been participating in ERM II since July 
2020, it is important to contain inflation with appropriate policies, not least to enhance 
productivity growth, especially in the non-traded goods sector. 
Achieving an environment that is conducive to sustainable convergence in 
Bulgaria requires stability-oriented economic policies and wide-ranging 
structural reforms. Given monetary policy’s limited room for manoeuvre under the 
currency board, it is imperative that other policy areas (fiscal, macroprudential) 
provide the economy with the wherewithal to cope with potential country-specific 
shocks and macroeconomic imbalances. This is also of utmost importance for a 
smooth participation in ERM II. Structural reforms to enhance the business and 
institutional environment are crucial in order to attract foreign direct investment and 
raise potential growth. These include significantly reducing corruption, ensuring an 
independent and effective judicial system, and enhancing the education system. A 
further reduction in the declining – but still elevated – corporate debt burden would 
support corporate profitability, credit growth and investment. It is also essential to 
strengthen national policies aimed at enhancing competition in product markets, to 
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proceed with the liberalisation of regulated sectors and to manage a smooth transition 
to a digital and greener economy. In this context, additional efforts are needed to 
enhance administrative capacity and to further improve the absorption of EU funds. 
With long-term unemployment accounting for a large percentage of total 
unemployment, additional measures are required to improve the employability and 
strengthen the skill level of the workforce, and to promote the economic inclusion of 
the most vulnerable segments of the population. With regard to macroeconomic 
imbalances, the European Commission did not select Bulgaria for an in-depth review 
in its Alert Mechanism Report 2022. 
The convergence in banking supervision achieved under the close cooperation 
framework ensures the application of uniform supervisory standards and thus 
contributes to safeguarding financial stability. With the entry into force of the close 
cooperation framework between the ECB and Българска народна банка (Bulgarian 
National Bank) on 1 October 2020, the ECB became responsible for the direct 
supervision of five significant institutions and for the oversight of 13 less significant 
institutions in Bulgaria. Българска народна банка (Bulgarian National Bank) has 
been integrated into the Single Supervisory Mechanism and is participating in its 
structures and networks. Bulgarian significant institutions are now supervised by Joint 
Supervisory Teams supported by experts in horizontal line supervision. With regard to 
the oversight of less significant institutions, which have a domestic market share of 
roughly 30%, the ECB is working closely with national supervisors to further 
harmonise implementation of the rules governing banking supervision, while also 
ensuring that joint supervisory standards are applied consistently across the system. 
5.1.2 Fiscal developments
Bulgaria’s general government budget deficit was well above the 3% reference 
value in 2021, while its debt was well below the 60% reference value. In the 
reference year 2021, the general government budget recorded a deficit of 4.1% of 
GDP, thus standing well above the 3% deficit reference value. The general 
government gross debt-to-GDP ratio was 25.1%, well below the 60% reference value 
(Table 5.1.2). Compared with the previous year, the general government deficit 
increased by 0.1 percentage points and the debt ratio increased slightly by 
0.4 percentage points. With regard to other fiscal factors, the deficit ratio exceeded the 
ratio of public investment to GDP in 2021. The budget deficits in 2020 and 2021 were 
substantially affected by the economic impact of the COVID-19 pandemic and the 
fiscal policy measures taken in response to it. 
Bulgaria has been subject to the preventive arm of the Stability and Growth 
Pact since 2012. In May 2022, the European Commission found that the general 
government deficit-to-GDP ratio in 2021 was above and not close to the reference 
value of 3%. The excess over the reference value was considered to be exceptional 
and temporary, since the deficit was projected to fall below 3% of GDP in 2023. 
Overall, the Commission analysis suggested that the deficit criterion had not been 
fulfilled. However, taking into account the exceptional uncertainty created by the 
continued extraordinary macroeconomic and fiscal impact of the COVID-19 pandemic, 
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80 
together with the invasion of Ukraine by Russia, the Commission did not propose 
opening new excessive deficit procedures at that stage. In the preceding year, in June 
2021, the European Commission had found that the general government deficit in 
2020 was above but close to the reference value of 3% of GDP. The excess over the 
reference value was at the time considered to be exceptional and temporary, as 
defined by the Treaty. In sum, the analysis suggested that the deficit criterion had 
been fulfilled. Previously, Bulgaria had been subject to an excessive deficit procedure 
from 2010 to 2012. Owing to a rise in the budget deficit above the reference value in 
2009, the ECOFIN Council decided in July 2010 that an excessive deficit situation 
existed in Bulgaria and set 2011 as the deadline for correcting it. Following the 
correction of the excessive deficit, the ECOFIN Council abrogated the excessive 
deficit procedure for Bulgaria in June 2012. In the subsequent period to 2019, general 
government debt was well below the 60% of GDP reference value and the general 
government balance breached the reference value only in 2014, reaching a deficit of 
5.4% of GDP. Since the European Commission considered the excess over the 
reference value to be both exceptional and temporary, it concluded that opening an 
excessive deficit procedure was not warranted. 
Both cyclical and non-cyclical factors relating to the COVID-19 pandemic 
contributed to the deterioration in the budget balance over the period 2019-21. 
Prior to the COVID-19 crisis, prudent fiscal policy had allowed Bulgaria to record 
structural surpluses, which reached 1.4% of GDP in 2019. As a consequence of the 
COVID-19 crisis, the structural balance deteriorated strongly in 2020 by 
4.3 percentage points, mostly on account of higher current expenditure. This spending 
increase reflected, to a large extent, fiscal support measures which were taken in 
response to the pandemic. Moreover, cyclical factors contributed to the overall 
increase in the budget deficit by 6.1 percentage points in 2020, reflecting the 
deterioration in the economic situation. From 2020 to 2021, the structural deficit 
increased by another 0.9 percentage points on account of higher expenditure, 
whereas the cyclical component improved by 0.8 percentage points. 
The government debt-to-GDP ratio has remained well below the 60% reference 
value over the past two decades but it increased during the COVID-19 crisis. 
Prior to the COVID-19 crisis, the debt ratio had declined between 2016 and 2019 by 
9.1 percentage points to 20% of GDP, mostly owing to high primary surpluses and, to 
a lesser extent, favourable interest-growth differentials. Between 2019 and 2021, the 
debt ratio increased during the COVID-19 crisis by 5.1 percentage points, mainly on 
the back of primary deficits. 
In the presence of a long-standing currency board, the level and structure of 
public debt allow Bulgaria to manage its debt effectively. The share of 
government debt with a short-term maturity has generally been negligible. Taking into 
account the low share of debt with a variable interest rate and the level of the debt 
ratio, fiscal balances are relatively insensitive to changes in interest rates. At the same 
time, the proportion of foreign currency-denominated government debt is high (74.6% 
in 2021), although almost entirely denominated in euro – the anchor currency of 
Bulgaria’s currency board framework. Fiscal balances are thus insensitive to changes 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 279 – 
Convergence Report, June 2022 81 
in exchange rates other than the euro/lev exchange rate, which is fixed under the 
currency board. 
The European Commission’s Spring 2022 Economic Forecast predicts an 
improvement in the budget balance and a slight increase in the public debt 
ratio. According to the European Commission’s Spring 2022 Economic Forecast, the 
headline balance is expected to improve to a deficit of 3.7% of GDP in 2022 and thus 
remain above the 3% deficit reference value. The foreseen improvement in the 
general government balance stems mainly from the partial phasing-out of pandemic 
support measures, which outweighs new measures in response to high energy prices 
and the Russia-Ukraine conflict. The budget balance is projected to improve further in 
2023 and reach a deficit of 2.4% of GDP. Over the period 2022-23, the structural 
deficit is expected to stand well above the medium-term objective (a structural deficit 
of 1% of GDP). Nevertheless, in the context of the COVID-19 pandemic, the Stability 
and Growth Pact’s general escape clause, which continues to be applied in 2022 and 
is expected to also remain in place in 2023, provides that “in periods of severe
economic downturn for the euro area or the Union as a whole, Member States may be 
allowed temporarily to depart from the adjustment path towards the medium-term 
budgetary objective…, provided that this does not endanger fiscal sustainability in the 
medium term”.176 The debt ratio is projected to increase slightly to stand at 25.3% of 
GDP in 2022 and 25.6% of GDP in 2023. The 2022 headline deficit presented in the 
2022 convergence programme is 5.3% of GDP and thus much higher than the 
European Commission’s Spring 2022 Economic Forecast, while the projected debt 
ratio is slightly above the European Commission’s figure. 
Bulgaria’s fiscal framework has helped it to maintain a low debt ratio, but there 
is still scope for further improvement. Bulgaria has a large number of fiscal rules at 
the general government and subnational levels, which comprise budget balance, debt 
and expenditure rules. While those rules mitigate the risk of increasing debt, in 
practice they are complex to implement and therefore need to be streamlined. As a 
response to the COVID-19 crisis, the Public Finance Act was amended in 2020. Two 
of the amendments are aimed at increasing the flexibility of the fiscal rules in the case 
of economic downturns. Those revisions allow deviations from the 3% general 
government deficit ceiling and the expenditure rule in the case of extraordinary 
circumstances outside the control of the government which seriously impact the fiscal 
position. Moreover, the ceiling for the cash-based budget deficit was increased from 
2% to 3% and the maximum amount of expenditure under the consolidated fiscal 
programme was effectively increased, as EU funds and national co-financing were 
exempted from the scope of expenditure, while the maximum amount of 40% of GDP 
remained. Those revisions led to a lower stringency of the two rules. The Fiscal 
Council was introduced in 2016 in line with EU requirements, and its mandate and the 
quality of its work have been strengthened over time; further improvements in the 
areas of its technical and administrative capacities are nevertheless still needed. 
Progress made in tax collection and the reduction of the informal economy has 
contributed to significant growth in tax revenues and further progress should be 
pursued.  
176  For further details, see Box 2 in the Framework for analysis. 
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82 
Bulgaria faces medium risks to fiscal sustainability over the medium and long 
term. The European Commission’s 2021 Fiscal Sustainability Report found that 
Bulgaria faced medium fiscal sustainability risks over the medium term,177 with the 
magnitude of the change in debt being subject to particularly large uncertainty. Over 
the long term, it was found to face medium risks, which were mainly driven by a 
projected increase in ageing-related costs.178 According to the reference scenario 
from the 2021 Ageing Report prepared by the Ageing Working Group (AWG) of the 
EU’s Economic Policy Committee,179 age-related public expenditure is projected to 
increase notably by 2.1 percentage points of GDP over the period 2019-70, from a 
level of 16.2% of GDP in 2016. Under the AWG’s risk scenario, the increase in costs 
was even higher and amounted to 4.1 percentage points of GDP, owing to a larger rise 
in healthcare and in long-term care spending (by respectively 0.9 and 1.2 percentage 
points of GDP in comparison with the baseline scenario). These projections signalled 
a need for further reforms in order to enhance the long-term sustainability of public 
finances. 
Looking ahead, Bulgaria needs to gradually return to prudent fiscal policies 
despite the low level of public debt. While fiscal policy should remain agile in its 
response to the evolving pandemic situation and given the geopolitical situation, a 
consistent and prudent fiscal policy will ensure that Bulgaria will comply with the 
Stability and Growth Pact and maintains buffers to alleviate adverse shocks. 
Moreover, the Next Generation EU programme needs to be implemented effectively in 
order to support the recovery and to adjust to the structural changes that are under 
way. There is also scope for a more growth-friendly tax system and policies, as well as 
a more cost-effective provision of healthcare services. Safeguarding and extending 
the current reductions in tax collection gaps, further reducing the informal economy 
and increasing spending efficiency are all essential measures for preserving 
medium-term fiscal sustainability. 
5.1.3 Exchange rate developments 
On 10 July 2020 the ERM II parties decided, by mutual agreement, to include the 
Bulgarian lev in ERM II, and it therefore participated in ERM II for most of the 
two-year reference period from 26 May 2020 to 25 May 2022. The Bulgarian lev 
was included in ERM II at a central rate of 1.95583 levs per euro with a standard 
fluctuation band of ±15%. Bulgaria joined the exchange rate mechanism with its 
existing currency board in place, as a unilateral commitment, thus placing no 
additional obligations on the ECB. The agreement on participation in ERM II was 
based on a number of policy commitments by the Bulgarian authorities, some of which 
had already been met when the lev was included in ERM II, with the aim of achieving a 
high degree of sustainable economic convergence by the time of the adoption of the 
 
177  This assessment was confirmed by the updated debt sustainability analysis which was published as part 
of the European Commission’s country report for Bulgaria on 23 May 2022. 
178  However, this assessment does not necessarily reflect the uncertainty surrounding the long-term 
assumptions and, for high-debt countries, it should be viewed with caution. 
179  European Commission and Economic Policy Committee, “The 2021 Ageing Report: Economic and 
Budgetary Projections for the EU Member States (2019-2070)”, European Economy Institutional Paper, 
No 148, European Commission, 2021. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 281 – 
Convergence Report, June 2022 83 
euro. These commitments relate to implementing specific policy measures pertaining 
to the non-banking financial sector, state-owned enterprises, the insolvency 
framework and the anti-money-laundering (AML) framework, as well as implementing 
the extensive reforms carried out in the judiciary and in the fight against corruption and 
organised crime in Bulgaria, in the light of the importance of these reforms for the 
stability and the integrity of the financial system. The ECB and the European 
Commission have been monitoring the effective implementation of these 
commitments, acting within their respective areas of competence as provided for by 
the Treaties and secondary legislation. In its role as the supervisory authority and 
given its shared responsibility for macroprudential policy, the ECB is closely 
monitoring the implementation of the commitments related to the financial sector, i.e. 
the insolvency framework and the AML framework, owing to their potential impact on 
prudential aspects. Notwithstanding the fact that all of the steps envisaged in the ERM 
II post-entry commitments are broadly on track, Bulgaria is encouraged to address in a 
timely manner any shortcomings that Council of Europe’s Committee of Experts on the
Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism 
(MONEYVAL) might possibly identify in its ongoing assessment. Over the reference 
period the lev did not exhibit any deviation from the central rate. As implied by the 
currency board framework, Българска народна банка (Bulgarian National Bank) has 
continued to exchange on demand domestic currency against the anchor currency 
(the euro) and vice versa at the fixed rate. Short-term interest rate differentials against 
the three-month EURIBOR stood at a low level throughout the reference period. In 
July 2020 Българска народна банка (Bulgarian National Bank) entered a 
precautionary swap line arrangement with the ECB under which it could borrow up to 
€2 billion in exchange for Bulgarian levs in order to address possible euro liquidity 
needs of Bulgarian financial institutions owing to the pandemic. As this arrangement 
helped to reduce the potential risk of financial vulnerabilities, it may also have further 
supported the stability of the exchange rate over the reference period. 
The real effective exchange rate of the Bulgarian lev has appreciated slightly 
over the past ten years (Chart 5.1.4). However, this indicator should be interpreted 
with caution, as Bulgaria is subject to a process of economic convergence, which 
complicates any long-term assessment of real exchange rate developments. 
Bulgaria’s combined current and capital account balance has consistently 
remained in surplus over the past ten years and the country’s net foreign
liabilities have declined markedly (Table 5.1.3). From 2012 to 2019 the combined 
current and capital account improved, primarily reflecting a substantial reduction in the 
goods deficit on account of the export-led recovery and, in an initial phase, subdued 
domestic demand following a sharp contraction in activity. A surplus of 1.5% was 
recorded in 2020, which decreased further to 0.3% in 2021 reflecting a small current 
account deficit of 0.4% of GDP in that year. This deficit was mainly due to the 
contraction in exports of tourism services caused by the COVID-19 pandemic. 
Tourism revenues started to recover in 2021, although foreign tourist visits remained 
well below pre-crisis levels. While the substantial adjustment in the balance of 
payments was associated with a significant contraction in net direct investment inflows 
– which fell from double-digit levels before the global financial crisis to an average of
2.4% of GDP in the period 2017-21 – the balance on other investment recorded net
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84 
outflows. Gross external debt decreased further, falling from 71.8% of GDP in 2017 to 
61.8% in 2021. At the same time, the country’s net international investment position, 
largely consisting of foreign direct investment, continued to improve and rose from 
-43.0% of GDP in 2017 to -19.8% of GDP in 2021 on account of a further accumulation 
of reserve assets. Nevertheless, fiscal and structural policies continue to be important 
for supporting external sustainability and the competitiveness of the economy. 
The Bulgarian economy is well integrated with the euro area through trade and 
investment linkages. In 2021 exports of goods and services to the euro area 
constituted 45.2% of total exports, with the corresponding figure for imports standing 
at 41.1%. In the same year the share of the euro area in Bulgaria’s stock of inward 
direct investment stood at 64.7% and its share in the country’s stock of portfolio 
investment liabilities was 77.1%. The share of Bulgaria’s stock of foreign assets 
invested in the euro area amounted to 49.9% in the case of direct investment and 
47.2% for portfolio investment in 2021. 
5.1.4 Long-term interest rate developments 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in Bulgaria increased slightly and stood at 0.5% on average, well below the 
2.6% reference value for the interest rate convergence criterion (Chart 5.1.5). 
Long-term interest rates in Bulgaria declined from 5.3% in January 2012 to 1.6% 
in April 2022. Over the last decade long-term interest rate developments in Bulgaria 
have been driven by the gradual compression in risk premia and by structural factors 
that helped to contain market expectations of future rates. The decline in risk premia is 
mainly attributable to the lower macro-financial risk perceived by financial markets and 
the significant improvement in the liquidity conditions of banks. This was due to the 
disappearance of uncertainty relating to the global financial crisis, which led to an 
improvement in the financial situation of the Bulgarian banking system and thus in the 
outlook for the public budget. Other factors have also contributed to the declining trend 
in long-term interest rates over the last ten years. These include the relatively weak 
private credit demand until 2015, spillovers from low interest rates in the euro area, 
Bulgarian banks’ continued demand for government debt securities in the context of a 
limited supply of these securities and scarce opportunities for lending to the private 
sector, a high private savings rate, and the effect of global trade tensions on growth 
expectations and thus interest rates. From April 2020 the negative impact of the 
COVID-19 pandemic on global and domestic economic activity and inflation drove 
long-term interest rates in Bulgaria down to a historically low level of 0.1% in March 
2021, where they remained until August 2021. Since then and until February 2022, in 
a context of increasing domestic inflation, long-term interest rates gradually increased 
in line with global financial market developments, also owing to the concentration of a 
large volume of government bond issues in the domestic market in the fourth quarter 
of 2021. In the last two months of the review period, the increase in long-term interest 
rates was steeper as a result of mounting global and domestic inflationary pressures. 
Hence, long-term interest rates in Bulgaria increased over the review period and stood 
at 1.6% in April 2022, up from 0.2% in April 2020 (Chart 5.1.5). The steady 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 283 – 
Convergence Report, June 2022 85 
improvement in Bulgaria’s macroeconomic performance and the stability of its fiscal 
outlook have also contributed to the decline in the default risk on long-term Bulgarian 
debt – as measured by ten-year credit default swap spreads – which fell from over 400 
basis points in early 2012 to around 115 basis points in April 2022. Bulgaria’s
government debt is rated investment grade by all three main rating agencies 
(Moody’s: Baa1; S&amp;P: BBB; Fitch: BBB).
The long-term interest rate differential of Bulgarian government bonds vis-à-vis 
the euro area average stood at 0.2% in April 2022. Since 2012 Bulgarian long-term 
interest rates have gradually and continuously converged towards the euro area 
average rate of corresponding maturity (Chart 5.1.6). Initially, stable and relatively 
high rates in Bulgaria combined with a decline in the long-term average interest rate in 
the euro area led to some widening of the differential, which came close to, but never 
beyond, 2.0% for a few months in 2014 and in 2016. From late 2016 the differential 
declined steadily and, after remaining in negative territory for more than a year owing 
to heightened political and economic uncertainty in some euro area countries, it turned 
slightly positive in mid-2019. Since then it has fluctuated within a narrow range of 
between 0.0% and 0.5%. In April 2022 it stood at 0.2% (0.7% vis-à-vis the euro area 
AAA yield). 
Capital markets in Bulgaria are smaller and less developed than in the euro area 
(Table 5.1.4). In the past few years only a few indications have emerged of any 
deepening of capital markets compared with early 2012. In recent years stock market 
capitalisation, as a percentage of GDP, has increased from an average of 10.7% over 
the period 2012-16 to 23.0% in 2021. Market-based debt financing of domestic 
monetary financial institutions (MFIs) has increased slightly since 2012 to stand at 
1.6% of GDP. Over the same period, the access of non-financial corporations in 
Bulgaria to the corporate debt market seems to have remained broadly unchanged, as 
outstanding debt securities issued by this sector accounted for 2.5% of GDP in 2021, 
which is 0.4 percentage points of GDP lower than in the period 2012-16. In 2021 the 
reliance of the Bulgarian banking system on euro area banks for its funding needs 
remained very limited and much lower than the average over the period 2012-16. Euro 
area banks’ claims on Bulgarian banks remained at historically low levels of 4.0% in 
2021. The degree of financial intermediation remains quite low in Bulgaria compared 
with the euro area average, even if it is comparable to that of peer countries in the 
region. MFI credit to non-government residents stood at 54.6% of GDP in 2021, just 
over 6 percentage points below its average for the period 2012-16. At the end of 2020 
foreign-owned banks continued to play a major role in the banking system in Bulgaria, 
accounting for more than 75% of total banking assets. The banking system is largely 
funded by resident private non-financial sector deposits (around 89% of total 
liabilities). The banking system’s assets vis-à-vis the non-financial private sector were 
dominated by loans, 68% of which were denominated in local currency. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 284 –
Bulgaria - Price developments
S 1 ECB Convergence Report, May 2022 
Chart 5.1.1 HICP inflation and reference value 1) 
(annual percentage changes)
-5
0
5
10
15
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
-5
0
5
10
15
HICP
HICP (12-month moving average)
Reference value
Sources: European Commission (Eurostat) and ECB calculations.
1) The basis of the calculation of the reference value for the period from May 2021 to April 2022 is the unweighted arithmetic average of the annual percentage
changes in the HICP for France, Finland and Greece plus 1.5 percentage points. The reference value is 4.9%.
Table 5.1.1 Measures of inflation and related indicators
(annual percentage changes, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Measures of inflation           
 HICP 0.9 -0.3 2.1 1.2 2.6 2.5 1.2 2.8 11.9 5.0
 HICP excluding unprocessed food and energy 0.8 -0.1 1.8 0.3 2.1 2.5 2.0 1.9 9.5 6.1
 HICP at constant tax rates 3) 0.9 -0.3 2.1 1.0 2.4 2.4 1.5 3.2 - -
 CPI 1.4 0.3 2.6 2.1 2.8 3.1 1.7 3.3 11.9 5.0
 Private consumption deflator 1.9 1.4 2.4 4.6 2.4 2.0 -0.6 3.6 11.9 4.7
 GDP deflator 3.3 1.8 4.9 4.8 4.2 5.2 4.2 6.2 9.5 3.9
 Producer prices 4) 2.4 -0.3 5.2 4.2 4.1 3.8 -0.2 14.9 - -
 Related indicators           
 Real GDP growth 1.7 1.5 1.8 2.8 2.7 4.0 -4.4 4.2 2.1 3.1
 GDP per capita in PPS 5) (euro area = 100) 46.4 44.1 49.3 47.0 48.2 49.9 52.3 . - -
 Comparative price levels (euro area = 100) 48.7 47.7 50.0 48.5 49.1 50.6 51.9 . - -
 Output gap 6) -0.4 -0.5 -0.2 0.2 0.6 2.5 -3.5 -1.0 -0.4 1.0
 Unemployment rate (%) 7) 8.8 11.7 6.0 7.2 6.2 5.2 6.1 5.3 5.4 5.3
 Unit labour costs, whole economy 5.8 4.7 6.8 9.5 6.7 3.1 9.5 5.4 7.7 4.8
 Compensation per employee, whole economy 7.7 6.7 8.7 10.5 9.7 6.9 7.2 9.5 9.7 7.7
 Labour productivity, whole economy 1.9 1.9 1.8 1.0 2.8 3.7 -2.1 4.0 1.9 2.7
 Imports of goods and services deflator 0.7 -1.5 2.9 6.7 2.0 0.0 -6.6 13.5 11.2 4.2
 Nominal effective exchange rate 8) 1.5 0.9 2.1 1.8 3.7 0.1 3.1 2.0 - -
 Money supply (M3) 9) 9.0 8.2 9.9 8.5 8.6 10.1 11.4 10.7 - -
 Lending from banks 10) 5.3 2.0 8.6 7.8 9.9 10.6 5.3 9.7 - -
 Stock prices (SOFIX) 11) 97.3 82.1 8.4 15.5 -12.3 -4.4 -21.2 42.0 - -
 Residential property prices 4.1 1.4 6.9 8.7 6.6 6.0 4.6 8.7 - -
Sources: European Commission (Eurostat, Directorate-General for Economic and Financial Affairs), national data for CPI, money supply, lending from banks
and ECB calculations based on Bloomberg Finance L.P. data for stock prices.
1) Multi-annual averages calculated using the geometric mean, except for GDP per capita in PPS, comparative price levels, output gap and unemployment rate, for which the
arithmetic mean is used.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) The difference between the HICP and the HICP at constant tax rates shows the theoretical impact of changes in indirect taxes (e.g. VAT and excise duties) on the overall rate
of inflation. This impact assumes a full and instantaneous pass-through of tax rate changes to the price paid by the consumer.
4) Domestic sales, total industry excluding construction.
5) PPS stands for purchasing power standards.
6) Percentage difference from potential GDP: a positive (negative) sign indicates that actual GDP is above (below) potential GDP.
7) Definition conforms to International Labor Organization guidelines.
8) EER-42 group of trading partners. A positive (negative) sign indicates an appreciation (depreciation).
9) The series includes repurchase agreements with central counterparties.
10) Adjusted for the derecognition of loans from the MFI statistical balance sheet due to their sale or securitisation.
11) Multi-annual and annual figures represent the percentage change between the end of the given period and the end of the previous period.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 285 – 
Bulgaria - Fiscal developments
S 2 ECB Convergence Report, May 2022 
Chart 5.1.2 General government balance and debt
(as a percentage of GDP)
-11
-9
-7
-5
-3
-1
1
3
5
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
10
20
30
40
50
60
70
80
90
100
110
Government balance (left-hand scale)
Government debt (right-hand scale)
Reference values (government balance: -3%; government debt: 60%)
Sources: European System of Central Banks and European Commission (Eurostat).
Table 5.1.2 Government budgetary developments and projections
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Government balance -1.1 -1.7 -0.5 1.6 1.7 2.1 -4.0 -4.1 -3.7 -2.4
 Total revenue 37.3 36.4 38.2 37.1 38.7 38.4 38.1 39.0 40.2 40.7
 Current revenue 35.7 34.2 37.2 36.0 37.9 37.5 36.7 37.8 37.8 38.1
 Direct taxes 5.6 5.2 6.0 5.9 5.8 5.8 5.9 6.4 6.1 6.6
 Indirect taxes 15.2 15.0 15.3 15.3 14.7 15.3 15.1 16.1 16.7 16.6
Net social contributions 8.2 7.5 8.8 8.2 8.7 8.8 9.2 9.3 9.2 9.3
Other current revenue 3) 6.8 6.5 7.1 6.6 8.7 7.6 6.6 6.0 5.8 5.6
 Capital revenue 1.6 2.2 1.1 1.1 0.8 0.9 1.3 1.2 2.4 2.6
 Total expenditure 38.4 38.1 38.8 35.4 37.0 36.3 42.0 43.1 43.9 43.1
 Current expenditure 33.4 32.3 34.5 32.0 32.9 31.8 36.9 39.0 37.9 36.5
Compensation of employees 9.7 9.1 10.2 9.1 9.5 10.0 10.8 11.7 11.2 11.1
 Social benefits 13.8 13.7 13.8 13.3 13.0 12.7 14.5 15.4 15.2 14.7
 Interest payable 0.7 0.8 0.6 0.8 0.7 0.6 0.5 0.5 0.5 0.5
Other current expenditure 4) 9.2 8.6 9.9 8.8 9.8 8.5 11.0 11.4 11.0 10.2
 Capital expenditure 5.0 5.8 4.2 3.4 4.1 4.5 5.2 4.1 5.9 6.6
 of which: Investment 3.8 4.4 3.2 2.3 3.1 3.3 3.8 3.3 5.0 5.4
Cyclically adjusted balance -1.0 -1.5 -0.4 1.6 1.5 1.4 -2.9 -3.8 -3.5 -2.7
One-off and temporary measures -0.3 -0.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
 Structural balance 5) -0.7 -0.9 -0.4 1.6 1.5 1.4 -2.9 -3.8 -3.5 -2.7
 Government debt 23.3 23.1 23.4 25.1 22.1 20.0 24.7 25.1 25.3 25.6
Average residual maturity (in years) 7.3 7.0 7.7 7.6 7.1 6.9 8.8 8.1 . .
In foreign currencies (% of total) 79.1 78.7 79.6 78.4 81.5 81.0 82.4 74.6 . .
 of which: Euro 74.5 70.2 78.7 77.3 80.4 80.1 81.8 74.0 . .
Domestic ownership (% of total) 52.7 50.7 54.6 56.5 56.0 55.8 50.9 54.0 . .
Medium and long-term maturity (% of total) 6) 97.3 94.7 99.9 99.9 99.9 100.0 100.0 99.9 . .
  of which: Variable interest rate (% of total) 9.3 13.6 4.9 8.4 5.2 4.7 3.3 3.0 . .
 Deficit-debt adjustment 1.1 1.9 0.3 -0.3 0.4 1.9 0.6 -1.3 . .
Net acquisitions of main financial assets 0.8 1.6 0.0 -0.8 0.1 -0.7 0.6 0.9 . .
Currency and deposits 0.7 1.3 0.1 -0.8 0.2 -0.4 0.7 0.9 . .
 Debt securities 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 . .
 Loans 0.1 0.2 0.0 0.0 0.0 0.0 0.0 0.1 . .
Equity and investment fund shares or units 0.0 0.1 -0.1 0.0 -0.1 -0.4 -0.1 -0.1 . .
Revaluation effects on debt 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 . .
 of which: Foreign exchange holding
 gains/losses 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 . .
 Other 7) 0.3 0.3 0.2 0.6 0.2 2.6 0.0 -2.3 . .
 Convergence programme: government balance - - - - - - - - -5.3 -2.9
 Convergence programme: structural balance - - - - - - - - -3.1 -2.7
 Convergence programme: government debt - - - - - - - - 25.5 27.7
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast, except for convergence programme data.
3) Sales and other current revenue.
4) Intermediate consumption, subsidies payable and other current expenditure.
5) Cyclically adjusted balance excluding one-off and other temporary measures.
6) Original maturity of more than one year.
7) Time of recording differences and other factors (sector reclassifications and statistical discrepancies).
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 286 –
Bulgaria - Exchange rate and external developments
S 3 ECB Convergence Report, May 2022 
Chart 5.1.3 Bilateral exchange rate and short-term
interest rate differential 1) 
Chart 5.1.4 Effective exchange rates 2) 
(EER-42 group of trading partners; monthly averages; index: Q1 1999 = 100)
(BGN/EUR exchange rate: monthly averages;
difference between three-month interbank interest rates
and three-month EURIBOR: basis points, monthly values)
2.2
2.1
2.0
1.9
1.8
1.7
2012 2014 2016 2018 2020
0.0
0.5
1.0
1.5
2.0
2.5
BGN/EUR exchange rate (left-hand scale)
Interest rate differential (right-hand scale)
105
113
121
129
137
145
2012 2014 2016 2018 2020
135
139
143
147
151
155
Nominal (left-hand scale)
Real (right-hand scale)
Sources: National data and ECB calculations.
1) The interest rate differential is calculated against SOFIBOR. Production of SOFIBOR
reference rate was discontinued by the national central bank as of 1 July 2018;
a comparable rate is not currently available.
Source: ECB.
2) The real EER-42 is CPI-deflated. An increase (decrease) in the EER indicates
an appreciation (depreciation).
Table 5.1.3 External developments
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Balance of payments
Current account and capital account balance 3) 2.6 2.9 2.3 4.3 2.0 3.3 1.5 0.3 0.7 0.5
Current account balance 1.0 0.9 1.1 3.3 0.9 1.9 -0.1 -0.4 -1.8 -1.8
 Goods -5.0 -6.1 -3.8 -1.5 -4.8 -4.7 -3.2 -4.9 . .
 Services 6.5 6.4 6.6 5.8 7.3 8.0 5.0 6.6 . .
 Primary income -3.8 -3.5 -4.0 -4.3 -4.8 -4.2 -3.5 -3.3 . .
 Secondary income 3.3 4.2 2.4 3.3 3.2 2.9 1.5 1.1 . .
Capital account balance 1.6 2.0 1.2 1.0 1.1 1.4 1.5 0.7 . .
Combined direct and portfolio investment balance 3) -1.1 -2.9 0.7 2.9 1.4 0.6 -3.3 1.7 . .
 Direct investment -2.3 -2.2 -2.4 -2.5 -1.3 -2.0 -4.5 -1.7 . .
 Portfolio investment 1.2 -0.7 3.1 5.4 2.8 2.6 1.2 3.4 . .
Other investment balance 1.6 2.6 0.6 1.2 1.7 4.3 -2.1 -1.9 . .
 Reserve assets 3.9 4.6 3.2 -0.2 2.4 -0.9 9.4 5.3 . .
Exports of goods and services 63.4 63.4 63.4 67.0 65.7 63.9 56.3 64.2 . .
Imports of goods and services 61.9 63.1 60.7 62.7 63.2 60.7 54.4 62.4 . .
Net international investment position 4) -48.9 -66.3 -31.4 -43.0 -37.0 -30.2 -27.1 -19.8 . .
Gross external debt 4) 76.4 87.6 65.2 71.8 66.1 61.3 64.9 61.8 . .
 Trade with the euro area 5)
Exports of goods and services 43.4 42.4 44.3 42.4 44.6 44.0 45.6 45.2 . .
 Imports of goods and services 42.2 42.6 41.8 42.8 42.6 41.6 40.8 41.1 . .
 Investment position with the euro area 5)
Direct investment assets 4) 49.6 51.0 48.2 46.0 47.2 48.2 49.5 49.9 . .
Direct investment liabilities 4) 65.4 65.7 65.1 66.1 65.8 65.2 63.8 64.7 . .
Portfolio investment assets 4) 45.4 47.4 43.4 44.3 41.2 43.5 41.0 47.2 . .
Portfolio investment liabilities 4) 74.7 72.2 77.2 79.9 83.5 71.8 73.6 77.1 . .
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) Differences between totals and the sum of their components are due to rounding.
4) End-of-period outstanding amounts.
5) As a percentage of the total.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 287 – 
Bulgaria - Long-term interest rate developments
S 4 ECB Convergence Report, May 2022 
Chart 5.1.5 Long-term interest rate 1) 
(monthly averages in percentages)
Chart 5.1.6 Long-term interest rate and HICP inflation
differentials vis-à-vis the euro area
(monthly averages in percentage points)
0
1
2
3
4
5
6
2012 2014 2016 2018 2020
0
1
2
3
4
5
6
Long-term interest rate
Long-term interest rate (12-month moving average)
Reference value
-4
-3
-2
-1
0
1
2
3
4
2012 2014 2016 2018 2020
-4
-3
-2
-1
0
1
2
3
4
Long-term interest rate differential
HICP inflation differential
Sources: European System of Central Banks and ECB calculations.
1) The basis of the calculation of the reference value for the period from May
2021 to April 2022 is the unweighted arithmetic average of the interest rate
levels in France, Finland and Greece plus 2 percentage points. The reference
value is 2.6%.
Sources: European System of Central Banks, ECB calculations and European
Commission (Eurostat).
Table 5.1.4 Long-term interest rates and indicators of financial development and integration
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2018 2019 2020 2021 May. 2021 Memo item:
to euro area
Apr. 2022 2021
 Long-term interest rates
 Bulgaria 2) 1.9 3.2 0.7 0.9 0.4 0.3 0.2 0.5 -
 Euro area 3), 4) 1.4 2.2 0.6 1.1 0.4 0.1 0.1 0.4 -
Euro area AAA par curve, ten-year residual maturity 2), 4) 0.6 1.2 0.0 0.5 -0.2 -0.4 -0.3 -0.1 -
 Indicators of financial development and integration
Debt securities issued by financial corporations 5) 1.1 1.1 1.2 1.0 1.1 1.2 1.6 - 66.7
Debt securities issued by non-financial corporations 6) 2.8 2.9 2.8 2.8 2.6 2.7 2.5 - 13.4
Stock market capitalisation 7) 17.0 10.7 23.4 24.3 23.2 23.4 23.0 - 77.7
MFI credit to non-government residents 8) 57.2 60.9 53.6 52.9 53.0 55.5 54.6 - 111.1
Claims of euro area MFIs on resident MFIs 9) 5.4 7.5 3.3 3.2 3.3 2.9 4.0 - 29.5
Sources: European System of Central Banks and ECB calculations.
1) Multi-annual averages calculated using the arithmetic mean.
2) Average interest rate.
3) GDP-weighted average of the euro area long-term interest rates for the purpose of assessing convergence.
4) Included for information only.
5) Outstanding amount of debt securities issued by resident MFIs (excluding the national central bank) and other financial corporations.
6) Outstanding amount of debt securities issued by resident non-financial corporations.
7) Outstanding amount of listed shares issued by residents at market values.
8) MFI (excluding national central bank) credit to domestic non-MFI residents other than general government. Credit comprises outstanding amounts of loans and debt securities.
9) Outstanding amount of deposits and debt securities issued by domestic MFIs (excluding the national central bank) held by euro area MFIs as a percentage of total liabilities 
of domestic MFIs (excluding the national central bank). Total liabilities exclude capital and reserves and remaining liabilities.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 288 –
 
Convergence Report, June 2022 
 
90 
5.2 Czech Republic 
5.2.1 Price developments 
In April 2022 the 12-month average rate of HICP inflation in the Czech Republic 
was 6.2%, i.e. well above the reference value of 4.9% for the criterion on price 
stability (Chart 5.2.1). This rate is expected to increase gradually over the coming 
months, driven mainly by the higher commodity prices, broadening price pressures 
and further aggravation of supply bottlenecks resulting from the Russia-Ukraine war. 
Over the past ten years the 12-month average rate of HICP inflation has 
fluctuated within a relatively wide range, from 0.2% to 6.2%, and the average for 
that period was moderate, standing at 2.0%. Between 2012 and 2015 inflation fell 
significantly as a result of global commodity price developments and an economic 
recession during the period 2012-13. Import price growth accelerated in 2014, owing 
partly to the exchange rate floor of 27 korunas per euro set by Česká národní banka as 
a complementary and temporary instrument for lifting inflation towards its 2% inflation 
target. The Czech economy returned to a path of solid economic growth in the second 
half of the decade, which led to a notable appreciation in the koruna against the euro 
and in real effective terms. In addition, growth in compensation per employee 
exceeded labour productivity growth throughout the period under review (Table 5.2.1), 
which generated constant upward pressure on core inflation. Having grown by 3.0% in 
2019, real GDP contracted markedly by 5.8% in 2020 on account of the coronavirus 
(COVID-19) pandemic. Following that sharp economic contraction, HICP inflation 
started to decline gradually towards the 2% target in the second half of the year, 
largely reflecting the stalling economy and developments in global markets. To 
counteract the economic effects of the pandemic, Česká národní banka cut its main 
policy rate by a cumulative 200 basis points over the period from March to May 2020, 
bringing it down to 0.25%, close to its all-time low of 0.05% (in November 2012). In the 
second half of 2021, large increases in the prices of energy and international 
commodities (including food), coupled with global supply bottlenecks, put significant 
upward pressure on HICP inflation and core inflation. Government support measures 
aimed at stabilising employment and providing emergency liquidity proved effective in 
supporting domestic consumption, generating sustained inflationary pressures during 
the economic recovery. To counter the acceleration in inflation, and with the economic 
recovery under way, Česká národní banka started a monetary policy tightening cycle 
in June 2021, which has thus far led to a cumulative 550 basis point hike in its main 
policy rate. 
In the first four months of 2022 the average annual rate of HICP inflation stood 
at 11.0%. Inflationary pressures remained elevated and became more broad-based, 
spreading from the energy sector to other sectors of the economy such as food and 
services (particularly in relation to leisure and contact-intensive activities). On the 
domestic front, the main sources of the inflationary pressures were strong demand 
from households as a result of pandemic-related fiscal support measures, excess 
savings and positive wealth effects from robust financial and real estate markets, 
especially for wealthier households, as well as strong wage growth and rising 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 289 – 
Convergence Report, June 2022 91 
owner-occupied housing costs. On the external front, increasing energy prices and the 
rise in producer prices owing to disruptions in global value chains and 
pandemic-related factory shutdowns also continued to put upward pressure on 
consumer price inflation. The growth in energy and food prices was notably amplified 
by developments in international commodity markets following Russia’s invasion of 
Ukraine in late February 2022. Continuing its monetary policy tightening cycle, Česká
národní banka raised its main policy rate by a cumulative 200 basis points at its Bank 
Board meetings in February, March and May 2022, up to 5.75% from 3.75% in 
December 2021. 
The orientation of monetary policy towards price stability has played an 
important role in shaping inflation dynamics in the Czech Republic over the 
past decade. Since April 2001 the inflation target has been defined in terms of CPI 
inflation, originally as a continuously declining band and since 2006 as a flat point 
target. The CPI inflation target was set at 3% (±1 percentage point) in 2006 and 
reduced to 2% (±1 percentage point) on 1 January 2010. In November 2013, in order 
to fulfil its mandate to maintain price stability, Česká národní banka intervened to 
weaken the domestic currency and set the aforementioned exchange rate floor. When 
the bank abandoned its commitment to a minimum exchange rate vis-à-vis the euro in 
April 2017, the related policy shift was smooth, with the Czech koruna appreciating 
gradually. The exit from the exchange rate floor was the first step towards normalising 
domestic monetary conditions and was followed by a sequence of increases in Česká
národní banka’s interest rates from 2017 until early 2020. 
Inflation in the Czech Republic is expected to continue its upward trend in the 
near term and remain above the upper bound of the target interval over the 
forecast horizon. However, the forecasts are subject to considerable 
uncertainty in the light of the Russia-Ukraine war. According to the European 
Commission’s Spring 2022 Economic Forecast, HICP inflation is expected to rise 
significantly to 11.7% in 2022, owing to increasing levels of HICP inflation excluding 
food and energy, which is expected to reach 8.9%. It is then expected to decline to 
4.5% in 2023. Particularly during the first half of 2022, factors such as high energy and 
administered prices, supply bottlenecks and elevated international commodity prices 
are expected to keep HICP inflation at a high level. If the effects of those factors 
subside, inflation is expected to fall gradually towards the upper bound of the target 
interval over the forecast horizon, supported also by tighter domestic monetary and 
macroprudential policies, an appreciation of the koruna and declining administered 
prices. Overall, risks to the inflation outlook are tilted to the upside in the near term, 
owing mostly to a higher pass-through of production costs to final consumer prices 
and higher than anticipated wage increases, in an environment of significantly lower 
real wages. Price growth could also continue to surprise on the upside beyond the 
near term if inflation expectations become unanchored from the 2% target, or if the 
koruna weakens as a result of geopolitical tensions or tighter global monetary 
conditions, which would reduce the current positive interest rate differential. 
Nevertheless, tighter domestic monetary and macroprudential policies alongside the 
unwinding of emergency fiscal support measures and fiscal consolidation could 
dampen household demand more strongly than expected and thus stall price growth. 
Looking further ahead, the catching-up process may result in positive inflation 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 290 –
 
Convergence Report, June 2022 
 
92 
differentials vis-à-vis the euro area, since GDP per capita and price levels are still 
relatively lower in the Czech Republic than in the euro area, unless this is 
counteracted by an appreciation in the nominal exchange rate. In order to prevent the 
build-up of excessive price pressures and macroeconomic imbalances, the 
catching-up process must be supported by appropriate policies. 
Maintaining sustainable convergence in the Czech Republic requires targeted 
economic policies, including structural reforms, that are geared towards 
fostering price and macroeconomic stability. With regard to macroeconomic 
imbalances, the European Commission did not select the Czech Republic for an 
in-depth review in its Alert Mechanism Report 2022. The Czech Republic is facing the 
challenge of boosting its economic growth potential by enhancing productivity. 
Economic and financial policies should aim to achieve broad efficiency gains by 
appropriately reallocating capital to bolster innovation and the knowledge-intensive 
sectors. To this end, it will be important to strengthen administrative and institutional 
capacity (e.g. in areas such as governance and insolvency) and address inefficiencies 
in the business environment that weigh on potential growth by hindering innovation 
and the development of new business. In addition, the lack of skilled labour should be 
addressed with targeted investments aimed at improving both the quality of higher 
education and the domestic business environment in high productivity sectors. 
Enhancing access to equity finance and venture capital for small and medium-sized 
enterprises, encouraging innovation (e.g. with tax incentives and grants for research 
and development) and improving insolvency frameworks will therefore be crucial to 
helping the economy operate at its full potential. 
Financial sector policies should be aimed at safeguarding financial stability and 
ensuring that the financial sector can contribute to sustainable economic 
growth. Risks in the Czech Republic’s financial sector relate to the rapid growth in 
mortgage lending and the sustained acceleration in house prices, in an environment of 
increased risk-taking by households on the back of loose credit conditions. The 
current domestic macro-financial environment and its medium-term outlook have both 
been determined largely by the post-pandemic economic recovery and warranted a 
tightening of macroprudential policy. The stricter borrower-based limits 
(debt-to-income ratio, debt service-to-income ratio and loan-to-value ratio), which 
came into force in April 2022, are expected to reduce the risk of negative feedback 
loops between house price growth and banks’ mortgage lending. The recalibration of 
the countercyclical capital buffer to a level of 2.5%, which will have been fully phased 
in by April 2023, should also limit the build-up of risks in the housing and credit 
markets. In order to further bolster confidence in the financial system, the national 
competent authorities should continue to improve their supervisory practices, among 
other things, by following the applicable recommendations from the relevant 
international and European bodies, and by collaborating closely with other national 
supervisors of EU Member States within the supervisory colleges. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 291 – 
Convergence Report, June 2022 93 
5.2.2 Fiscal developments
The Czech Republic’s general government budget deficit was well above the 3% 
reference value in 2021, while its debt was below the 60% reference value. In the 
reference year 2021, the general government budget balance recorded a deficit of 
5.9% of GDP, thus well above the 3% deficit reference value. The general government 
gross debt-to-GDP ratio was 41.9%, i.e. below the 60% reference value (Table 5.2.2). 
Compared with the previous year, the government deficit-to-GDP ratio increased by 
0.1 percentage points, while the debt-to-GDP ratio increased notably by 
4.2 percentage points. With regard to other fiscal factors, the deficit ratio exceeded the 
ratio of public investment to GDP in 2021. The budget deficits in 2020 and 2021 were 
substantially affected by the economic impact of the COVID-19 pandemic and the 
fiscal policy measures taken in response to it. However, some measures taken in 2021 
are considered to have had a lasting negative effect on the budget balance. In 
particular, the 2021 income tax reform (which embeds a broad rate cut of around 
5 percentage points) and the cancellation of the property sales tax are of a more 
permanent nature and have lowered revenue generation in the medium term 
significantly. 
The Czech Republic has been subject to the preventive arm of the Stability and 
Growth Pact since 2014. In May 2022, the European Commission found that the 
general government deficit in 2021 was above and not close to the reference value of 
3% of GDP. The excess over the reference value was considered to be exceptional 
but not temporary. Overall, the Commission’s analysis suggested that the deficit 
criterion had not been fulfilled. However, taking into account the exceptional 
uncertainty created by the continued extraordinary macroeconomic and fiscal impact 
of the COVID-19 pandemic, together with the invasion of Ukraine by Russia, the 
Commission did not propose opening new excessive deficit procedures at that stage. 
In the preceding year, in June 2021, the European Commission had found that the 
general government deficit in 2020 was above and not close to the reference value of 
3% of GDP, but it had argued against taking a decision to place Member States under 
the excessive deficit procedure in light of the exceptional uncertainty. Previously, the 
Czech Republic had been subject to an excessive deficit procedure between 
December 2009 and June 2014. In the subsequent period to 2019, the Czech 
Republic comfortably met its medium-term objective of a structural deficit of no more 
than 1% of GDP. 
Both cyclical and non-cyclical factors relating to the COVID-19 pandemic 
contributed to the deterioration in the budget balance over the period 2019-21. 
Already prior to the COVID-19 crisis, the fiscal position had weakened significantly 
from a surplus of 1.5% of GDP in 2017 to 0.3% in 2019, driven by a deterioration in the 
structural balance. As a consequence of the COVID-19 crisis, this weakening 
accelerated in 2020 as the structural balance deteriorated strongly by 3.2 percentage 
points, mostly on account of higher expenditure. This spending increase reflected, to a 
large extent, fiscal support measures which were taken in response to the pandemic. 
Moreover, cyclical factors contributed to the overall increase in the budget deficit by 
2.9 percentage points in 2020, reflecting the deterioration in the economic situation. 
From 2020 to 2021, the structural deficit increased by a further 0.8 percentage points, 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 292 –
 
Convergence Report, June 2022 
 
94 
mainly on account of lower tax receipts due to the personal income tax reform, 
whereas the cyclical component improved by 0.7 percentage points. 
The debt-to-GDP ratio has increased over the past two years after having been 
on a declining path in the period 2014-19, remaining well below the 60% 
reference value. Prior to the COVID-19 crisis, the debt ratio had decreased by 
14.3 percentage points from its peak value of 44.4% of GDP in 2013, to 30.1% of GDP 
in 2019. The reduction was mostly driven by primary surpluses and favourable 
interest-growth differentials. Between 2019 and 2021, the debt ratio increased during 
the COVID-19 crisis by 11.8 percentage points, mainly on account of large primary 
deficits as expenditure increased strongly to support the economy during the 
pandemic. The increase in the debt-to-GDP ratio was also driven by a deficit-debt 
adjustment of 1.4 percentage points of GDP in 2020. 
The level and structure of government debt protect the Czech Republic from 
any sudden changes in market conditions, with the bulk of debt at long-term 
maturities and most debt denominated in local currency. The share of 
government debt with a short-term maturity is low (2.5% in 2021 – Table 5.2.2). Taking 
into account also the share of debt with a variable interest rate and the overall level of 
the debt ratio, fiscal balances are relatively insensitive to changes in interest rates. 
The proportion of foreign currency-denominated government debt is low (7.7% in 
2021); it is mostly denominated in euro (95% of foreign-denominated debt). 
Considering the size of the debt ratio, fiscal balances are also relatively insensitive to 
changes in exchange rates. The share of debt denominated in foreign currencies has 
been on a decreasing path and stands well below the 2010-14 average (21.8%), 
pointing to a decline in exchange rate-related vulnerabilities. 
The European Commission’s Spring 2022 Economic Forecast predicts an 
improvement in the budget balance and a moderate increase in the public debt 
ratio. According to the European Commission’s Spring 2022 Economic Forecast, the 
headline balance is expected to improve to a deficit of 4.3% of GDP in 2022 and thus 
stay well above the 3% deficit reference value. The foreseen improvement in the 
general government balance stems from the improving macroeconomic outlook and 
the phasing-out of fiscal measures implemented to mitigate the adverse effects of the 
crisis. The budget balance is projected to improve slightly in 2023 and reach a deficit 
of 3.9% of GDP. Over the period 2022-23, the structural deficit is expected to stand 
well above the medium-term objective. Nevertheless, the Stability and Growth Pact’s 
general escape clause, which continues to be applied in 2022 and is also expected to 
remain in place in 2023, provides that “in periods of severe economic downturn for the 
euro area or the Union as a whole, Member States may be allowed temporarily to 
depart from the adjustment path towards the medium-term budgetary objective…, 
provided that this does not endanger fiscal sustainability in the medium term”. In 2022 
the debt ratio is projected to increase to 42.8% of GDP, before rising further to stand at 
44% in 2023. The Czech Republic’s medium-term fiscal policy strategy, as presented 
in the 2022 update of the convergence programme, forecasts a path for both the 
nominal and the structural deficit which is somewhat more optimistic than that shown 
in the European Commission’s Spring 2022 Economic Forecast. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 293 – 
Convergence Report, June 2022 95 
The Czech Republic’s fiscal governance framework is applied effectively but 
further progress remains warranted. The national legislation implementing the EU 
Directive on requirements for budgetary frameworks was adopted in 2017. Since then, 
the Fiscal Council has become operational and issued reports on long-term 
sustainability and on compliance with the budgetary rules. Nevertheless, coordination 
among the various levels of general government remains low and should be further 
enhanced. With regard to tax compliance, tax collection has benefited from the 
implementation of several measures, in particular the electronic registration of sales. 
Policies aimed at improving tax collection should be continued. 
The Czech Republic faces medium risks to fiscal sustainability over the 
medium term and high risks over the long term. The European Commission’s 
2021 Fiscal Sustainability Report found that the Czech Republic faced medium fiscal 
sustainability risks over the medium term,180 as government debt (which currently 
stands at 42% of GDP) is projected to rise to 67% of GDP in 2032. Moreover, a 
sensitivity to macro-fiscal shocks also contributed to this assessment. Over the long 
term, it was found to face high risks, which were primarily linked to budgetary 
pressures stemming from population ageing and the initial budgetary position but were 
also due to risks from a debt sustainability analysis perspective.181 Indeed, according 
to the 2021 Ageing Report prepared by the Ageing Working Group (AWG) of the EU’s
Economic Policy Committee,182 the Czech Republic would record a significant rise in 
age-related expenditure (6.1 percentage points of GDP by 2070) under the AWG’s
reference scenario, from a level of 18.6% of GDP in 2019. Under the AWG’s risk
scenario, the increase was projected to be 8.0 percentage points of GDP, which was 
significantly above the EU average. All these factors suggested that reforms of the 
pension, health and long-term care systems were necessary to improve the long-term 
sustainability of public finances. 
Looking ahead, a prudent fiscal policy will be needed to safeguard the 
sustainability of public finances. While fiscal policy should remain agile in its 
response to the evolving pandemic situation and given the geopolitical situation, a 
consistent and prudent fiscal policy is required to ensure that the Czech Republic 
complies with the Stability and Growth Pact and maintains buffers to alleviate adverse 
shocks. This is particularly important given that current fiscal plans seem to entail a 
risk of entrenching higher structural deficits. These risks are largely associated with 
the 2021 income tax reform, which has likely lowered revenue generation in the 
medium term. Public sector indebtedness does, however, not represent a significant 
risk in the short run against the backdrop of an initial low level. Moreover, the Next 
Generation EU programme needs to be implemented effectively in order to support 
the recovery and to adjust to the structural changes that are under way. 
180  This assessment was confirmed by the updated debt sustainability analysis which was published as part
of the European Commission's country report for the Czech Republic on 23 May 2022.
181  However, this assessment does not necessarily reflect the uncertainty surrounding the long-term 
assumptions and, for high-debt countries, should be viewed with caution. 
182  European Commission and Economic Policy Committee, “The 2021 Ageing Report: Economic and
Budgetary Projections for the EU Member States (2019-2070)”, European Economy Institutional Paper, 
No 148, European Commission, 2021.
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96 
5.2.3 Exchange rate developments 
In the two-year reference period from 26 May 2020 to 25 May 2022, the Czech 
koruna did not participate in ERM II, but traded under a flexible exchange rate 
regime. Over the reference period the Czech currency mostly traded significantly 
above its May 2020 average exchange rate against the euro of 27.2687 korunas per 
euro, which is used as a benchmark for illustrative purposes in the absence of an ERM 
II central rate (Chart 5.2.3). The maximum upward deviation from this benchmark was 
11.5%, whereas the maximum downward deviation amounted to 0.6%. On 25 May 
2022 the exchange rate stood at 24.6480 korunas per euro, i.e. 9.6% stronger than its 
average level in May 2020. Over the past ten years the Czech koruna has appreciated 
by 2.6% against the euro. 
The Czech koruna exhibited, on average, a relatively high degree of volatility 
against the euro over the two-year reference period. Following a depreciation of 
the currency during the intensification of the COVID-19 pandemic, the Czech koruna 
broadly strengthened from the beginning of the reference period until late August 
2020. It then started to weaken again in September and October as the country 
experienced a second wave of the pandemic. Thereafter the koruna reversed its 
depreciation and continued on the stable appreciating path which it had been following 
before the start of the pandemic, albeit with a higher degree of volatility. Volatility in 
foreign exchange markets significantly increased at the end of February 2022 
following the Russian invasion of Ukraine. On average during the first quarter of 2022, 
the Czech koruna exhibited a high degree of volatility. At the same time, short-term 
interest rate differentials against the three-month EURIBOR were modest until the first 
half of 2021, before turning relatively wide in the second half of the year and further 
increasing substantially to a level of 5.1 percentage points 5.3 percentage points in the 
three-month period ending in March 2022. 
Over the past ten years the Czech koruna has appreciated in real effective 
terms (Chart 5.2.4). Following a period of increased volatility at the height of the 
global financial crisis, the real effective exchange rate weakened until 2015 when it 
started to appreciate again. However, this indicator should be interpreted with caution, 
as the Czech Republic is subject to a process of economic convergence, which 
complicates any long-term assessment of real exchange rate developments. 
The combined current and capital account balance has remained in surplus 
over the past ten years, while the country’s net foreign liabilities have declined 
(Table 5.2.3). The combined current and capital account surplus rose from 0.8% of 
GDP in 2019 to 3.2% of GDP in 2020, reflecting an increase in the trade surplus owing 
to improved terms of trade, as well as a decline in the primary income deficit. In 2021 
the current account balance narrowed notably. This was due to a decline in the trade 
surplus on the back of higher import prices and supply chain disruptions denting the 
recovery in exports, particularly in the automotive sector. At the same time, the 
primary income deficit decreased to 3.3% in 2021. On the financing side, the Czech 
Republic recorded fairly sizeable net inflows of other investment, amounting to 4.9% of 
GDP in 2021. However, these inflows were more than offset by net acquisitions of 
reserve assets and net inflows of portfolio investment. As a result, the country’s gross 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 295 – 
 
Convergence Report, June 2022 
 
97 
external debt continued to decline, falling from 75.9% in 2020 to 73.1% in 2021. At the 
same time, the country’s net international investment position continued to improve, 
from -19.8% of GDP in 2019 to -16.3% of GDP in 2020 and -15.6% in 2021. 
The Czech economy is well integrated with the euro area through trade and 
investment linkages. In 2021 exports of goods and services to the euro area 
constituted 62.2% of total Czech exports, whereas imports of goods and services from 
the euro area amounted to 49.5% of the country’s total imports. In the same year the 
share of the euro area in the Czech Republic’s stock of inward direct investment stood 
at 79.4% and its share in the country’s stock of portfolio investment liabilities was 
75.7%. The share of the Czech Republic’s stock of foreign assets invested in the euro 
area amounted to 69.6% in the case of direct investment and 69.7% for portfolio 
investment in 2021. 
5.2.4 Long-term interest rate developments 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in the Czech Republic stood at 2.5% on average and were thus just below the 
2.6% reference value for the interest rate convergence criterion (Chart 5.2.5). 
Long-term interest rates in the Czech Republic stood at 4.0% at the end of the 
reference period, above the level seen at the start of 2012. In the period 2012-16 
long-term interest rates in the Czech Republic declined, as the economic recovery did 
not push up inflation and thus allowed Česká národní banka to maintain a highly 
accommodative monetary policy. As inflation started to pick up in 2017 long-term 
interest rates followed suit and increased until 2018, reflecting global developments 
and an acceleration of economic growth that led to overheating in the domestic labour 
market and to rising inflationary pressures. In 2019 long-term interest rates changed 
course again and, despite the gradual tightening of monetary policy initiated by Česká 
národní banka in mid-2017, started to decline. This was due to signs of weakness in 
the global economic outlook combined with geopolitical tensions including, in 
particular, the US-China trade dispute and perceived risks of a disorderly Brexit. 
Following the outbreak of the COVID-19 pandemic, long-term interest rates reached 
their lowest point in the summer of 2020, in part reflecting the prompt and decisive 
interest rate cuts implemented by Česká národní banka over the period from March to 
May 2020. In this context, the two-week repo rate – the main policy rate – was lowered 
to 0.25% at the beginning of May 2020, down from 2.25% in February of that year. 
Since the final quarter of 2020 long-term interest rates have risen steadily owing to 
persistent inflationary pressures that led Česká národní banka to pursue a series of 
rate increases between June and December 2021, culminating in a rise in the 
two-week repo rate to 3.75%. The central bank increased the two-week repo rate 
three more times in 2022, with the rate standing at 5.75% at the end of the review 
period. This was in response to continuing upward pressures on inflation from both 
domestic and foreign sources and to the risk of the Russian invasion of Ukraine 
leading to higher, and more persistent, inflation than previously expected. The credit 
quality of Czech government debt remained rather benign. Credit default swap 
spreads for Czech government debt have been the lowest among the peer group of 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 296 – 
 
Convergence Report, June 2022 
 
98 
countries in recent months, stabilising at slightly below 50 basis points. The Czech 
Republic’s government debt is rated high investment grade by all three main rating 
agencies (Moody’s: Aa3; S&amp;P: AA-; Fitch: AA-). 
The Czech Republic’s long-term interest rate differential vis-à-vis the euro area 
average turned positive at the end of 2017 for the first time since 2012 and 
gradually increased further until April 2022. Over the period 2012-17 this 
differential remained negative but was increasing steadily, mainly because of the 
decline in risk premia on euro area sovereign debt that began in late 2012, when the 
reduction in uncertainty around the resolution of the euro area debt crisis contributed 
to driving down euro area yields. However, since the end of 2017 a positive – and 
increasing – long-term interest rate differential has opened, with Czech interest rates 
exceeding the euro area average, reflecting a persistent and rising inflation 
differential. In April 2022 the interest rate differential stood at 2.6% (3.1% vis-à-vis the 
euro area AAA yield), which is the second highest value since the start of the review 
period (April 2020). 
Capital markets in the Czech Republic are smaller and less developed than 
those in the euro area (Table 5.2.4). Stock market capitalisation in the Czech 
Republic, as a percentage of GDP, stood at 13.3% in 2021, which is almost equal to 
the average value recorded over the period 2012-21. Outstanding debt securities 
issued by non-financial institutions (a measure of market-based indebtedness) have 
gradually decreased in recent years to stand at 5.2% of GDP in 2021, after averaging 
over 7% in the period 2012-16. Meanwhile, after having declined for five years, debt 
securities issued by financial institutions increased in 2021, returning to almost 13% of 
GDP, which is also in line with the average value observed during the period 2012-21. 
Financial intermediation, as measured by MFI credit to the non-government sector, 
increased in 2021 compared with the period 2012-16 and stood at 57.8% of GDP, 
around half of the euro area average. In recent years the ability of the Czech 
Republic’s banking sector to obtain funding from euro area banks has stabilised at 
high levels, as claims of euro area MFIs on resident MFIs stood at 22.4% of the total 
liabilities of domestic MFIs in 2021. The development of the Czech Republic’s capital 
markets in terms of size and intermediation capacity remains limited, but is in line with 
that of other non-euro area EU Member States in central and eastern Europe. 
  
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 297 – 
Czech Republic - Price developments
S 1 ECB Convergence Report, May 2022 
Chart 5.2.1 HICP inflation and reference value 1) 
(annual percentage changes)
-2
0
2
4
6
8
10
12
14
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
-2
0
2
4
6
8
10
12
14
HICP
HICP (12-month moving average)
Reference value
Sources: European Commission (Eurostat) and ECB calculations.
1) The basis of the calculation of the reference value for the period from May 2021 to April 2022 is the unweighted arithmetic average of the annual percentage
changes in the HICP for France, Finland and Greece plus 1.5 percentage points. The reference value is 4.9%.
Table 5.2.1 Measures of inflation and related indicators
(annual percentage changes, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Measures of inflation
 HICP 2.0 1.2 2.7 2.4 2.0 2.6 3.3 3.3 11.7 4.5
HICP excluding unprocessed food and energy 2.1 1.3 2.8 2.6 1.8 2.3 3.7 3.8 8.9 4.0
HICP at constant tax rates 3) 1.7 0.7 2.7 2.6 1.9 2.6 3.2 3.4 - -
 CPI 2.0 1.2 2.9 2.5 2.1 2.8 3.2 3.8 . .
Private consumption deflator 1.8 0.8 2.7 2.3 2.5 2.8 2.8 3.1 11.7 5.4
 GDP deflator 2.4 1.5 3.2 1.3 2.6 3.9 4.4 4.0 7.4 4.7
 Producer prices 4) 0.9 -0.9 2.7 1.8 2.0 2.6 0.1 7.1 - -
 Related indicators
Real GDP growth 1.8 1.8 1.7 5.2 3.2 3.0 -5.8 3.3 1.9 2.7
GDP per capita in PPS 5) (euro area = 100) 83.4 80.6 87.0 85.0 86.3 87.6 89.2 . - -
Comparative price levels (euro area = 100) 67.4 65.3 70.1 66.8 70.0 71.0 72.5 . - -
 Output gap 6) -0.7 -1.4 0.1 1.9 2.4 2.9 -4.3 -2.4 -2.2 -1.2
Unemployment rate (%) 7) 4.2 5.8 2.5 2.9 2.2 2.0 2.6 2.8 2.6 2.6
Unit labour costs, whole economy 3.0 1.3 4.8 3.5 6.1 4.3 7.7 2.3 2.8 2.8
Compensation per employee, whole economy 4.3 2.3 6.2 7.2 8.1 7.2 3.2 5.6 2.4 5.3
Labour productivity, whole economy 1.2 1.0 1.4 3.6 1.8 2.8 -4.2 3.2 -0.3 2.4
Imports of goods and services deflator 0.6 0.3 0.9 0.3 -0.6 0.8 -0.2 4.4 7.9 3.1
Nominal effective exchange rate 8) 0.0 -1.9 2.0 3.6 4.5 -0.6 -1.3 3.8 - -
Money supply (M3) 9) 7.2 6.2 8.1 11.2 6.2 6.5 9.7 7.2 - -
Lending from banks 10) 6.2 5.7 6.7 7.6 7.3 5.5 3.3 10.1 - -
Stock prices (PX Index) 11) 56.5 1.2 54.7 17.0 -8.5 13.1 -7.9 38.8 - -
Residential property prices 6.8 2.4 11.4 11.7 8.6 9.2 8.4 19.7 - -
Sources: European Commission (Eurostat, Directorate-General for Economic and Financial Affairs), national data for CPI, money supply, lending from banks
and ECB calculations based on Refinitiv data for stock prices.
1) Multi-annual averages calculated using the geometric mean, except for GDP per capita in PPS, comparative price levels, output gap and unemployment rate, for which the
arithmetic mean is used.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) The difference between the HICP and the HICP at constant tax rates shows the theoretical impact of changes in indirect taxes (e.g. VAT and excise duties) on the overall rate
of inflation. This impact assumes a full and instantaneous pass-through of tax rate changes to the price paid by the consumer.
4) Domestic sales, total industry excluding construction.
5) PPS stands for purchasing power standards.
6) Percentage difference from potential GDP: a positive (negative) sign indicates that actual GDP is above (below) potential GDP.
7) Definition conforms to International Labor Organization guidelines.
8) EER-42 group of trading partners. A positive (negative) sign indicates an appreciation (depreciation).
9) The series includes repurchase agreements with central counterparties.
10) Adjusted for the derecognition of loans from the MFI statistical balance sheet due to their sale or securitisation.
11) Multi-annual and annual figures represent the percentage change between the end of the given period and the end of the previous period.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 298 –
Czech Republic - Fiscal developments
S 2 ECB Convergence Report, May 2022 
Chart 5.2.2 General government balance and debt
(as a percentage of GDP)
-11
-9
-7
-5
-3
-1
1
3
5
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
10
20
30
40
50
60
70
80
90
100
110
Government balance (left-hand scale)
Government debt (right-hand scale)
Reference values (government balance: -3%; government debt: 60%)
Sources: European System of Central Banks and European Commission (Eurostat).
Table 5.2.2 Government budgetary developments and projections
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Government balance -1.6 -1.4 -1.8 1.5 0.9 0.3 -5.8 -5.9 -4.3 -3.9
 Total revenue 41.0 40.9 41.1 40.5 41.5 41.4 41.6 40.5 40.2 39.8
 Current revenue 40.0 39.7 40.3 39.8 40.7 40.5 40.6 39.6 38.6 38.1
 Direct taxes 7.9 7.7 8.1 8.1 8.5 8.5 8.5 6.8 6.5 6.5
 Indirect taxes 12.0 12.2 11.8 12.3 12.0 11.9 11.4 11.5 11.4 11.4
Net social contributions 15.1 14.6 15.7 14.9 15.4 15.5 16.0 16.6 15.8 15.5
Other current revenue 3) 5.0 5.3 4.7 4.6 4.8 4.7 4.7 4.8 4.9 4.8
 Capital revenue 1.0 1.2 0.8 0.6 0.8 0.8 0.9 0.9 1.6 1.7
 Total expenditure 42.6 42.3 42.9 39.0 40.6 41.1 47.3 46.4 44.5 43.7
 Current expenditure 37.3 36.9 37.8 35.0 35.7 36.0 41.2 40.9 38.8 38.2
Compensation of employees 9.4 8.7 10.2 9.0 9.6 9.9 11.1 11.0 10.2 10.0
 Social benefits 16.3 16.3 16.3 15.2 15.1 15.3 18.0 17.8 17.2 17.2
 Interest payable 1.0 1.2 0.7 0.7 0.7 0.7 0.8 0.7 0.9 0.9
Other current expenditure 4) 10.6 10.7 10.6 10.0 10.3 10.0 11.3 11.4 10.5 10.1
 Capital expenditure 5.3 5.4 5.1 4.0 4.9 5.1 6.1 5.5 5.8 5.5
 of which: Investment 4.2 4.1 4.3 3.3 4.1 4.4 4.9 4.7 4.9 5.2
Cyclically adjusted balance -1.4 -0.9 -1.8 0.7 -0.1 -0.9 -4.1 -4.9 -3.4 -3.5
One-off and temporary measures -0.2 -0.4 0.0 0.0 0.0 0.0 0.0 0.0 -0.4 0.0
 Structural balance 5) -1.1 -0.4 -1.8 0.7 -0.1 -0.9 -4.1 -4.9 -3.1 -3.5
 Government debt 38.3 41.3 35.2 34.2 32.1 30.1 37.7 41.9 42.8 44.0
Average residual maturity (in years) - - - - - - - - . .
In foreign currencies (% of total) 15.8 20.6 11.1 15.0 12.4 11.7 8.7 7.7 . .
 of which: Euro 14.9 19.2 10.5 14.2 11.7 11.1 8.1 7.4 . .
Domestic ownership (% of total) 64.2 65.3 63.2 54.6 60.4 61.6 67.8 71.6 . .
Medium and long-term maturity (% of total) 6) 96.0 94.1 97.8 97.1 97.0 98.7 98.7 97.5 . .
  of which: Variable interest rate (% of total) 13.8 15.8 11.8 11.8 12.5 12.4 10.2 11.9 . .
 Deficit-debt adjustment 0.1 -0.7 1.0 1.4 0.6 0.4 1.4 0.9 . .
Net acquisitions of main financial assets 0.7 0.1 1.4 1.8 0.2 0.3 2.0 2.5 . .
Currency and deposits 0.8 0.1 1.5 2.2 0.4 0.4 2.0 2.4 . .
 Debt securities 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 . .
 Loans -0.1 0.0 -0.1 -0.3 -0.2 -0.1 0.0 0.1 . .
Equity and investment fund shares or units 0.0 0.0 0.0 -0.1 0.0 0.0 0.0 0.0 . .
Revaluation effects on debt -0.1 -0.1 0.0 -0.2 0.1 0.0 0.1 -0.1 . .
 of which: Foreign exchange holding
 gains/losses 0.0 0.0 -0.1 -0.3 0.0 0.0 0.1 -0.1 . .
 Other 7) -0.5 -0.6 -0.4 -0.2 0.3 0.0 -0.7 -1.5 . .
 Convergence programme: government balance - - - - - - - - -3.6 -2.3
 Convergence programme: structural balance - - - - - - - - -3.1 -3.1
 Convergence programme: government debt - - - - - - - - 42.7 43.4
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast, except for convergence programme data.
3) Sales and other current revenue.
4) Intermediate consumption, subsidies payable and other current expenditure.
5) Cyclically adjusted balance excluding one-off and other temporary measures.
6) Original maturity of more than one year.
7) Time of recording differences and other factors (sector reclassifications and statistical discrepancies).
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 299 – 
Czech Republic - Exchange rate and external developments
S 3 ECB Convergence Report, May 2022 
Chart 5.2.3 Bilateral exchange rate and short-term
interest rate differential
Chart 5.2.4 Effective exchange rates 1) 
(EER-42 group of trading partners; monthly averages; index: Q1 1999 = 100)
(CZK/EUR exchange rate: monthly averages;
difference between three-month interbank interest rates
and three-month EURIBOR: basis points, monthly values)
29.0
28.0
27.0
26.0
25.0
24.0
2012 2014 2016 2018 2020
-1.0
0.0
1.0
2.0
3.0
4.0
5.0
6.0
CZK/EUR exchange rate (left-hand scale)
Interest rate differential (right-hand scale)
135
142
149
156
163
170
2012 2014 2016 2018 2020
125
135
145
155
165
175
Nominal (left-hand scale)
Real (right-hand scale)
Sources: National data and ECB calculations. Source: ECB.
1) The real EER-42 is CPI-deflated. An increase (decrease) in the EER indicates
an appreciation (depreciation).
Table 5.2.3 External developments
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Balance of payments
Current account and capital account balance 3) 1.5 1.5 1.5 2.4 0.7 0.8 3.2 0.7 -1.9 -1.8
Current account balance 0.4 0.1 0.7 1.5 0.5 0.3 2.0 -0.9 -3.7 -3.8
 Goods 4.1 4.3 3.8 5.0 3.7 4.1 4.9 1.2 . .
 Services 1.9 1.8 2.0 2.4 2.2 1.8 1.8 1.8 . .
 Primary income -5.1 -5.7 -4.5 -5.0 -4.8 -5.0 -4.2 -3.3 . .
 Secondary income -0.5 -0.3 -0.6 -1.0 -0.7 -0.6 -0.5 -0.5 . .
Capital account balance 1.2 1.4 0.9 0.9 0.2 0.4 1.2 1.6 . .
Combined direct and portfolio investment balance 3) -3.0 -3.2 -2.9 -5.9 -0.4 -4.2 -5.0 1.1 . .
 Direct investment -1.4 -1.5 -1.4 -0.9 -0.9 -2.4 -2.6 -0.1 . .
 Portfolio investment -1.6 -1.7 -1.5 -5.0 0.6 -1.8 -2.4 1.2 . .
Other investment balance -1.1 -0.3 -2.0 -15.4 0.9 2.4 6.9 -4.9 . .
 Reserve assets 6.0 5.5 6.4 23.8 0.9 1.9 0.8 4.9 . .
Exports of goods and services 76.6 78.7 74.5 78.9 77.0 73.9 70.2 72.5 . .
Imports of goods and services 70.6 72.6 68.7 71.5 71.0 67.9 63.4 69.5 . .
Net international investment position 4) -28.4 -36.6 -20.2 -24.9 -24.4 -19.8 -16.3 -15.6 . .
Gross external debt 4) 72.5 66.7 78.3 85.5 81.6 75.7 75.9 73.1 . .
 Trade with the euro area 5)
Exports of goods and services 62.3 62.3 62.2 62.6 61.9 61.9 62.2 62.2 . .
 Imports of goods and services 51.8 52.4 51.2 52.5 52.1 51.6 50.4 49.5 . .
 Investment position with the euro area 5)
Direct investment assets 4) 76.3 78.8 73.8 80.4 73.7 73.2 72.3 69.6 . .
Direct investment liabilities 4) 80.5 81.0 80.0 80.8 80.5 80.0 79.1 79.4 . .
Portfolio investment assets 4) 71.4 73.2 69.7 70.2 69.2 69.8 69.6 69.7 . .
Portfolio investment liabilities 4) 61.4 53.7 69.0 61.9 65.4 69.4 72.4 75.7 . .
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) Differences between totals and the sum of their components are due to rounding.
4) End-of-period outstanding amounts.
5) As a percentage of the total.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 300 – 
Czech Republic - Long-term interest rate developments
S 4 ECB Convergence Report, May 2022 
Chart 5.2.5 Long-term interest rate 1) 
(monthly averages in percentages)
Chart 5.2.6 Long-term interest rate and HICP inflation
differentials vis-à-vis the euro area
(monthly averages in percentage points)
0
1
2
3
4
2012 2014 2016 2018 2020
0
1
2
3
4
Long-term interest rate
Long-term interest rate (12-month moving average)
Reference value
-2
-1
0
1
2
3
4
5
2012 2014 2016 2018 2020
-2
-1
0
1
2
3
4
5
Long-term interest rate differential
HICP inflation differential
Sources: European System of Central Banks and ECB calculations.
1) The basis of the calculation of the reference value for the period from May
2021 to April 2022 is the unweighted arithmetic average of the interest rate
levels in France, Finland and Greece plus 2 percentage points. The reference
value is 2.6%.
Sources: European System of Central Banks, ECB calculations and European
Commission (Eurostat).
Table 5.2.4 Long-term interest rates and indicators of financial development and integration
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2018 2019 2020 2021 May. 2021 Memo item:
to euro area
Apr. 2022 2021
 Long-term interest rates
 Czech Republic 2) 1.5 1.5 1.5 2.0 1.5 1.1 1.9 2.5 -
 Euro area 3), 4) 1.4 2.2 0.6 1.1 0.4 0.1 0.1 0.4 -
Euro area AAA par curve, ten-year residual maturity 2), 4) 0.6 1.2 0.0 0.5 -0.2 -0.4 -0.3 -0.1 -
 Indicators of financial development and integration
Debt securities issued by financial corporations 5) 12.8 13.7 11.8 11.3 9.2 13.6 12.7 - 66.7
Debt securities issued by non-financial corporations 6) 6.8 7.4 6.2 6.8 6.4 6.2 5.2 - 13.4
Stock market capitalisation 7) 13.1 14.6 11.6 11.2 10.3 10.0 13.3 - 77.7
MFI credit to non-government residents 8) 54.5 53.2 55.8 55.2 54.1 57.1 57.8 - 111.1
Claims of euro area MFIs on resident MFIs 9) 17.1 9.9 24.3 26.0 25.0 22.8 22.4 - 29.5
Sources: European System of Central Banks and ECB calculations.
1) Multi-annual averages calculated using the arithmetic mean.
2) Average interest rate.
3) GDP-weighted average of the euro area long-term interest rates for the purpose of assessing convergence.
4) Included for information only.
5) Outstanding amount of debt securities issued by resident MFIs (excluding the national central bank) and other financial corporations.
6) Outstanding amount of debt securities issued by resident non-financial corporations.
7) Outstanding amount of listed shares issued by residents at market values.
8) MFI (excluding national central bank) credit to domestic non-MFI residents other than general government. Credit comprises outstanding amounts of loans and debt securities.
9) Outstanding amount of deposits and debt securities issued by domestic MFIs (excluding the national central bank) held by euro area MFIs as a percentage of total liabilities 
of domestic MFIs (excluding the national central bank). Total liabilities exclude capital and reserves and remaining liabilities.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 301 – 
Convergence Report, June 2022 103 
5.3 Croatia
5.3.1 Price developments
In April 2022 the 12-month average rate of HICP inflation in Croatia was 4.7%, 
i.e. below the reference value of 4.9% for the criterion on price stability (Chart
5.3.1). This rate is expected to increase gradually over the coming months, driven
mainly by the higher commodity prices, broadening price pressures and further
aggravation of supply bottlenecks resulting from the Russia-Ukraine war.
Over the past ten years the 12-month average rate of HICP inflation has 
fluctuated within a relatively wide range, from -0.8% to 4.7%, and the average 
for that period was subdued, standing at 1.1%. Average inflation rose between 
2012 and 2013 owing to increases in energy and food prices, before falling to a very 
low level in 2014 and entering negative territory in 2015 and 2016, largely on the back 
of lower commodity prices and subdued domestic price pressures. In 2017 inflation 
turned positive, driven mainly by food price developments and a recovery in domestic 
demand (Table 5.3.1). Headline inflation increased further in 2018 as growth in energy 
prices accelerated, but fell again in 2019 owing to a significant reduction in the value 
added tax (VAT) rate on selected unprocessed foods and a moderation in energy price 
inflation. The slowdown in inflation in 2020 was driven by the sharp drop in energy 
prices as a result of the fall in global oil prices during the first few months of the 
coronavirus (COVID-19) pandemic. To a lesser extent that slowdown also reflected a 
decline in demand for tourism-related services and durable consumer goods. In 2021 
HICP inflation rose sharply again, owing mainly to higher energy costs, but also to the 
higher food prices resulting from the spillover of inflationary pressures on imported 
goods (e.g. raw materials, energy products and transportation costs) and from the 
adverse weather conditions that weighed on the supply of certain crops. Helped by 
ample policy support, the impact of the pandemic on labour markets was contained. 
Wage growth continued its pre-pandemic upward trend almost unabated, while the 
unemployment rate returned to close to its pre-crisis level in 2021, in the context of an 
exceptionally strong rebound in economic activity. 
In the first four months of 2022 the average annual rate of HICP inflation stood 
at 7.2%. Continuing the upward trend it had started in 2021, HICP inflation increased 
further at the beginning of 2022, driven largely by sharp increases in energy and food 
prices. Those high inflationary pressures were then compounded by Russia’s invasion
of Ukraine in late February. The rise in HICP inflation was mitigated by fiscal measures 
(some temporary), such as reduced VAT rates for gas, electricity and basic groceries, 
cuts in fuel excise duties and the freezing of margins on petroleum products. 
Policy choices have played an important role in shaping inflation dynamics in 
Croatia over the past decade, most notably the orientation of monetary policy 
towards price stability. The primary objective of Hrvatska narodna banka is to 
maintain price stability. Since the introduction of the kuna in 1994, the central bank has 
pursued that objective by ensuring a stable exchange rate of the kuna against the 
euro. Prior to Croatia’s participation in ERM II, the local currency traded under a tightly 
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managed floating exchange rate regime, with no pre-announced level, path or band, 
and its exchange rate against the euro fluctuated within a narrow range of -4.7% and 
+3.8% around its average level from 1999. Over the years Hrvatska narodna banka 
conducted foreign exchange interventions (one of the main monetary policy tools of 
the central bank) both to support and weaken the currency, although in the five years 
preceding the outbreak of the pandemic, most of those interventions were to counter 
appreciation pressures. In the early stages of the COVID-19 crisis, the central bank 
had to strongly intervene to support the kuna and maintain sufficient liquidity in the 
financial system (see Section 5.3.3 for more details). In July 2020 the kuna was 
included in ERM II with a central exchange rate of 7.53450 kuna per euro. 
Inflation is expected to return to moderate levels in the coming years. However, 
the forecasts are subject to considerable uncertainty in the light of the 
Russia-Ukraine war. Over the longer term there are concerns about the 
sustainability of inflation convergence in Croatia. According to the European 
Commission’s Spring 2022 Economic Forecast, the average annual rate of HICP 
inflation is expected to reach 6.1% in 2022, before decelerating to 2.8% in 2023, owing 
mainly to a fall in energy prices and the easing of global supply bottlenecks. The risks 
to the short-term inflation outlook are tilted to the upside, as supply bottlenecks and 
the higher energy and food prices could continue for longer than projected. Moreover, 
although recent liberalisation measures in the labour market have helped to cushion 
wage pressures, persistent labour shortages in some sectors may still result in 
stronger than expected wage growth, thus exerting upward pressure on inflation. 
Looking further ahead, the catching-up process is likely to result in positive inflation 
differentials vis-à-vis the euro area, since GDP per capita and price levels are still 
lower in Croatia than in the euro area. In order to prevent the build-up of excessive 
price pressures and macroeconomic imbalances, the catching-up process must be 
supported by appropriate policies. 
Achieving an environment that is conducive to sustainable convergence in 
Croatia requires stability-oriented economic policies and wide-ranging 
structural reforms. Given monetary policy’s limited room for manoeuvre owing to the 
tightly managed floating exchange rate regime and the high level of euroisation, it is 
imperative that other policy areas provide the economy with the wherewithal to cope 
with country-specific shocks in order to ensure the correction of macroeconomic 
imbalances and prevent their recurrence in the future. Although the COVID-19 crisis 
has not hampered Croatia’s reform momentum, also in the context of the post-entry 
commitments the country made upon joining ERM II, its economic growth potential is 
still low for a catching-up economy, particularly in terms of the contribution from 
productivity. As this is standing in the way of economic convergence with the euro 
area average, Croatia needs to implement structural policies aimed at raising potential 
growth and enhancing the competitiveness of its economy. Priority should be given to 
improving the quality of the institutional and business environment, including boosting 
competition in product markets. In addition, it is essential to improve the efficiency of 
the public administration and the judicial system. Overall, policies should be geared 
towards supporting innovation and investment in new technologies, also with a view to 
reducing the country’s high dependence on tourism. Modernising its infrastructure (in 
particular the rail network) would boost potential output and promote a more efficient 
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allocation of resources. Measures should also be implemented to reduce mismatches 
in the labour market, enhance the quantity and quality of the labour supply, push up 
the low participation rate (especially in the 50-64 age group) and align the education 
system with the needs of the market. Against this background, it will be of utmost 
importance to ensure an efficient absorption of the abundant EU funds allocated to the 
country. With regard to macroeconomic imbalances, the European Commission 
selected Croatia for an in-depth review in its Alert Mechanism Report 2022, which 
highlighted that imbalances relating to high levels of external, private and government 
debt in the context of low potential growth continued to subside in 2021, returning to 
their favourable pre-pandemic trends. 
The convergence in banking supervision achieved under the close cooperation 
framework ensures the application of uniform supervisory standards and thus 
contributes to safeguarding financial stability. With the entry into force of the close 
cooperation framework between the ECB and Hrvatska narodna banka on 1 October 
2020, the ECB became responsible for the direct supervision of eight significant 
institutions and for the oversight of 15 less significant institutions in Croatia. Hrvatska 
narodna banka has been integrated into the Single Supervisory Mechanism and is 
participating in its structures and networks. Croatian significant institutions are now 
supervised by Joint Supervisory Teams supported by experts in horizontal line 
supervision. With regard to the oversight of less significant institutions, which have a 
domestic market share of roughly 22%, the ECB is working closely with national 
supervisors to further harmonise implementation of the rules governing banking 
supervision, while also ensuring that joint supervisory standards are applied 
consistently across the system. As at the end of 2021, Croatia’s banking sector had a 
sound capital position and sufficient liquidity. Following a sharp decline in 2020, bank 
profits recovered partially in 2021. The non-performing loan ratio stood at 4.6% in 
September 2021, but continued to decline despite the phasing-out of the 
pandemic-related policy support measures. After a setback in 2020, the corporate 
debt-to-GDP ratio started to fall again in 2021 but remains high. By contrast, 
household debt, although low relative to GDP, continued the upward trend it had 
initiated in 2017, underpinned by the Government’s subsidisation programme for 
housing loans and buoyant house price dynamics. In this context, the build-up of risks 
in the residential real estate segment warrants close monitoring. 
5.3.2 Fiscal developments 
Croatia’s general government budget balance was just below the 3% deficit 
reference value in 2021 and its debt was above the 60% reference value. In the 
reference year 2021, the general government budget balance recorded a deficit of 
2.9% of GDP, thus just below the 3% deficit reference value. The general government 
gross debt-to-GDP ratio was 79.8%, above the 60% reference value (Table 5.3.2). 
Compared with the previous year, the general government deficit improved by 
4.4 percentage points and the debt ratio decreased significantly by 7.5 percentage 
points. With regard to other fiscal factors, the deficit ratio did not exceed the ratio of 
public investment to GDP in 2021. The budget deficits in 2020 and 2021 were 
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substantially affected by the economic impact of the COVID-19 pandemic and the 
fiscal policy measures taken in response to it. 
Croatia has been subject to the preventive arm of the Stability and Growth Pact 
since 2017. The general government deficit-to-GDP ratio in 2021 was below the 
reference value of 3% and is projected to remain below it in 2022. Therefore, Croatia 
fulfilled the deficit criterion as defined in the Treaty and in Regulation (EC) No 
1467/1997. Even though Croatia’s debt ratio was above the reference value of 60% of 
GDP, it complied with the debt criterion, as the debt reduction benchmark had been 
respected in 2021. In the preceding year, in June 2021, the European Commission 
had found that the general government deficit in 2020 was above and not close to the 
reference value of 3% of GDP. The excess over the reference value was considered to 
be exceptional, but not temporary, as defined by the Treaty. Moreover, Croatia’s 
general government debt exceeded the 60% of GDP reference value and did not 
diminish at a satisfactory pace. However, taking into account the high uncertainty, the 
agreed fiscal policy response to the COVID-19 crisis and the Council 
recommendations of 20 July 2020, the Commission considered that at that juncture a 
decision on whether to place Member States under the excessive deficit procedure 
should not be taken. Previously, Croatia had been subject to an excessive deficit 
procedure as of January 2014, which was abrogated in June 2017.183 In the 
subsequent period to 2019, the deficit and debt criteria were comfortably met and 
Croatia was found to be compliant with the provisions of the preventive arm of the 
Stability and Growth Pact. 
Both cyclical and non-cyclical factors relating to the COVID-19 pandemic 
contributed to the deterioration in the budget balance over the period 2019-21. 
During the period 2015-19, the nominal budget deficit improved markedly to an 
average of 0.6% (from an average of 6.1% of GDP in the period 2010-14). This was 
driven by a large structural adjustment and the improvement in the macroeconomic 
conditions. In 2019 Croatia recorded a surplus of 0.2% of GDP. Owing to the 
COVID-19 pandemic, the budget balance deteriorated in 2020 by 7.5 percentage 
points (3 percentage points in structural terms), before recovering in 2021 by 4.4 
percentage points (1.3 percentage points in structural terms). The sharp deterioration 
in the government balance in 2020 resulted from the marked deterioration in economic 
activity and the discretionary fiscal measures implemented to support companies and 
households, as well as the operation of automatic fiscal stabilisers. Croatia’s deficit 
improved significantly over 2021 thanks to the strong growth in GDP and government 
tax revenue, coupled with the phasing-out of COVID-19-related expenditure 
measures. 
The government debt-to-GDP ratio has remained well above the 60% reference 
value over the past decade, having followed a downward path from 2015 to 
2019, before increasing again during the COVID-19 crisis. The debt ratio 
increased rapidly and continuously from 48.7% of GDP in 2009 to a peak of 84.7% of 
GDP in 2014. From 2015 to 2019, the debt ratio followed a downward path and 
 
183  The ECOFIN Council, following Croatia’s accession to the EU in June 2013 and taking into account the 
level of the 2013 deficit, as well as the planned 2014 deficit – both of which breached the 3% deficit 
reference value – decided on January 2014 to open an excessive deficit procedure, with the deadline for 
correcting the excessive deficit being 2016. 
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reached a trough of 71.1% of GDP in 2019, mostly reflecting primary surpluses, as 
well as some favourable deficit-debt adjustments. However, the debt ratio increased 
by 16.2 percentage points of GDP in 2020, rising to a historical peak of 87.3% of GDP, 
notably on account of the impact of the COVID-19 crisis. The debt ratio decreased by 
around 7.5 percentage points in 2021 to reach 79.8% of GDP, i.e. below the peak 
value in 2014 prior to the pandemic. 
While Croatia is protected, to some extent, from interest rate shocks, its fiscal 
balances would be highly sensitive to any exchange rate movements vis-à-vis 
the euro. The share of government debt with a short-term maturity is low (5.7% in 
2021 – Table 5.3.2). Taking into account the fact that the medium and long-term debt 
is based entirely on fixed rates, fiscal balances are relatively insensitive to interest rate 
changes. However, a high share of public debt is denominated in foreign currency 
(70.7% in 2021), mainly euro (99.9% of foreign-denominated debt). Taking the 
government debt-to-GDP ratio into account, this implies that fiscal balances are highly 
sensitive to exchange rate changes. However, the high sensitivity of fiscal balances to 
euro/kuna exchange rate changes is mitigated by the tightly managed float operated 
by Hrvatska narodna banka (designed to reduce exchange rate volatility against the 
euro). In addition, the proportion of government debt issued in kuna has slightly 
increased (Table 5.3.2). 
The European Commission’s Spring 2022 Economic Forecast predicts an 
improvement in the budget balance (with the deficit remaining below the 3% 
reference value) and a marked decrease in the debt ratio. The European 
Commission’s Spring 2022 Economic Forecast indicates continued compliance with 
the deficit and debt criteria of the Stability and Growth Pact. The nominal deficit is 
expected to remain below the 3% reference value and decline to 2.3% of GDP in 2022 
and 1.8% of GDP in 2023. According to the European Commission’s Spring 2022 
Forecast, the structural deficit is expected to stand well above the medium-term 
objective (a structural deficit of 1% of GDP) over the period 2022-23.184 Nevertheless, 
the Stability and Growth Pact’s general escape clause, which continues to be applied 
in 2022 and is also expected to remain in place in 2023, provides that “in periods of 
severe economic downturn for the euro area or the Union as a whole, Member States 
may be allowed temporarily to depart from the adjustment path towards the 
medium-term budgetary objective…, provided that this does not endanger fiscal
sustainability in the medium term”. In 2022 the debt ratio is projected to further 
decrease to 75.3% of GDP, but remain above the 60% reference value. Croatia’s
medium-term fiscal policy strategy, as presented in the 2022 update of the 
convergence programme, forecasts a path for both the nominal and the structural 
deficit which is close to that shown in the European Commission’s Spring 2022 
Economic Forecast. 
Croatia has improved its fiscal framework, but further progress remains 
warranted with a view to ensuring efficient absorption of the Next Generation 
EU funds. Since the last report, Croatia has made progress in the reduction of public 
sector inefficiencies, including the management of state-owned enterprises, 
184  In January 2020, Croatia’s medium-term objective changed from a structural deficit of 1.75% of GDP to a 
structural deficit of 1% of GDP.
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simplification and digitalisation of administrative procedures and the fight against 
corruption. Measures have also been taken to improve the public finance 
management framework and the efficiency and sustainability of the healthcare 
system, with a view to strengthening the structural position of Croatia’s public finances 
in the medium term. Croatia has the opportunity, as one of the main recipients of the 
Next Generation EU funds, to address these challenges further and, if funds are used 
efficiently, upgrade its infrastructure and improve its resilience to adverse shocks 
without weighing on its government debt. 
Croatia faces medium debt sustainability risks over the medium and long run. 
While the 2021 Fiscal Sustainability Report concluded that risks to fiscal sustainability 
over the medium term are high, the updated assessment that was published as part of 
the European Commission’s country report for Croatia on 23 May 2022 points to 
medium risks. Over the long term, Croatia appeared to be at medium risk,185 as the 
risks to age-related spending (particularly old age pension spending) were contained. 
Indeed, according to the 2021 Ageing Report prepared by the Ageing Working Group 
(AWG) of the EU’s Economic Policy Committee,186 Croatia was likely to experience a 
slight decline in age-related public expenditure by 0.3 percentage points of GDP by 
2070 under the AWG’s reference scenario, from a level of 21.5% of GDP in 2019, 
albeit this turns into an increase of 3.1 percentage points of GDP under the AWG’s risk 
scenario. The decline was mainly due to some savings in gross pensions, which were 
projected to fall from 10.2% of GDP to 9.5% in the period 2019-70, owing to a relative 
decline in the benefit ratio and the coverage ratios. A recent reform of the pension 
system over the period 2019-20 has nevertheless mitigated the decline in these ratios 
by increasing the retirement age and the minimum pension and penalising early 
retirement. In turn, the adequacy of the pension system has improved by comparison 
with the previous AWG report, with a limited burden on long-term fiscal sustainability. 
Looking ahead, a prudent and credible fiscal policy, as well as further structural 
reforms, are needed for public finances to ensure a downward debt path. While 
fiscal policy should remain agile in its response to the evolving pandemic situation and 
given the geopolitical situation, a consistent and prudent fiscal policy will ensure that 
Croatia complies with the Stability and Growth Pact and maintains buffers to alleviate 
adverse shocks. A fiscal policy aimed at enhancing the efficiency of public spending 
should also create space for more growth-supporting policies. The Next Generation 
EU programme needs to be implemented effectively to support the recovery and 
adjust to the structural changes that are under way. Moreover, there is scope for more 
cost-effective provision of healthcare and social protection services, as rising arrears 
exert notable pressures on the fiscal budget. The health sector is specifically 
supported by a dedicated component of the Recovery and Resilience Facility, with a 
view to improving its efficiency and financial sustainability. Also, to ensure a downward 
government debt path, the fiscal responsibility legislation should be enforced. 
Continued efforts to improve the governance framework of state-owned enterprises 
 
185  However, this assessment does not necessarily reflect the uncertainty surrounding the long-term 
assumptions and, for high-debt countries, should be viewed with caution. 
186  European Commission and Economic Policy Committee, “The 2021 Ageing Report: Economic &amp; 
Budgetary Projections for the 28 EU Member States (2019-2070)”, European Economy Institutional 
Paper, No 148, European Commission, 2021. 
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and further lower the stock of arrears in the health sector are warranted to further 
reduce the government’s contingent liabilities. 
5.3.3 Exchange rate developments 
On 10 July 2020 the ERM II parties decided, by mutual agreement, to include the 
Croatian kuna in ERM II, and it therefore participated in ERM II for most of the 
two-year reference period from 26 May 2020 to 25 May 2022. The Croatian kuna 
was included in ERM II at a central rate of 7.53450 kuna per euro with a standard 
fluctuation band of ±15%. The agreement on participation in ERM II was based on a 
number of policy commitments by the Croatian authorities, some of which had already 
been met when the kuna was included in ERM II, with the aim of achieving a high 
degree of sustainable economic convergence by the time of the adoption of the euro. 
These commitments relate to banking supervision, the country’s macroprudential 
framework, its anti-money-laundering (AML) framework, the collection, production and 
dissemination of statistics, the business environment, public sector governance and 
the insolvency framework. The ECB and the European Commission have been 
monitoring the effective implementation of these commitments, acting within their 
respective areas of competence as provided for by the Treaties and secondary 
legislation. In its role as the supervisory authority and given its shared responsibility for 
macroprudential policy, the ECB is closely monitoring the implementation of the 
commitments related to the financial sector, i.e. the insolvency framework and AML 
framework, owing to their potential impact on prudential aspects. Notwithstanding the 
fact that all of the measures envisaged in the ERM II post-entry commitments have 
been met, further progress needs to be made to address the outstanding 
shortcomings in the area of AML, as identified in the recent report by the Council of 
Europe’s Committee of Experts on the Evaluation of Anti-Money Laundering 
Measures and the Financing of Terrorism (MONEYVAL). Based on the key findings of 
the Mutual Evaluation Report on Croatia, MONEYVAL decided at its plenary meeting 
on 15-17 December 2021 to place Croatia in “enhanced follow-up”.187 Over the 
reference period the exchange rate of the Croatian kuna against the euro displayed a 
low degree of volatility and traded close to its central rate (Chart 5.3.3). Since the 
kuna’s inclusion in ERM II, as well as over the entire reference period, the maximum 
upward deviation from the central rate has been 1.0%, while the maximum downward 
deviation has amounted to 0.8%. These deviations are significantly smaller than the 
standard fluctuation band within ERM II. On 25 May 2022 the exchange rate stood at 
7.5355 kuna per euro, i.e. virtually at the level of its central rate within ERM II. In April 
2020 Hrvatska narodna banka entered a precautionary swap line arrangement with 
the ECB under which it could borrow up to €2 billion in exchange for Croatian kuna in 
order to address possible euro liquidity needs of Croatian financial institutions owing to 
 
187  See Anti-money laundering and counter-terrorist financing measures: Croatia. Fifth Round Mutual 
Evaluation Report, Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the 
Financing of Terrorism (MONEYVAL), 15 December 2021, available at: 
https://rm.coe.int/moneyval-2021-24-mer-hr-en/1680a56562. See also Meeting Report of the 62nd 
Plenary Meeting of MONEYVAL, Committee of Experts on the Evaluation of Anti-Money Laundering 
Measures and the Financing of Terrorism (MONEYVAL), 17 December 2021, available at: 
https://rm.coe.int/moneyval-2021-40-plen62-meetingreport-en/1680a60d34. 
 
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the pandemic. As this arrangement helped to reduce the potential risk of financial 
vulnerabilities, it may also have further supported the stability of the exchange rate 
over the reference period. Over the past ten years the exchange rate of the Croatian 
kuna against the euro has remained virtually unchanged, reflecting Croatia’s track 
record of maintaining exchange rate stability with the euro even prior to the inclusion of 
the kuna in ERM II. 
The exchange rate of the Croatian kuna against the euro exhibited, on average, 
a low degree of volatility over the reference period. This reflected the commitment 
by Hrvatska narodna banka under ERM II to limit exchange rate fluctuations around 
the central rate. In March and April 2020 growing uncertainty about the effects of the 
pandemic spurred demand for foreign currency by the domestic sector. The central 
bank had to strongly intervene in support of the kuna (for the first time since 2015), 
leading to a considerable decline in its stock of foreign reserves which, however, 
quickly recovered thereafter. Besides the swap line agreement concluded with the 
ECB, sufficient liquidity was also maintained via structural and regular market 
operations and a reduction in banks’ reserve requirements. Finally, with a view to 
preventing the freezing of the bond market and to securing favourable financing 
conditions for all sectors, the central bank implemented for the first time a programme 
of government bond purchases in March 2020. While the central bank had to strongly 
intervene in support of the kuna in the early stages of the COVID-19 crisis, over the 
reference period it only conducted four smaller foreign exchange interventions – two 
by selling euro in support of the kuna and two by selling domestic currency for euro. 
Overall, its sales and purchases of foreign currency over the two-year reference 
period resulted in a net sale. 
The real effective exchange rate of the Croatian kuna has depreciated slightly 
over the past ten years (Chart 5.3.4). Looking forward, this indicator should be 
interpreted with caution, as Croatia is subject to a process of economic convergence, 
which complicates any long-term assessment of real exchange rate developments. 
Croatia’s combined current and capital account balance has improved over the 
past ten years, while the country’s net foreign liabilities declined markedly 
(Table 5.3.3). The combined current and capital account balance turned positive in 
2014 and has remained in surplus since then, reaching 4.6% of GDP in 2019. 
Developments between 2014 and 2019 primarily reflected buoyant tourism receipts, 
which more than offset the rising goods trade deficit. The combined current and capital 
account balance declined to 2.0% in 2020, on account of the slump in tourism 
engendered by restrictions and uncertainties related to people’s movement across 
borders in the context of the COVID-19 pandemic. This balance improved significantly 
in 2021 (peaking at +5.8%) on the back of a strong recovery in tourism. Gross external 
debt, after having declined steadily from 2014 to 2019, increased to around 80% of 
GDP in 2020 before returning to a downward trend in 2021. The gradual narrowing of 
the net international investment position observed since 2011 came to a temporary 
halt in 2020. In 2021 the net international investment position improved again to reach 
a level of -33.9% of GDP, slightly above the MIP threshold of -35%. The country’s net 
foreign liabilities are largely composed of foreign direct investment, which constitutes 
a more stable source of funding than portfolio and other investment. However, fiscal 
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and structural policies continue to be important for supporting external sustainability 
and the competitiveness of the economy. 
The Croatian economy is well integrated with the euro area through trade and 
financial linkages. In 2021 exports of goods and services to the euro area constituted 
53.8% of total exports, while the corresponding figure for imports was higher, at 
57.1%. In the same year the share of the euro area in Croatia’s stock of inward direct
investment stood at 71.9% and its share in the country’s stock of portfolio investment 
liabilities was 58.1%. The share of Croatia’s stock of foreign portfolio investment 
assets invested in the euro area amounted to 35.7% in 2021. Croatia’s economy is
also characterised by a high degree of euroisation, which goes beyond public and 
private debt and is also reflected in the currency composition of household savings 
and liquid assets of non-financial corporates. 
5.3.4 Long-term interest rate developments 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in Croatia stood at 0.8% on average and thus remained below the 2.6% 
reference value for the interest rate convergence criterion (Chart 5.3.5). 
Long-term interest rates in Croatia stood at 2.4% at the end of the reference 
period, after having declined continuously from 2012, when they averaged 
around 6%, to the beginning of 2022. Over the past ten years the declining trend in 
long-term interest rates in Croatia was interrupted by two short-lived episodes of 
sizeable increases in 2013 and mid-2015. In both cases, domestic factors played a 
major role in driving up long-term interest rates. In 2013 the increase in the long-term 
interest rate was accompanied by the downgrading of Croatian sovereign debt to 
below investment grade and by rising credit default swap spreads, which are a 
measure of investors’ perceptions of Croatian sovereign risk. In 2015 the upward 
movements in the risk premia on Croatian long-term bond yields were driven by the 
slowdown in the economy and the perceived political uncertainty. The expected 
deterioration in bank balance sheets following the conversion into euro of loans 
originally denominated in Swiss francs also raised sovereign yields via the 
sovereign-bank nexus. Since the second half of 2015 long-term interest rates in 
Croatia have been falling steadily. This can be attributed to the progress with fiscal 
consolidation that allowed a more accommodative monetary policy stance in a context 
of an improving economic outlook. Global developments also contributed to the trend 
decline in long-term interest rates. More recently, after falling further in 2019 in line 
with developments in global financial markets, long-term interest rates fluctuated 
around 1% between April and October 2020, with the dynamics influenced by the 
impact of the COVID-19 pandemic on financial market volatility. However, in the third 
quarter of 2020 long-term interest rates resumed their declining trend, also thanks to 
the government bond purchase programme initiated by Hrvatska narodna banka in 
March 2020 to maintain favourable financing conditions and support the stability of the 
government bond market. The declining trend of long-term interest rates continued 
until the beginning of 2022, when financial markets seemed to assess the resurgence 
of inflation in 2021 – which occurred in a context of robust economic growth – to be 
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more persistent than previously expected. In April 2022 the long-term interest rate 
stood at 2.4%. Over the review period, credit default swap spreads have widened 
slightly by around 10 basis points. In the past two years two of the three main 
international rating agencies have upgraded the country’s rating. 
Croatia’s long-term interest rate differential vis-à-vis the euro area has declined 
since 2012 and stood at 1.0% in April 2022. From 2012 to mid-2016 the long-term 
interest rate differential fluctuated between 2% and 3%, reflecting investors’ 
perceptions of a more vulnerable sovereign outlook for Croatia than for the euro area 
as a whole, despite inflation being, at times, lower than in the euro area. Since the 
summer of 2016 the progress made on structural policy and the substantial alignment 
of the domestic business cycle with that of the euro area contributed to the gradual but 
continuous convergence of Croatian long-term interest rates towards euro area levels. 
Therefore, the differential has increased only slightly over the review period, from 
0.9% in April 2020 to 1.0% in April 2022. 
Capital markets in Croatia are smaller and less developed than those in the 
euro area (Table 5.3.4), but they are among the most developed in central and 
eastern Europe. The Croatian financial system is still dominated by foreign-owned 
banks (which account for around 90% of the total assets of the banking sector), but 
non-banking institutions are also playing an increasingly significant role in financial 
intermediation. In particular, insurance corporations and, since the start of the pension 
system reform in 2002, pension funds together account for around 18% of total 
financial sector assets. Stock market capitalisation as a percentage of GDP has 
historically been higher than in many peer countries in the region and stood at 32.7% 
in 2021. Overall, the degree of financial intermediation remains much lower than in the 
euro area, but it is in line with that of peer countries in the region. MFI credit to private 
residents as a percentage of GDP stabilised at 54.7% in 2021, which is in line with the 
average over the last five years. The corporate debt market remains underdeveloped. 
The share of debt securities issued by financial and non-financial institutions as a 
percentage of GDP stood at 1.4% and 4.4% respectively in 2021, thus remaining close 
to their very low historical levels. Recourse by Croatia’s banking sector to funding from 
euro area banks has fallen dramatically over the past ten years. The claims of euro 
area MFIs on resident MFIs decreased from an annual average of more than 7% of 
GDP between 2012 and 2021 to 1.9% of GDP in 2021. Since 2012 the share of MFI 
loans denominated in domestic currency in total loans extended to the private sector 
has increased consistently, from about 27% at the end of 2012 to 48% in February 
2022. 
  
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Croatia - Price developments
S 1 ECB Convergence Report, May 2022 
Chart 5.3.1 HICP inflation and reference value 1) 
(annual percentage changes)
-2
0
2
4
6
8
10
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
-2
0
2
4
6
8
10
HICP
HICP (12-month moving average)
Reference value
Sources: European Commission (Eurostat) and ECB calculations.
1) The basis of the calculation of the reference value for the period from May 2021 to April 2022 is the unweighted arithmetic average of the annual percentage
changes in the HICP for France, Finland and Greece plus 1.5 percentage points. The reference value is 4.9%.
Table 5.3.1 Measures of inflation and related indicators
(annual percentage changes, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Measures of inflation           
 HICP 1.1 1.0 1.3 1.3 1.6 0.8 0.0 2.7 6.1 2.8
 HICP excluding unprocessed food and energy 1.2 1.1 1.3 1.4 1.1 1.1 0.8 1.8 4.3 3.3
 HICP at constant tax rates 3) 0.9 0.5 1.4 1.2 1.5 1.4 0.3 2.4 - -
 CPI 1.0 0.7 1.2 1.1 1.5 0.8 0.2 2.6 6.1 2.8
 Private consumption deflator 1.0 0.7 1.3 0.9 1.4 1.1 0.3 2.7 6.0 2.5
 GDP deflator 1.1 0.5 1.6 1.2 2.0 1.9 -0.1 3.2 3.8 2.4
 Producer prices 4) 0.9 -0.7 2.5 2.1 2.4 0.8 -2.0 9.6 - -
 Related indicators           
 Real GDP growth 1.4 0.6 2.2 3.4 2.9 3.5 -8.1 10.2 3.4 3.0
 GDP per capita in PPS 5) (euro area = 100) 58.7 56.7 61.1 59.3 60.7 62.6 61.8 . - -
 Comparative price levels (euro area = 100) 66.1 65.7 66.6 65.6 66.8 67.4 66.8 . - -
 Output gap 6) -1.3 -2.9 0.3 1.5 2.5 3.6 -6.5 0.3 0.8 1.1
 Unemployment rate (%) 7) 12.1 16.0 8.3 11.2 8.4 6.6 7.5 7.6 6.3 6.0
 Unit labour costs, whole economy -0.2 -2.1 1.8 -0.7 3.6 0.0 9.8 -3.1 1.1 1.5
 Compensation per employee, whole economy 0.7 -1.0 2.4 0.2 3.9 0.4 2.1 5.6 3.0 2.7
 Labour productivity, whole economy 0.8 1.1 0.6 0.9 0.3 0.4 -7.0 8.9 1.8 1.1
 Imports of goods and services deflator 1.0 -0.1 2.1 2.3 1.1 0.4 -0.1 6.7 7.6 3.7
 Nominal effective exchange rate 8) 0.3 -0.3 0.9 1.6 2.4 -0.4 0.0 0.7 - -
 Money supply (M3) 9) 5.7 3.0 8.5 5.6 8.4 4.5 11.0 13.0 - -
 Lending from banks 10) 1.4 -1.6 4.4 4.5 4.4 5.8 3.6 3.7 - -
 Stock prices (CROBEX) 11) 19.5 14.6 4.2 -7.6 -5.1 15.4 -13.8 19.6 - -
 Residential property prices 2.4 -1.8 6.8 3.8 6.1 9.0 7.7 7.3 - -
Sources: European Commission (Eurostat, Directorate-General for Economic and Financial Affairs), national data for CPI, money supply, lending from banks
and ECB calculations based on Bloomberg Finance L.P. data for stock prices.
1) Multi-annual averages calculated using the geometric mean, except for GDP per capita in PPS, comparative price levels, output gap and unemployment rate, for which the
arithmetic mean is used.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) The difference between the HICP and the HICP at constant tax rates shows the theoretical impact of changes in indirect taxes (e.g. VAT and excise duties) on the overall rate
of inflation. This impact assumes a full and instantaneous pass-through of tax rate changes to the price paid by the consumer.
4) Domestic sales, total industry excluding construction.
5) PPS stands for purchasing power standards.
6) Percentage difference from potential GDP: a positive (negative) sign indicates that actual GDP is above (below) potential GDP.
7) Definition conforms to International Labor Organization guidelines.
8) EER-42 group of trading partners. A positive (negative) sign indicates an appreciation (depreciation).
9) The series includes repurchase agreements with central counterparties.
10) Adjusted for the derecognition of loans from the MFI statistical balance sheet due to their sale or securitisation.
11) Multi-annual and annual figures represent the percentage change between the end of the given period and the end of the previous period.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 312 – 
Croatia - Fiscal developments
S 2 ECB Convergence Report, May 2022 
Chart 5.3.2 General government balance and debt
(as a percentage of GDP)
-11
-9
-7
-5
-3
-1
1
3
5
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
30
40
50
60
70
80
90
Government balance (left-hand scale)
Government debt (right-hand scale)
Reference values (government balance: -3%; government debt: 60%)
Sources: European System of Central Banks and European Commission (Eurostat).
Table 5.3.2 Government budgetary developments and projections
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Government balance -3.0 -4.1 -1.9 0.8 0.0 0.2 -7.3 -2.9 -2.3 -1.8
 Total revenue 45.0 43.9 46.2 45.5 45.5 46.3 47.2 46.4 46.4 46.7
 Current revenue 44.3 43.5 45.1 45.0 45.0 45.4 45.6 44.4 43.9 43.7
 Direct taxes 6.2 6.3 6.2 6.2 6.3 6.5 6.5 5.4 5.3 5.3
 Indirect taxes 18.9 18.5 19.3 19.2 19.6 19.7 18.7 19.3 19.3 19.5
 Net social contributions 11.6 11.6 11.5 11.7 11.5 11.3 11.7 11.3 11.1 10.9
 Other current revenue 3) 7.6 7.1 8.1 7.9 7.5 7.9 8.7 8.4 8.2 8.0
 Capital revenue 0.7 0.4 1.1 0.4 0.5 0.9 1.6 1.9 2.4 3.0
 Total expenditure 48.0 48.1 48.0 44.7 45.5 46.1 54.5 49.2 48.6 48.5
 Current expenditure 42.4 42.7 42.0 40.7 40.1 39.7 46.7 42.8 41.5 40.8
 Compensation of employees 11.8 11.5 12.1 11.2 11.6 11.6 13.3 12.5 12.4 12.5
 Social benefits 16.0 16.3 15.7 15.4 15.2 15.1 17.1 15.5 15.2 15.0
 Interest payable 2.7 3.2 2.1 2.6 2.3 2.2 2.0 1.6 1.4 1.3
 Other current expenditure 4) 11.9 11.6 12.2 11.5 11.1 10.9 14.3 13.2 12.5 12.2
 Capital expenditure 5.7 5.4 6.0 4.0 5.3 6.3 7.9 6.4 7.2 7.7
  of which: Investment 3.9 3.7 4.2 2.7 3.5 4.3 5.6 4.8 5.3 5.7
 Cyclically adjusted balance -2.4 -2.9 -2.0 0.1 -1.2 -1.3 -4.4 -3.0 -2.6 -2.2
 One-off and temporary measures 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
 Structural balance 5) -2.4 -2.9 -2.0 0.1 -1.2 -1.4 -4.4 -3.1 -2.7 -2.3
 Government debt 78.5 79.4 77.6 76.7 73.3 71.1 87.3 79.8 75.3 73.1
 Average residual maturity (in years) 5.4 5.2 5.6 5.5 5.3 5.4 5.8 5.8 . .
 In foreign currencies (% of total) 75.8 78.8 72.8 76.3 74.7 71.3 70.9 70.7 . .
  of which: Euro 72.8 74.4 71.2 72.7 70.9 71.1 70.8 70.6 . .
 Domestic ownership (% of total) 61.6 58.1 65.1 60.8 63.5 67.5 67.9 66.0 . .
 Medium and long-term maturity (% of total) 6) 93.8 92.8 94.8 95.1 95.2 95.3 93.8 94.3 . .
  of which: Variable interest rate (% of total) 24.5 31.1 17.9 21.7 19.9 16.7 13.9 17.2 . .
 Deficit-debt adjustment 0.6 0.0 1.2 1.1 0.3 1.8 2.5 0.2 . .
 Net acquisitions of main financial assets 0.7 0.3 1.2 0.6 0.4 1.5 2.9 0.4 . .
 Currency and deposits 0.4 0.0 0.8 0.2 0.1 1.7 2.4 -0.3 . .
 Debt securities 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 . .
 Loans 0.4 0.3 0.4 0.4 0.5 -0.1 0.5 0.7 . .
 Equity and investment fund shares or units 0.0 0.0 -0.1 0.0 -0.2 -0.1 0.0 0.0 . .
 Revaluation effects on debt 0.1 0.1 0.1 -0.3 -0.7 0.3 1.0 0.2 . .
  of which: Foreign exchange holding    
 gains/losses 0.1 0.2 0.1 -0.4 -0.6 0.3 1.1 0.2 . .
 Other 7) -0.3 -0.4 -0.1 0.8 0.5 0.0 -1.4 -0.4 . .
 Convergence programme: government balance - - - - - - - - -2.8 -1.6
 Convergence programme: structural balance - - - - - - - - -2.9 -2.4
 Convergence programme: government debt - - - - - - - - 76.2 71.7
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast, except for convergence programme data.
3) Sales and other current revenue.
4) Intermediate consumption, subsidies payable and other current expenditure.
5) Cyclically adjusted balance excluding one-off and other temporary measures.
6) Original maturity of more than one year.
7) Time of recording differences and other factors (sector reclassifications and statistical discrepancies).
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 313 – 
Croatia - Exchange rate and external developments
S 3 ECB Convergence Report, May 2022 
Chart 5.3.3 Bilateral exchange rate and short-term
interest rate differential 1) 
Chart 5.3.4 Effective exchange rates 2) 
(EER-42 group of trading partners; monthly averages; index: Q1 1999 = 100)
(HRK/EUR exchange rate: monthly averages;
difference between three-month interbank interest rates
and three-month EURIBOR: basis points, monthly values)
7.8
7.7
7.6
7.5
7.4
7.3
2012 2014 2016 2018 2020
0.0
1.0
2.0
3.0
4.0
5.0
HRK/EUR exchange rate (left-hand scale)
Interest rate differential (right-hand scale)
95
98
101
104
107
110
2012 2014 2016 2018 2020
100
102
104
106
108
110
Nominal (left-hand scale)
Real (right-hand scale)
Sources: National data and ECB calculations.
1) The interest rate differential is calculated against ZIBOR. Production of ZIBOR
reference rate was discontinued as of 1 January 2020; a comparable rate is not 
currently available.
Source: ECB.
2) The real EER-42 is CPI-deflated. An increase (decrease) in the EER indicates
an appreciation (depreciation).
Table 5.3.3 External developments
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Balance of payments
Current account and capital account balance 3) 2.6 1.2 4.0 4.4 3.1 4.6 2.0 5.8 6.2 4.8
Current account balance 1.5 0.6 2.3 3.5 1.9 3.0 -0.1 3.4 1.7 0.3
Goods -16.5 -15.2 -17.9 -16.9 -18.3 -18.8 -17.3 -18.1 . .
Services 15.5 14.7 16.3 17.6 17.5 18.5 10.5 17.2 . .
Primary income -0.7 -1.7 0.3 -0.4 -0.5 -0.1 2.3 0.3 . .
Secondary income 3.2 2.8 3.7 3.3 3.2 3.4 4.4 4.0 . .
Capital account balance 1.1 0.6 1.7 0.9 1.3 1.6 2.1 2.4 . .
Combined direct and portfolio investment balance 3) -2.6 -2.9 -2.3 -1.5 0.3 -3.7 -1.5 -5.1 . .
Direct investment -2.7 -2.1 -3.3 -2.3 -1.6 -6.1 -1.3 -5.0 . .
Portfolio investment 0.1 -0.8 1.0 0.8 1.9 2.4 -0.1 -0.1 . .
Other investment balance 2.8 3.7 2.0 1.6 0.0 6.5 2.3 -0.5 . .
Reserve assets 2.9 1.0 4.3 5.2 2.9 1.8 1.2 10.5 . .
Exports of goods and services 45.9 42.9 48.8 49.3 49.5 50.8 42.0 52.5 . .
Imports of goods and services 46.9 43.4 50.4 48.6 50.3 51.1 48.8 53.4 . .
Net international investment position 4) -66.6 -83.5 -49.7 -64.2 -55.7 -46.7 -47.8 -33.9 . .
Gross external debt 4) 93.2 106.6 79.8 87.9 80.8 72.7 79.8 77.9 . .
 Trade with the euro area 5)
Exports of goods and services 55.6 57.1 54.4 54.5 55.7 54.5 53.6 53.8 . .
 Imports of goods and services 58.6 59.3 58.0 58.5 57.1 58.3 58.9 57.1 . .
 Investment position with the euro area 5)
Direct investment assets 4) 30.9 30.9 30.8 28.3 29.9 29.5 29.7 36.8 . .
Direct investment liabilities 4) 70.1 68.9 71.2 68.4 69.1 73.1 73.3 71.9 . .
Portfolio investment assets 4) 49.9 59.3 42.4 48.2 48.7 42.6 36.8 35.7 . .
Portfolio investment liabilities 4) 56.6 53.4 59.9 58.7 59.4 61.7 61.8 58.1 . .
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean. Owing to the unavailability of data, the multi-annual averages for the "trade with the euro area" series and for the
"direct investment assets", "portfolio investment assets" and "direct investment liabilities" components of the "investment position with the euro area" series are calculated
for the period starting in 2013.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) Differences between totals and the sum of their components are due to rounding.
4) End-of-period outstanding amounts.
5) As a percentage of the total.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 314 – 
Croatia - Long-term interest rate developments
S 4 ECB Convergence Report, May 2022 
Chart 5.3.5 Long-term interest rate 1) 
(monthly averages in percentages)
Chart 5.3.6 Long-term interest rate and HICP inflation
differentials vis-à-vis the euro area
(monthly averages in percentage points)
0
1
2
3
4
5
6
7
8
2012 2014 2016 2018 2020
0
1
2
3
4
5
6
7
8
Long-term interest rate
Long-term interest rate (12-month moving average)
Reference value
-2
-1
0
1
2
3
4
2012 2014 2016 2018 2020
-2
-1
0
1
2
3
4
Long-term interest rate differential
HICP inflation differential
Sources: European System of Central Banks and ECB calculations.
1) The basis of the calculation of the reference value for the period from May
2021 to April 2022 is the unweighted arithmetic average of the interest rate
levels in France, Finland and Greece plus 2 percentage points. The reference
value is 2.6%.
Sources: European System of Central Banks, ECB calculations and European
Commission (Eurostat).
Table 5.3.4 Long-term interest rates and indicators of financial development and integration
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2018 2019 2020 2021 May. 2021 Memo item:
to euro area
Apr. 2022 2021
 Long-term interest rates
 Croatia 2) 2.9 4.4 1.5 2.2 1.3 0.8 0.4 0.8 -
 Euro area 3), 4) 1.4 2.2 0.6 1.1 0.4 0.1 0.1 0.4 -
Euro area AAA par curve, ten-year residual maturity 2), 4) 0.6 1.2 0.0 0.5 -0.2 -0.4 -0.3 -0.1 -
 Indicators of financial development and integration
Debt securities issued by financial corporations 5) 0.5 - 0.5 0.3 0.4 0.4 1.4 - 66.7
Debt securities issued by non-financial corporations 6) 4.6 - 4.1 3.7 4.0 4.3 4.4 - 13.4
Stock market capitalisation 7) 36.9 - 35.7 34.4 36.4 36.8 32.7 - 77.7
MFI credit to non-government residents 8) 61.6 66.8 56.3 55.4 53.8 60.6 54.7 - 111.1
Claims of euro area MFIs on resident MFIs 9) 7.3 11.4 3.1 4.1 3.1 3.1 1.9 - 29.5
Sources: European System of Central Banks and ECB calculations.
1) Multi-annual averages calculated using the arithmetic mean.
2) Average interest rate.
3) GDP-weighted average of the euro area long-term interest rates for the purpose of assessing convergence.
4) Included for information only.
5) Outstanding amount of debt securities issued by resident MFIs (excluding the national central bank) and other financial corporations. Data available since 2013.
6) Outstanding amount of debt securities issued by resident non-financial corporations. Data available since 2013.
7) Outstanding amount of listed shares issued by residents at market values. Data available since 2013.
8) MFI (excluding national central bank) credit to domestic non-MFI residents other than general government. Credit comprises outstanding amounts of loans and debt securities.
Data available since 2010.
9) Outstanding amount of deposits and debt securities issued by domestic MFIs (excluding the national central bank) held by euro area MFIs as a percentage of total liabilities
of domestic MFIs (excluding the national central bank). Total liabilities exclude capital and reserves and remaining liabilities. Data available since 2010.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 315 – 
Convergence Report, June 2022 117 
5.4 Hungary
5.4.1 Price developments
In April 2022 the 12-month average rate of HICP inflation in Hungary was 6.8%, 
i.e. well above the reference value of 4.9% for the criterion on price stability
(Chart 5.4.1). This rate is expected to increase gradually over the coming months,
driven mainly by the higher commodity prices, broadening price pressures and further
aggravation of supply bottlenecks resulting from the Russia-Ukraine war.
Over the past ten years the 12-month average rate of HICP inflation has 
fluctuated within a relatively wide range, from -0.3% to 6.8%, and the average 
for that period was elevated at 2.5%. In 2012, with economic activity slowing, 
inflation rose to 5.7% as a result of, among other things, a hike in the value added tax 
rate. The ensuing economic recovery was to a large extent supported by government 
and central bank policies in an environment of contracting bank lending to the private 
sector. As inflation receded, the Magyar Nemzeti Bank loosened its monetary policy 
stance. In 2014 and 2015 the average annual rate of HICP inflation was close to zero 
owing to a combination of factors, including global commodity price developments, 
utility price cuts, relatively muted wage growth and subdued external price pressures. 
However, from 2016 it accelerated again, reaching 2.4% in 2017 on account of the 
ongoing economic recovery, and rising further to 2.9% in 2018 and 3.4% in 2019. This 
increase reflected strong domestic demand and a tight labour market environment, as 
well as changes to indirect taxes, most notably excise duties on tobacco products, the 
impact of volatile items sensitive to global commodity price movements and strong 
wage growth, which were partially offset by a reduction in social security contributions 
and VAT rates on some food items and services. The outbreak of the coronavirus 
(COVID-19) pandemic in March 2020 resulted in a large drop in economic activity in 
the second quarter of that year, with annual real GDP falling by 4.5%. The authorities 
took unprecedented fiscal, macroprudential and monetary policy measures to mitigate 
the impact of the pandemic on the economy. In particular, the Magyar Nemzeti Bank 
made two key policy rate cuts of 15 basis points each in June and July 2020, bringing 
the rate down to a historical low of 0.6%. It also purchased government securities in 
the secondary market. At the same time, inflation remained rather resilient, standing at 
3.4% in 2020. This was largely attributable to higher prices for food and services, the 
interplay of the effects of the overlapping demand and supply shocks triggered by the 
pandemic and the weakening exchange rate, together with the pre-pandemic very 
robust domestic demand and buoyant wage growth amid tight labour market 
conditions, which offset the negative contribution of fuel prices to inflation. In 2021 the 
economy rebounded strongly, with real GDP rising at an annual average rate of 7.1%. 
Inflation also picked up considerably, driven mainly by sharp increases in energy 
prices, particularly towards the end of the year, but also by the supply bottlenecks 
triggered by the pandemic. In this context, the Magyar Nemzeti Bank started a cycle of 
interest rate hikes, raising its key policy rate seven times from June 2021, which 
brought it up to 2.4% in December. Average HICP inflation stood at 5.2% in 2021 
(Table 5.5.1). 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 316 –
 
Convergence Report, June 2022 
 
118 
In the first four months of 2022 the average annual rate of HICP inflation 
increased further to 8.6%. Continuing the upward trend it had initiated at the end 
2021, HICP inflation rose further at the beginning of 2022. This was largely due to 
higher energy and commodity prices, while the inflationary effects of the robust wage 
growth stemming mainly from administrative wage increases were largely offset by the 
reduction in social security contributions paid by the employer. Against this 
background, the Magyar Nemzeti Bank raised its key policy rate four times in the first 
four months of 2022, bringing it up to 5.4% in April. Following Russia’s invasion of 
Ukraine in late February, inflationary pressures intensified, notably on account of 
rapidly rising energy and commodity prices. 
Policy choices have played an important role in shaping inflation dynamics in 
Hungary over the past decade, most notably the orientation of monetary policy 
towards price stability. The Magyar Nemzeti Bank defines its inflation target as an 
annual rate of consumer price inflation of 3% with an ex-ante tolerance band of 
±1 percentage point that was adopted in March 2015. Successive cuts in 
administrative prices, which constitute a large share of Hungary’s HICP basket of 
goods and services, have helped to contain consumer price inflation. 
Inflation is expected to decline gradually in the coming years. However, the 
forecasts are subject to considerable uncertainty in the light of the 
Russia-Ukraine war. Over the longer term there are concerns about the 
sustainability of inflation convergence in Hungary. According to the European 
Commission’s Spring 2022 Economic Forecast, the rate of HICP inflation is projected 
to accelerate significantly in 2022, up to a high level of 9.0%, before declining to 4.1% 
in 2023. This outlook is based on the expectation that economic growth will moderate, 
but nevertheless remain robust, with unemployment stabilising at historically low 
levels and private consumption continuing to be the main driver of growth. The risks to 
the inflation outlook are tilted to the upside, as labour market conditions remain tight, 
global supply bottlenecks could have a further impact on price developments in certain 
product and market segments, and tensions in energy markets may continue to 
exacerbate inflationary pressures. Looking further ahead, unless counteracted by an 
appreciation in the nominal exchange rate, the catching-up process is likely to result in 
positive inflation differentials vis-à-vis the euro area, since GDP per capita and price 
levels are still lower in Hungary than in the euro area. In order to prevent the build-up 
of excessive price pressures and macroeconomic imbalances, the catching-up 
process must be supported by appropriate policies. 
Achieving an environment that is conducive to sustainable convergence in 
Hungary requires stability-oriented economic policies and wide-ranging 
structural reforms. Further improving the quality of public institutions and ensuring 
that they are free from undue political intervention, as well as implementing adequate 
product market policies, are prerequisites for private sector-led economic growth. 
Enhanced governance, stronger institutions and a better functioning administration at 
the national level should, among other things, help to improve the absorption of EU 
funds. In this respect, however, on 27 April 2022 the European Commission, under the 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 317 – 
Convergence Report, June 2022 119 
general regime of conditionality for the protection of the Union budget,188 sent a 
written notification to the Hungarian authorities about concerns over respect for the 
rule of law, which may result in a suspension of or reduction in the disbursement of EU 
funds. With regard to macroeconomic imbalances, the European Commission did not 
select Hungary for an in-depth review in its Alert Mechanism Report 2022. 
Financial sector policies should be aimed at safeguarding financial stability and 
ensuring that the financial sector makes a sound contribution to sustainable 
economic growth. Efforts to strengthen banks’ balance sheets over the past years 
have borne fruit, and the banking sector overall has sound capital positions and 
sufficient liquidity buffers. Bank profitability has improved and the non-performing loan 
ratio has declined further. However, there is still the risk that borrowers will have 
difficulties servicing their debts once the debt servicing moratorium that was granted in 
response to the pandemic has been phased out. In turn, this could push up the 
number of non-performing loans. Moreover, a deterioration in the quality of loan 
portfolios could put additional pressure on banks’ profitability. Strengthening the
banking sector’s long-term profitability will also require consolidation in the sector and 
further financial deepening. Financial policies should be geared towards achieving 
sustainable developments in loans to households and avoiding the build-up of 
macro-financial imbalances. Existing or planned economic policy measures to protect 
specific groups of society or the government budget should take into account any 
potentially adverse implications for financial stability. At the same time, there are still 
signs of overvaluation in at least some segments of the housing market, mainly in the 
capital city. Moreover, corporate real estate lending in foreign currency has been 
increasing steadily, which, going forward, may lead to significant currency mismatches 
and heighten credit institutions’ foreign exchange risk. In order to further bolster 
confidence in the financial system, the national competent authorities should continue 
to improve their supervisory practices, among other things, by following the applicable 
recommendations from the relevant international and European bodies, and by 
collaborating closely with other national supervisors of EU Member States within the 
supervisory colleges. 
5.4.2 Fiscal developments
Hungary’s general government budget deficit was well above the 3% reference 
value in 2021 and its debt was above the 60% reference value. In the reference 
year 2021, the general government budget balance recorded a deficit of 6.8% of GDP, 
i.e. significantly above the 3% reference value. The general government gross
debt-to-GDP ratio was 76.8%, i.e. above the 60% reference value (Table 5.4.2).
Compared with the previous year, the deficit ratio decreased by 1 percentage point of
GDP and the debt ratio declined notably by 2.8 percentage points. Regarding other
fiscal factors, the deficit ratio exceeded the ratio of public investment to GDP in 2021.
The budget deficits in 2020 and 2021, and therefore the debt ratio, were substantially
188  Regulation (EU, Euratom) 2020/2092 of the European Parliament and of the Council of 16 December 
2020 on a general regime of conditionality for the protection of the Union budget (OJ L 433I, 22.12.2020, 
p. 1).
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 318 –
 
Convergence Report, June 2022 
 
120 
affected by the economic impact of the COVID-19 pandemic and the fiscal policy 
measures taken in response to it. 
Hungary has been subject to the preventive arm of the Stability and Growth 
Pact since 2013. In May 2022, the European Commission found that the general 
government deficit in 2021 was above and not close to the reference value of 3% of 
GDP. The excess over the reference value was considered to be exceptional but not 
temporary. Overall, the Commission’s analysis suggested that the deficit criterion had 
not been fulfilled. Moreover, as Hungary’s debt ratio in 2021 was higher than the 60% 
reference value and had not decreased in line with the debt reduction benchmark, it 
was found that the debt criterion had not been fulfilled. However, in the Commission’s 
view, the need to comply with the debt reduction benchmark was not warranted under 
the current exceptional economic conditions as such compliance would imply too 
demanding a frontloaded fiscal effort that risked jeopardising growth. Moreover, taking 
into account the exceptional uncertainty created by the continued extraordinary 
macroeconomic and fiscal impact of the COVID-19 pandemic, together with the 
invasion of Ukraine by Russia, the Commission did not propose opening new 
excessive deficit procedures at that stage. In the preceding year, in June 2021, the 
European Commission had found that the general government deficit in 2020 was 
above and not close to the reference value of 3% of GDP and that the debt criterion 
had not been fulfilled, but it had argued against taking a decision to place Member 
States under the excessive deficit procedure in light of the exceptional uncertainty. 
During the pre-pandemic period, Hungary had been compliant with the corrective arm. 
Hungary was subject to a significant deviation procedure between 2018 and 2020 
following a significant deviation from its medium-term budgetary objective in 2017. 
Both cyclical and non-cyclical factors relating to the COVID-19 pandemic 
contributed to a deterioration in the budget balance over the period 2019-21. 
Prior to the COVID-19 crisis, the budget deficit had benefited from favourable 
macroeconomic conditions and had remained below the 3% reference value since 
2012, reaching 2.1% of GDP in 2019. The structural position has since deteriorated 
and stood at a deficit of around 3.8% of GDP in 2019, without any notable 
improvement since 2017. On account of the COVID-19 pandemic, the budget balance 
declined in 2020 by 5.7 percentage points, before improving by 1 percentage point in 
2021 to record a deficit of 6.8% of GDP. This deterioration was due to both (i) a 
significant decrease in government revenues (well above the one suggested by 
cyclical developments) and (ii) an increase in public expenditure, leading to a 
significant increase in the structural deficit (which rose from 3.8% of GDP in 2019 to 
6.6% in 2021). Therefore, the sharp deterioration in the government balance reflected 
not only the marked worsening of the macroeconomic outlook but also the fiscal 
measures that were implemented to mitigate the crisis. 
The government debt-to-GDP ratio has remained above the 60% reference value 
over the past decade, having followed a downward path from 2012 to 2019, 
before increasing again during the COVID-19 pandemic. In the run-up to the 
pandemic, the debt ratio followed a downward path, underpinned largely by a 
favourable interest-growth differential. Having declined by 15 percentage points since 
2012, the debt ratio reached a trough of 65.5% of GDP in 2019. It then increased 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 319 – 
 
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121 
markedly on account of the impact of the COVID-19 crisis, rising by 11.3 percentage 
points to reach 76.8% in 2021, wiping out all of the reduction efforts made over the 
previous ten years. By reducing GDP and increasing public expenditure, coupled with 
unfavourable deficit-debt adjustments (due to the acquisition of financial assets and 
revaluation effects), the COVID-19 pandemic and the fiscal response to it explain a 
large part of the increase observed over the period 2020-21. 
The level and structure of government debt indicate low roll-over risks and low 
sensitivity to exchange rate movements. The reliance on short-term funding has 
been reduced over time: the share of government debt with a short-term maturity 
significantly declined from 18.2% in 2017 to 5.9% in 2021, which helps to shield debt 
financing costs from roll-over risks in times of stress. It is worth noting that a 
substantial part of long-term government debt can be redeemed earlier upon request 
by the holder (MÁP+ bonds), although such early redemption has historically been low 
and investors who do so tend to reinvest in another long-term government bond. The 
risk of early redemption is mitigated by the structure of interest payments and the 
repurchase terms and conditions. Hungary has managed to considerably reduce the 
proportion of foreign currency-denominated government debt (which is almost 
exclusively denominated in euro); this declined from 39.3%, on average, over the 
period 2012-16 to 22.6% in 2021. At the same time, fiscal balances remain relatively 
sensitive to changes in the exchange rate vis-à-vis the euro. 
The European Commission’s Spring 2022 Economic Forecast foresees an 
improvement in the budget balance and a slight decrease in the debt ratio. 
According to the European Commission’s latest forecast, the headline deficit is 
expected to significantly decrease from a record level of 7.8% of GDP in 2020 but stay 
above 3%, reaching 4.9% of GDP by 2023.189 Over the period 2022-23, the structural 
deficit is expected to stand well above the medium-term objective (a structural deficit 
of 1.0% of GDP). Nevertheless, the Stability and Growth Pact’s general escape 
clause, which continues to be applied in 2022 and is also expected to remain in place 
in 2023, provides that “in periods of severe economic downturn for the euro area or the 
Union as a whole, Member States may be allowed temporarily to depart from the 
adjustment path towards the medium-term budgetary objective…, provided that this 
does not endanger fiscal sustainability in the medium term”. With regard to the debt 
ratio, the European Commission forecasts a slight decrease by 0.7 percentage point 
of GDP by 2023, to reach 76.1% of GDP, thus remaining above the 60% reference 
value. Hungary’s medium-term fiscal policy strategy, as presented in the 2022 update 
of the convergence programme, forecasts a path for both the nominal and the 
structural deficit which is significantly (more than 1 percentage point of GDP) lower 
than the European Commission’s Spring 2022 Economic Forecast. 
Despite some progress in reforming the fiscal framework, there is scope for 
further improvement. In December 2019, the Hungarian Parliament adopted 
amendments to the national fiscal rules that should increase their transparency and 
enhance their implementation. However, the fiscal framework should put stronger 
emphasis on the multi-annual dimension of the budget process. In particular, the 
 
189  In January 2020, Hungary’s medium-term objective changed from a structural deficit of 1.5% of GDP to a 
structural deficit of 1.0% of GDP. 
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122 
incentives to systematically spend budget reserves before the end of the calendar 
year should be removed, as they lower the quality of public spending. 
Hungary is at medium risk of fiscal stress over the medium term and at high risk 
over the long term, mostly on account of projected debt remaining above the 
60% reference value and the ageing population. The European Commission’s 
2021 Fiscal Sustainability Report pointed to medium risks in the medium term190 and 
high risks in the long term.191 This higher medium-term risk compared with the 2019 
assessment was driven by the notable COVID-19 pandemic-related increase in the 
debt-to-GDP ratio. Looking at the longer term, according to the 2021 Ageing Report 
prepared by the Ageing Working Group (AWG) of the EU’s Economic Policy 
Committee,192 Hungary would experience a significant rise in age-related expenditure 
of 5.5 percentage points by 2070 under the AWG’s reference scenario, from a level of 
17.1% of GDP in 2019. Under the AWG’s risk scenario, the increase was projected to 
be 9.8 percentage points (arising mostly from increases of 3.1% and 1.2% of GDP in 
long-term care and healthcare respectively), which is significantly above the EU 
average. All these factors suggest that reforms are needed to improve the long-term 
sustainability of public finances. 
Looking ahead, a prudent and credible fiscal policy, as well as further structural 
reforms, are needed for public finances to ensure a downward debt path. While 
fiscal policy should remain agile in its response to the evolving pandemic situation and 
given the geopolitical situation, a prudent fiscal policy is needed to safeguard the 
sustainability of public finances. A consistent and prudent fiscal policy will ensure that 
Hungary complies with the Stability and Growth Pact and maintains buffers to alleviate 
adverse shocks. The country has made some progress in reducing the complexity of 
its tax system. It has focused on decreasing the high tax-to-GDP ratio, especially the 
labour tax burden, and has improved the effectiveness of value added tax collection. 
Still, policies aimed at improvements in tax collection and reductions in the informal 
economy should continue to be pursued. Distortive tax measures should be avoided. 
Reinforcing multi-annual fiscal planning could mitigate the procyclicality of fiscal policy 
and increase the effectiveness of public spending. Structural reforms to the pension 
system, as well as the health and long-term care systems, are also necessary to 
address longer-term risks to fiscal sustainability. 
5.4.3 Exchange rate developments 
Over the reference period from 26 May 2020 to 25 May 2022, the Hungarian 
forint did not participate in ERM II, but traded under a flexible exchange rate 
regime. In the two-year reference period the Hungarian forint often traded significantly 
weaker than its May 2020 average exchange rate against the euro of 350.76 forints 
 
190  This assessment was confirmed by the updated debt sustainability analysis which was published as part 
of the European Commission’s country report for Hungary on 23 May 2022. 
191  However, this assessment does not necessarily reflect the uncertainty surrounding the long-term 
assumptions and, for high-debt countries, should be viewed with caution. 
192  European Commission and Economic Policy Committee, “The 2021 Ageing Report: Economic &amp; 
Budgetary Projections for the 28 EU Member States (2019-2070)”, European Economy Institutional 
Paper, No 148, European Commission, 2021. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 321 – 
 
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123 
per euro, which is used as a benchmark for illustrative purposes in the absence of an 
ERM II central rate (Chart 5.4.3). The maximum upward deviation from this 
benchmark was 2.2%, while the maximum downward deviation amounted to 12.1%. 
On 25 May 2022 the exchange rate stood at 388.25 forints per euro, i.e. 10.7% weaker 
than its average level in May 2020. In June 2020 the Magyar Nemzeti Bank entered a 
repo line arrangement with the ECB under which it could borrow up to €4 billion 
against adequate euro-denominated collateral to provide euro liquidity to Hungarian 
financial institutions in order to address possible needs owing to the pandemic. As this 
arrangement helped to reduce the potential risk of financial vulnerabilities, it may also 
have had an impact on exchange rate developments over the reference period. Over 
the past ten years the exchange rate of the Hungarian forint against the euro has 
depreciated by 32.2%. 
The exchange rate of the Hungarian forint against the euro exhibited, on 
average, a high degree of volatility over the reference period. Between late May 
and mid-August 2020 the Hungarian forint continued its recovery from the sharp 
depreciation recorded during the intensification of the COVID-19 pandemic in March 
2020, against the background of a gradual reduction in volatility in global foreign 
exchange markets and the conclusion of the repo line arrangement between the 
Magyar Nemzeti Bank and the ECB in June. Thereafter the exchange rate of the forint 
continued to display a relatively high degree of volatility, reflecting the continued 
uncertainty in global financial markets regarding the evolution of the pandemic. At the 
same time, the Magyar Nemzeti Bank entered a rate hiking cycle in June 2021 and 
has raised its key policy rate on 11 occasions since then, by a total of 450 basis points. 
As a result, short-term interest rate differentials against the three-month EURIBOR, 
which were relatively wide over the entire reference period, increased substantially to 
5.3 percentage points in the three-month period ending in March 2022. 
The real effective exchange rate of the Hungarian forint has depreciated over 
the past ten years (Chart 5.4.4). Looking forward, this indicator should be interpreted 
with caution, as Hungary is subject to a process of economic convergence, which 
complicates any long-term assessment of real exchange rate developments. 
Over the past ten years Hungary’s combined current and capital account 
balance remained in surplus until 2021 and contributed to a reduction in the 
country’s net foreign liabilities, which, however, remain high (Table 5.4.3). 
Between 2012 and 2016 Hungary’s combined current and capital account balance 
was in a range from around 4% to 7% of GDP, averaging 5.5% of GDP over the 
period. This reflected both a large trade surplus, averaging 7.3% – which more than 
offset the deficit on income payments – as well as a sizeable capital account surplus 
which was due to large transfers from the EU budget. In 2017 the trade balance 
started to narrow on account of very robust domestic demand. As a result, the current 
account balance turned negative as of 2019. As this was only partly offset by an 
increase in the capital account balance, the combined current and capital account 
surplus gradually narrowed from 2.8% in 2017 to 1.2% in 2019. In 2020 and 2021 the 
current account deficit widened further to 1.0% and 2.9% of GDP respectively, as 
exports declined more than imports during the pandemic, pushing the combined 
current and capital account into a deficit of 0.4% of GDP in 2021. Hungary’s combined 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 322 – 
 
Convergence Report, June 2022 
 
124 
current and capital account surplus has been mirrored in sizeable net financial 
outflows over the past decade. Since 2012, while being a net recipient of foreign direct 
investment flows, Hungary has been a net exporter of capital in the form of portfolio 
investment and other investment. Against this background, gross external debt 
gradually decreased from an average of 139.5% of GDP over the period 2012-16 to 
98.4% of GDP in 2019. In 2020 gross external debt increased sharply to 155.5% of 
GDP largely on account of transactions of a large multinational enterprise – which, 
however, also led to a roughly equal increase in the country’s gross external assets – 
and stood at 158.0% of GDP in 2021. As a result, Hungary’s net international 
investment position improved from an average of -76.0% of GDP over the period 
2012-16 to -49.1% in 2019, and then improved further to -48.9% of GDP in 2020 and 
-44.8% of GDP in 2021. However, the country’s net foreign liabilities remain high. 
Fiscal and structural policies therefore continue to be important for supporting external 
sustainability and the competitiveness of the economy. 
The Hungarian economy is well integrated with the euro area through trade and 
investment linkages. In 2021 exports of goods and services to the euro area 
constituted 56.5% of total exports, while the corresponding figure for imports was 
marginally lower, at 55.6%. In the same year the share of the euro area in Hungary’s 
stock of inward direct investment stood at 42.4% and its share in the country’s stock of 
portfolio investment liabilities was 45.7%. The share of Hungary’s stock of foreign 
assets invested in the euro area amounted to 29.6% in the case of direct investment 
and 59.0% for portfolio investment in 2021. 
5.4.4 Long-term interest rate developments 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in Hungary stood at 4.1% on average and thus above the 2.6% reference value 
for the interest rate convergence criterion (Chart 5.4.5). 
Long-term interest rates in Hungary have been on a downward path since 
mid-2012. A combination of factors has contributed to this declining trend, including 
improving macroeconomic conditions and lower global risk aversion. Several 
monetary policy measures adopted by the Magyar Nemzeti Bank – such as reducing 
the availability of its short-term deposit facilities, introducing foreign exchange and 
long-term interest rate swaps, purchasing corporate, mortgage and government 
bonds, and providing cheap financing for SMEs through its various Funding for Growth 
schemes – also contributed to the decline in long-term rates. Overall, long-term 
interest rates in Hungary declined from 9.5% in January 2012 to around 2% in 
December 2017. They then temporarily increased in 2018 owing to the rebound in 
economic activity and the resurgence of inflationary pressures. However, long-term 
interest rates resumed their decline in 2019, reflecting developments in global yields, 
until reaching a historical low in the summer of 2021. This more recent decline was 
initially driven by the deterioration in the global economic outlook and higher levels of 
global risk aversion, which favoured global portfolio flows into low-risk, high-return 
assets, including Hungarian fixed income assets. Since spring 2020 long-term interest 
rates have also been affected by the measures taken by the Magyar Nemzeti Bank to 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 323 – 
Convergence Report, June 2022 125 
dampen the high volatility in financial markets caused by the COVID-19 pandemic and 
ensure the proper functioning of the monetary policy transmission mechanism. Such 
measures consisted of changes to the operational framework; the introduction of a 
bond purchase programme including government, corporate and mortgage products; 
foreign exchange liquidity swaps; and an enhanced lending facility under the Funding 
for Growth Scheme. Furthermore, to counter the negative impact of the pandemic on 
the economic outlook, the central bank reduced its main policy rate from 0.9% – the 
level maintained since May 2016 – to 0.6% in July 2020. In 2021, following the robust 
recovery of the economy and, more notably, the acceleration in price dynamics, the 
Magyar Nemzeti Bank decided to increase the base rate, which stood at 2.9% in 
January 2022, close an emergency credit facility inaugurated during the pandemic, 
discontinue its forint liquidity-providing foreign exchange swaps, and phase out 
quantitative easing instruments. Since then the Magyar Nemzeti Bank has sharply 
increased its base rate on account of higher than expected inflation outcomes and 
distinct upside risks to future inflation arising from the consequences of the Russian 
invasion of Ukraine. As a result, the base rate stood at 5.4% at the end of April 2022. 
Mirroring these developments, long-term interest rates in Hungary stood at 6.6% in 
April 2022, 410 basis points higher than their April 2020 level. After declining for the 
last two years, credit default swap spreads for Hungarian government debt have 
recently increased to approximately their April 2020 level, standing at around 115 
basis points in April 2022. Hungary’s government debt is rated investment grade by all
three main rating agencies. 
Hungary’s long-term interest rate differential vis-à-vis the euro area increased 
recently after a long period of stabilisation (Chart 5.4.6). Hungary’s long-term 
interest rate differential declined from around 5% in 2012 to around 2% in 2015, where 
it stayed for a long period. The decline in the interest rate differential coincided with the 
gradual but sustained tightening of Hungary’s fiscal stance, which allowed the central 
bank to bring down interest rates and adopt a monetary policy stance closer to that 
prevailing in the euro area. Over the period from April 2020 to April 2022 the long-term 
interest rate differential increased from a trough of 1.7% in May 2020 to 5.2% in April 
2022, reflecting the positive and increasing inflation differential and the tightening of 
monetary policy in Hungary.  
Capital markets in Hungary are smaller and much less developed than in the 
euro area (Table 5.4.4). Stock market capitalisation as a percentage of GDP remains 
rather low at just over 18.2% of GDP in 2021, which is slightly above the annual 
average during the period 2012-21. In 2021 outstanding debt securities issued by 
non-financial corporations remained at low levels, standing at 5.9% of GDP, but have 
increased compared with the ten-year average of 2.2% over the period 2012-21. Debt 
securities issued by financial institutions in 2021 amounted to 7.0% of GDP, which is 
slightly below the average value recorded over the period 2012-21. Hungarian banks’ 
borrowing from euro area banks – a measure of banking system integration – has 
continued to fall, with claims by euro area banks on Hungarian banks standing at 3.6% 
of GDP in 2021, well below the average of 6.1% over the period 2012-21. The degree 
of financial intermediation is low compared with the euro area average and is among 
the lowest in the region. MFI credit to non-government residents stood at 41.0% of 
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Convergence Report, June 2022 
 
126 
GDP in 2021, practically the same as the average level recorded in the period 
2012-21. 
  
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 325 – 
Hungary - Price developments
S 1 ECB Convergence Report, May 2022 
Chart 5.4.1 HICP inflation and reference value 1) 
(annual percentage changes)
-2
0
2
4
6
8
10
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
-2
0
2
4
6
8
10
HICP
HICP (12-month moving average)
Reference value
Sources: European Commission (Eurostat) and ECB calculations.
1) The basis of the calculation of the reference value for the period from May 2021 to April 2022 is the unweighted arithmetic average of the annual percentage
changes in the HICP for France, Finland and Greece plus 1.5 percentage points. The reference value is 4.9%.
Table 5.4.1 Measures of inflation and related indicators
(annual percentage changes, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Measures of inflation           
 HICP 2.5 1.6 3.5 2.4 2.9 3.4 3.4 5.2 9.0 4.1
 HICP excluding unprocessed food and energy 2.9 2.5 3.3 2.1 2.3 3.7 3.7 4.5 8.4 4.0
 HICP at constant tax rates 3) 2.3 1.0 3.5 2.9 3.4 3.2 3.3 4.7 - -
 CPI 2.4 1.5 3.4 2.3 2.8 3.3 3.3 5.1 9.0 4.1
 Private consumption deflator 3.1 2.0 4.1 3.3 3.3 4.6 3.3 6.3 9.0 4.1
 GDP deflator 4.0 2.7 5.4 4.0 4.8 4.8 6.3 6.9 5.6 4.6
 Producer prices 4) 2.7 -0.8 6.3 4.6 6.2 3.9 0.8 16.9 - -
 Related indicators           
 Real GDP growth 2.7 2.1 3.3 4.3 5.4 4.6 -4.5 7.1 3.6 2.6
 GDP per capita in PPS 5) (euro area = 100) 65.4 63.6 67.8 64.5 66.9 68.6 71.0 . - -
 Comparative price levels (euro area = 100) 60.4 58.4 62.8 62.5 62.4 63.7 62.5 . - -
 Output gap 6) -0.1 -1.5 1.3 2.2 3.8 4.1 -3.7 -0.2 -0.5 -1.1
 Unemployment rate (%) 7) 5.9 7.9 3.8 4.0 3.6 3.3 4.1 4.1 3.8 4.0
 Unit labour costs, whole economy 3.2 2.1 4.4 4.6 3.3 3.4 6.6 4.0 6.7 4.5
 Compensation per employee, whole economy 4.1 1.7 6.5 7.0 6.4 6.9 3.0 9.2 8.7 6.5
 Labour productivity, whole economy 0.8 -0.4 2.0 2.3 3.0 3.4 -3.4 5.0 1.9 1.9
 Imports of goods and services deflator 1.9 0.1 3.8 1.8 3.5 1.2 2.4 10.3 9.6 -1.0
 Nominal effective exchange rate 8) -2.1 -2.2 -1.9 1.7 -1.2 -2.6 -5.9 -1.5 - -
 Money supply (M3) 9) 8.3 4.3 12.3 8.5 10.7 8.4 18.9 15.5 - -
 Lending from banks 10) 3.5 -3.6 11.2 6.4 11.0 15.1 11.4 12.3 - -
 Stock prices (BUX) 11) 198.8 88.5 58.5 23.0 -0.6 17.7 -8.6 20.5 - -
 Residential property prices 8.6 4.6 12.7 12.2 14.3 17.0 4.9 15.4 - -
Sources: European Commission (Eurostat, Directorate-General for Economic and Financial Affairs), national data for CPI, money supply, lending from banks
and ECB calculations based on Refinitiv data for stock prices.
1) Multi-annual averages calculated using the geometric mean, except for GDP per capita in PPS, comparative price levels, output gap and unemployment rate, for which the
arithmetic mean is used.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) The difference between the HICP and the HICP at constant tax rates shows the theoretical impact of changes in indirect taxes (e.g. VAT and excise duties) on the overall rate
of inflation. This impact assumes a full and instantaneous pass-through of tax rate changes to the price paid by the consumer.
4) Domestic sales, total industry excluding construction.
5) PPS stands for purchasing power standards.
6) Percentage difference from potential GDP: a positive (negative) sign indicates that actual GDP is above (below) potential GDP.
7) Definition conforms to International Labor Organization guidelines.
8) EER-42 group of trading partners. A positive (negative) sign indicates an appreciation (depreciation).
9) The series includes repurchase agreements with central counterparties.
10) Adjusted for the derecognition of loans from the MFI statistical balance sheet due to their sale or securitisation.
11) Multi-annual and annual figures represent the percentage change between the end of the given period and the end of the previous period.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 326 – 
Hungary - Fiscal developments
S 2 ECB Convergence Report, May 2022 
Chart 5.4.2 General government balance and debt
(as a percentage of GDP)
-11
-9
-7
-5
-3
-1
1
3
5
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
30
40
50
60
70
80
90
Government balance (left-hand scale)
Government debt (right-hand scale)
Reference values (government balance: -3%; government debt: 60%)
Sources: European System of Central Banks and European Commission (Eurostat).
Table 5.4.2 Government budgetary developments and projections
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Government balance -3.3 -2.3 -4.2 -2.5 -2.1 -2.1 -7.8 -6.8 -6.0 -4.9
 Total revenue 45.2 47.0 43.3 44.3 44.0 43.9 43.4 41.1 41.3 41.4
 Current revenue 43.2 44.6 41.8 43.3 42.7 42.1 41.8 39.2 39.9 40.0
 Direct taxes 6.7 6.8 6.5 7.1 6.6 6.6 6.7 5.6 6.8 6.7
 Indirect taxes 18.1 18.4 17.9 17.8 18.0 17.9 18.1 17.5 18.0 18.1
 Net social contributions 12.6 13.4 11.7 12.8 12.1 11.7 11.2 10.5 10.0 9.8
 Other current revenue 3) 5.8 5.9 5.8 5.5 6.0 5.8 5.9 5.6 5.2 5.3
 Capital revenue 2.0 2.4 1.5 1.0 1.3 1.8 1.6 1.9 1.4 1.4
 Total expenditure 48.4 49.3 47.6 46.7 46.1 46.0 51.2 47.9 47.3 46.4
 Current expenditure 40.8 42.6 39.0 40.0 38.5 37.8 40.1 38.4 37.9 37.1
 Compensation of employees 10.4 10.3 10.5 10.8 10.5 10.3 10.8 10.2 10.9 10.3
 Social benefits 14.2 15.7 12.7 13.6 12.8 12.1 12.5 12.3 12.3 12.0
 Interest payable 3.1 3.9 2.4 2.6 2.3 2.2 2.3 2.3 2.7 3.0
 Other current expenditure 4) 13.1 12.7 13.4 13.1 13.0 13.2 14.4 13.6 12.0 11.7
 Capital expenditure 7.6 6.6 8.6 6.7 7.6 8.2 11.1 9.6 9.4 9.3
  of which: Investment 5.2 4.6 5.7 4.5 5.8 6.2 6.4 5.8 5.4 5.9
 Cyclically adjusted balance -3.2 -1.6 -4.8 -3.5 -3.8 -4.0 -6.1 -6.7 -5.8 -4.4
 One-off and temporary measures 0.1 0.1 0.0 0.4 0.0 -0.2 0.1 -0.1 0.0 0.0
 Structural balance 5) -3.3 -1.7 -4.9 -3.8 -3.8 -3.8 -6.2 -6.6 -5.8 -4.4
 Government debt 74.5 76.5 72.6 72.1 69.1 65.5 79.6 76.8 76.4 76.1
 Average residual maturity (in years) 4.5 4.4 4.6 3.9 3.8 4.1 5.1 5.9 . .
 In foreign currencies (% of total) 31.1 39.3 22.9 26.2 23.2 20.5 22.0 22.6 . .
  of which: Euro 30.9 38.8 22.9 26.2 23.2 20.5 22.0 22.6 . .
 Domestic ownership (% of total) 56.4 47.4 65.5 62.7 63.7 66.1 66.7 68.3 . .
 Medium and long-term maturity (% of total) 6) 86.3 84.9 87.7 81.8 82.1 88.6 91.9 94.1 . .
  of which: Variable interest rate (% of total) 10.8 9.0 12.5 13.7 14.4 13.1 10.8 10.5 . .
 Deficit-debt adjustment 1.1 0.2 2.1 0.7 1.7 0.4 7.3 0.5 . .
 Net acquisitions of main financial assets 0.8 0.4 1.2 -0.1 0.9 0.0 5.7 -0.5 . .
 Currency and deposits 0.4 0.1 0.6 -0.5 1.0 -0.5 4.6 -1.7 . .
 Debt securities 0.0 0.0 0.0 0.0 0.0 -0.1 0.0 0.0 . .
 Loans 0.4 0.4 0.5 0.3 0.1 0.2 0.6 1.1 . .
 Equity and investment fund shares or units 0.1 -0.1 0.2 0.1 -0.1 0.4 0.5 0.1 . .
 Revaluation effects on debt 0.4 0.0 0.8 0.3 0.8 0.4 1.7 0.7 . .
  of which: Foreign exchange holding    
 gains/losses 0.3 0.0 0.6 -0.1 0.6 0.6 1.7 0.4 . .
 Other 7) -0.1 -0.2 0.1 0.5 -0.1 -0.1 -0.1 0.2 . .
 Convergence programme: government balance - - - - - - - - -4.9 -3.5
 Convergence programme: structural balance - - - - - - - - -3.6 -3.0
 Convergence programme: government debt - - - - - - - - 76.1 73.8
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast, except for convergence programme data.
3) Sales and other current revenue.
4) Intermediate consumption, subsidies payable and other current expenditure.
5) Cyclically adjusted balance excluding one-off and other temporary measures.
6) Original maturity of more than one year.
7) Time of recording differences and other factors (sector reclassifications and statistical discrepancies).
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 327 – 
Hungary - Exchange rate and external developments
S 3 ECB Convergence Report, May 2022 
Chart 5.4.3 Bilateral exchange rate and short-term
interest rate differential
Chart 5.4.4 Effective exchange rates 1) 
(EER-42 group of trading partners; monthly averages; index: Q1 1999 = 100)
(HUF/EUR exchange rate: monthly averages;
difference between three-month interbank interest rates
and three-month EURIBOR: basis points, monthly values)
390.0
364.0
338.0
312.0
286.0
260.0
2012 2014 2016 2018 2020
0.0
2.0
4.0
6.0
8.0
HUF/EUR exchange rate (left-hand scale)
Interest rate differential (right-hand scale)
65
71
77
83
89
95
2012 2014 2016 2018 2020
115
121
127
133
139
145
Nominal (left-hand scale)
Real (right-hand scale)
Sources: National data and ECB calculations. Source: ECB.
1) The real EER-42 is CPI-deflated. An increase (decrease) in the EER indicates
an appreciation (depreciation).
Table 5.4.3 External developments
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Balance of payments
Current account and capital account balance 3) 3.5 5.5 1.4 2.8 2.5 1.2 1.0 -0.4 -3.4 -0.8
Current account balance 1.1 2.6 -0.5 2.0 0.2 -0.7 -1.0 -2.9 -5.5 -3.5
 Goods 0.9 3.0 -1.2 1.3 -1.7 -2.5 -0.9 -2.5 . .
 Services 4.4 4.3 4.5 5.5 5.9 4.9 3.0 3.2 . .
 Primary income -3.4 -3.7 -3.1 -3.9 -3.6 -2.5 -2.5 -3.0 . .
 Secondary income -0.8 -1.0 -0.6 -0.9 -0.4 -0.5 -0.6 -0.7 . .
Capital account balance 2.4 2.9 1.9 0.8 2.3 1.9 2.0 2.5 . .
Combined direct and portfolio investment balance 3) -0.7 -0.4 -1.0 1.4 -2.3 0.8 -3.7 -1.1 . .
 Direct investment -1.7 -2.0 -1.4 -1.6 -2.2 -0.2 -1.9 -1.3 . .
 Portfolio investment 1.0 1.6 0.5 3.0 -0.1 1.1 -1.8 0.2 . .
Other investment balance 3.4 7.6 -0.9 0.8 1.2 -0.8 -2.1 -3.5 . .
 Reserve assets -0.1 -2.2 1.9 0.0 2.7 0.2 4.3 2.4 . .
Exports of goods and services 84.4 86.4 82.4 85.9 83.8 81.9 79.1 81.3 . .
Imports of goods and services 79.1 79.1 79.1 79.1 79.6 79.5 77.0 80.6 . .
Net international investment position 4) -62.8 -76.0 -49.6 -54.4 -50.7 -49.1 -48.9 -44.8 . .
Gross external debt 4) 131.1 139.5 122.7 101.5 100.4 98.4 155.5 158.0 . .
 Trade with the euro area 5)
Exports of goods and services 56.8 56.2 57.4 57.4 57.3 57.6 58.2 56.5 . .
 Imports of goods and services 57.2 57.6 56.8 58.8 57.6 56.7 55.5 55.6 . .
 Investment position with the euro area 5)
Direct investment assets 4) 29.8 32.6 26.9 19.7 30.1 24.5 30.6 29.6 . .
Direct investment liabilities 4) 53.5 59.2 47.8 64.5 49.8 36.2 46.1 42.4 . .
Portfolio investment assets 4) 62.6 65.6 59.6 60.3 60.6 59.4 58.6 59.0 . .
Portfolio investment liabilities 4) 42.4 44.2 40.7 38.2 38.3 37.6 43.5 45.7 . .
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) Differences between totals and the sum of their components are due to rounding.
4) End-of-period outstanding amounts.
5) As a percentage of the total.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 328 –
Hungary - Long-term interest rate developments
S 4 ECB Convergence Report, May 2022 
Chart 5.4.5 Long-term interest rate 1) 
(monthly averages in percentages)
Chart 5.4.6 Long-term interest rate and HICP inflation
differentials vis-à-vis the euro area
(monthly averages in percentage points)
0
2
4
6
8
10
2012 2014 2016 2018 2020
0
2
4
6
8
10
Long-term interest rate
Long-term interest rate (12-month moving average)
Reference value
-2
0
2
4
6
2012 2014 2016 2018 2020
-2
0
2
4
6
Long-term interest rate differential
HICP inflation differential
Sources: European System of Central Banks and ECB calculations.
1) The basis of the calculation of the reference value for the period from May
2021 to April 2022 is the unweighted arithmetic average of the interest rate
levels in France, Finland and Greece plus 2 percentage points. The reference
value is 2.6%.
Sources: European System of Central Banks, ECB calculations and European
Commission (Eurostat).
Table 5.4.4 Long-term interest rates and indicators of financial development and integration
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2018 2019 2020 2021 May. 2021 Memo item:
to euro area
Apr. 2022 2021
 Long-term interest rates
 Hungary 2) 3.9 5.0 2.8 3.1 2.5 2.2 3.1 4.1 -
 Euro area 3), 4) 1.4 2.2 0.6 1.1 0.4 0.1 0.1 0.4 -
Euro area AAA par curve, ten-year residual maturity 2), 4) 0.6 1.2 0.0 0.5 -0.2 -0.4 -0.3 -0.1 -
 Indicators of financial development and integration
Debt securities issued by financial corporations 5) 7.7 9.3 6.1 5.5 5.7 6.6 7.0 - 66.7
Debt securities issued by non-financial corporations 6) 2.2 1.8 2.7 1.4 1.6 3.2 5.9 - 13.4
Stock market capitalisation 7) 16.9 14.8 19.0 18.7 20.4 17.2 18.2 - 77.7
MFI credit to non-government residents 8) 40.6 44.0 37.1 34.4 35.7 40.5 40.9 - 111.1
Claims of euro area MFIs on resident MFIs 9) 6.1 8.5 3.7 3.7 4.3 3.4 3.6 - 29.5
Sources: European System of Central Banks and ECB calculations.
1) Multi-annual averages calculated using the arithmetic mean.
2) Average interest rate.
3) GDP-weighted average of the euro area long-term interest rates for the purpose of assessing convergence.
4) Included for information only.
5) Outstanding amount of debt securities issued by resident MFIs (excluding the national central bank) and other financial corporations.
6) Outstanding amount of debt securities issued by resident non-financial corporations.
7) Outstanding amount of listed shares issued by residents at market values.
8) MFI (excluding national central bank) credit to domestic non-MFI residents other than general government. Credit comprises outstanding amounts of loans and debt securities.
9) Outstanding amount of deposits and debt securities issued by domestic MFIs (excluding the national central bank) held by euro area MFIs as a percentage of total liabilities 
of domestic MFIs (excluding the national central bank). Total liabilities exclude capital and reserves and remaining liabilities.
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131 
5.5 Poland 
5.5.1 Price developments 
In April 2022 the 12-month average rate of HICP inflation in Poland was 7.0%, 
i.e. well above the reference value of 4.9% for the criterion on price stability 
(Chart 5.5.1). This rate is expected to increase gradually over the coming months, 
driven mainly by the higher commodity prices, broadening price pressures and further 
aggravation of supply bottlenecks resulting from the Russia-Ukraine war. 
Over the past ten years the 12-month average rate of HICP inflation has 
fluctuated within a relatively wide range, from -0.7% to 7.0%, while the average 
for that period was moderate, standing at 1.7%. In 2012 the Polish economy 
slowed on account of weak domestic demand and unfavourable external conditions. 
The weakening of domestic economic activity during the period 2012-13, together with 
the significant fall in global commodity prices, contributed to a sharp decline in inflation 
from 2013 to 2015. The average annual rate of HICP inflation stood at -0.7% in 2015, 
despite the stronger rate of real GDP growth from 2014 and the fact that Narodowy 
Bank Polski had cut its main policy rate to 1.5% in March 2015. From mid-2016 HICP 
inflation rose gradually on the back of relatively strong economic activity. Although real 
GDP growth moderated somewhat from mid-2018, it rose over the period 2017-19 at 
an annual average rate of close to 5%. From 2019 HICP inflation started to rise more 
markedly, to stand at 3% at the end of the year. This increase was driven largely by 
hikes in food and services prices. The outbreak of the coronavirus (COVID-19) 
pandemic in March 2020 resulted in a significant decline in real GDP growth in the 
second quarter of that year. Over 2020 as a whole, real GDP fell by 2.2%, which was 
less of a marked decline than in most EU Member States. The national authorities took 
major fiscal, macroprudential and monetary policy measures to offset the economic 
damage caused by the pandemic. In particular, Narodowy Bank Polski cut its main 
policy rate on several occasions from mid-March 2020, bringing it down to a historical 
low of 0.1% in May 2020. Inflation was more resilient, largely reflecting higher prices 
for food and services, and stood on average at 3.7% that year. In 2021 the economy 
rebounded strongly, with real GDP rising at an annual average rate of 5.9%. Against 
this background, inflation rose sharply in the same year, driven mainly by surging 
energy prices, particularly at the end of the year. To counteract the risk of inflation 
expectations becoming unanchored from the target, Narodowy Bank Polski raised its 
main policy rate to 1.75% during the fourth quarter of 2021. On average, HICP inflation 
stood at 5.2% in 2021 (Table 5.5.1). 
In the first four months of 2022 the average annual rate of HICP inflation stood 
at a high level of 9.6%. Continuing the marked upward trend it had initiated at the end 
of 2021, HICP inflation rose further at the beginning of 2022, owing largely to sharp 
increases in energy and food prices on the back of rising global commodity prices and 
supply bottlenecks that were exacerbated by Russia’s invasion of Ukraine in late 
February. The hikes in energy prices were nevertheless contained somewhat by the 
temporary fiscal measures taken by the authorities at the end of 2021 and start of 
2022. Rising services prices also contributed to the overall increase in consumer price 
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132 
inflation, in the context of a strong rebound in domestic economic activity from early 
2021 and robust wage growth as a result of unemployment rates remaining at 
historically low levels. Against this background, Narodowy Bank Polski raised its main 
policy rate further from the start of 2022, bringing it up to 5.25% in early May. 
Policy choices have played an important role in anchoring inflation 
expectations in Poland over the past decade, most notably the orientation of 
monetary policy towards price stability. Narodowy Bank Polski operates a floating 
exchange rate system and has had an inflation-targeting monetary policy framework in 
place since 1998. The medium-term CPI inflation target has been 2.5% 
(±1 percentage point) since 2004. Despite the developments in 2021, inflation 
expectations have generally remained well anchored, broadly supported by a number 
of reforms designed to strengthen financial stability, increase labour market flexibility 
and enhance product market competition. 
Inflation is projected to decline from mid-2023. However, the forecasts are 
subject to considerable uncertainty in the light of the Russia-Ukraine war. Over 
the longer term there are concerns about the sustainability of inflation 
convergence in Poland. According to the European Commission’s Spring 2022 
Economic Forecast, average annual HICP inflation is projected to increase from 5.2% 
in 2021 to 11.6% in 2022, before moderating to 7.3% in 2023. The risks to the inflation 
outlook are tilted to the upside, as domestic labour market shortages look set to 
continue in the short term, global supply bottlenecks could have a further impact on 
price developments in certain product segments, and, in particular, tensions in energy 
markets may continue to exacerbate inflationary pressures. Looking further ahead, the 
catching-up process is likely to result in positive inflation differentials vis-à-vis the euro 
area, given that GDP per capita and price levels are still lower in Poland than in the 
euro area, unless this is counteracted by an appreciation in the nominal exchange 
rate. In order to prevent the build-up of excessive price pressures and macroeconomic 
imbalances, the catching-up process must be supported by appropriate policies. 
Achieving an environment that is conducive to sustainable convergence in 
Poland requires stability-oriented economic policies and targeted structural 
reforms. Although the Polish economy managed to weather both the global financial 
crisis and the pandemic comparatively well, a number of structural issues still need to 
be addressed. It is still important that fiscal and structural policies continue to support 
external sustainability, enhance competitiveness and ensure investor confidence. In 
order to enhance potential growth and resource allocation, efforts are required to 
boost competition in product markets, and to speed up innovation and infrastructure 
modernisation. In the labour market, a number of structural weaknesses need to be 
dealt with, for example, by strengthening vocational education and reducing labour 
market mismatches, as well as by boosting the labour force participation rate. It is also 
essential that structural reforms are carried out to tackle disincentives to work. In the 
long term, there is a pressing need for Poland to reduce both its reliance on fossil fuel 
energy production and its greenhouse gas emissions. Otherwise, that dependency 
may continue to exert pressure on energy prices in the years to come. With regard to 
macroeconomic imbalances, the European Commission did not select Poland for an 
in-depth review in its Alert Mechanism Report 2022. 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 331 – 
Convergence Report, June 2022 133 
Financial sector policies should be aimed at safeguarding financial stability and 
ensuring that the financial sector makes a sound contribution to economic 
growth. The consequences of the pandemic have proved to be less severe for the 
economy and the banking sector than initially anticipated. In 2021 the burden of credit 
losses on banks’ balance sheets decreased markedly, and the concerns about a credit 
crunch that were being voiced at the beginning of the pandemic did not materialise, 
with lending to the non-financial sector having started to pick up again. Legal risks 
associated with the conversion of foreign exchange-denominated mortgage loans into 
domestic currency remain the main source of risk and uncertainty for the banking 
sector, especially given the recent increase in market volatility. In addition, the 
relatively high level of growth in house prices and the rebound in mortgage lending 
recorded in 2021 require close monitoring. In order to further strengthen the financial 
system, the national competent authority should continue to improve its supervisory 
practices, among other things, by following the applicable recommendations from the 
relevant international and European bodies, and by collaborating closely with other 
national supervisors of EU Member States within the supervisory colleges. 
5.5.2 Fiscal developments
Poland’s general government budget balance was well below the 3% deficit 
reference value in 2021, and its debt was below the 60% reference value. In the 
reference year 2021, the general government budget balance recorded a deficit of 
1.9% of GDP, i.e. well below the 3% reference value. The general government gross 
debt-to-GDP ratio was 53.8%, i.e. below the 60% reference value (Table 5.5.2). 
Compared with the previous year, the deficit declined by 5 percentage points of GDP 
and the debt ratio fell notably by 3.3 percentage points. With regard to other fiscal 
factors, the deficit ratio did not exceed the ratio of public investment to GDP in 2021. 
The budget deficits in 2020 and 2021 were substantially affected by the economic 
impact of the COVID-19 pandemic and the fiscal policy measures taken in response to 
it. 
Poland has been subject to the preventive arm of the Stability and Growth Pact 
since 2015. In May 2022, the European Commission found that while the 2021 
general government deficit was well below the reference value of 3% of GDP, Poland 
is planning a deficit above and not close to 3% of GDP in 2022. The planned excess 
over the reference value was considered to be exceptional but not temporary. Overall, 
the Commission’s analysis suggested that the deficit criterion had not been fulfilled. 
However, taking into account the exceptional uncertainty created by the continued 
extraordinary macroeconomic and fiscal impact of the COVID-19 pandemic, together 
with the invasion of Ukraine by Russia, the Commission did not propose opening new 
excessive deficit procedures at that stage. In the preceding year, in June 2021, the 
European Commission had found that the general government deficit in 2020 was 
above and not close to the reference value of 3% of GDP, while the debt-to-GDP ratio 
remained below the 60% threshold, but it had argued against taking a decision to 
place Member States under the excessive deficit procedure in light of the exceptional 
uncertainty. Previously, Poland had been in an excessive deficit procedure as of 2009, 
which was subsequently abrogated by the ECOFIN Council in June 2015, one year 
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earlier than the extended deadline, on account of a systemic pension reform. In the 
subsequent period to 2019, some deviations from the requirements of the preventive 
arm of the Stability and Growth Pact were observed, in particular vis-à-vis the 
recommended adjustment path towards the country’s medium-term objective. 
Both cyclical and non-cyclical factors relating to the COVID-19 pandemic 
contributed to the deterioration in the budget balance over the period 2019-21. 
Poland entered the pandemic with a low budget deficit of 0.7% of GDP in 2019, and 
this was also the case in the previous years (0.2% of GDP in 2018 and 1.5% of GDP in 
2017). This allowed for a forceful policy response in 2020, increasing the budget deficit 
by 6.2 percentage points. The deterioration in the fiscal position resulted in a structural 
deficit of 5.9% of GDP (from 2.3% in 2019), driven mostly by higher expenditure. 
Cyclical factors contributed to the increase in the deficit by 2.6 percentage points, 
reflecting the economic downturn. In 2021 fiscal support was gradually scaled down, 
as many of the initial measures were extended with greater targeting to assist those 
households and businesses that were most affected by the virus. As a result, the 
structural deficit fell to 1.8% of GDP, with revenues recovering by 1 percentage point 
and expenses falling by 4 percentage points, while the cyclical component improved 
by 0.9 percentage points from 2020 to 2021. 
Following a strong increase in 2020, the debt-to-GDP ratio declined in 2021, 
remaining below the 60% reference value. The debt-to-GDP ratio had been on a 
declining path prior to the pandemic, falling from 50.6% of GDP in 2017 to 45.6% of 
GDP in 2019 on account of primary balances and a favourable interest-growth 
differential. Driven by the pandemic-induced higher primary deficit and negative 
growth, as well as a large deficit-debt adjustment (5.5% of GDP), the debt ratio 
increased by 11.5 percentage points to 57.1% of GDP in 2020, above its historical 
average. The debt-to-GDP ratio declined by 3.3% of GDP in 2021 as the primary 
deficit moderated and economic activity rebounded. 
The structure of government debt makes Poland relatively sensitive to interest 
rate and exchange rate developments. In 2021, 20.1% of government debt was 
subject to variable interest rates (Table 5.5.2). Short-term debt stood at only 1.2% of 
total debt. Taking both factors into account, together with the level of the debt-to-GDP 
ratio, the budget balance is relatively sensitive to changes in interest rates. The share 
of foreign currency-denominated debt, most of which is denominated in euro, was 
relatively high at 22.7%, and the share of debt held domestically stood at 66.9%. 
Overall, and taking the debt-to-GDP ratio into account, the fiscal balance is relatively 
sensitive to exchange rate fluctuations. 
The European Commission’s Spring 2022 Economic Forecast foresees a 
notable deterioration in the budget balance and a notable improvement in the 
public debt ratio. According to the European Commission’s latest forecasts, the 
general government deficit is projected to notably deteriorate to 4% and 4.4% of GDP 
in 2022 and 2023 respectively, thus standing well above the 3% reference value. The 
deterioration in the budget balance reflects the cost of aid to people fleeing from 
Ukraine, higher interest expenses, temporary measures in response to high energy 
and food prices, and lower revenues from the income tax reform. Over the period 
2022-23, the structural deficit is projected to remain above the medium-term objective 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 333 – 
 
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135 
of 1% of GDP. Nevertheless, the Stability and Growth Pact’s general escape clause, 
which continues to be applied in 2022 and is also expected to remain in place in 2023, 
provides that “in periods of severe economic downturn for the euro area or the Union 
as a whole, Member States may be allowed temporarily to depart from the adjustment 
path towards the medium-term budgetary objective…, provided that this does not 
endanger fiscal sustainability in the medium term”. The public debt ratio is projected to 
decline over the projection horizon and remain below the 60% reference value, 
decreasing to 49.8% of GDP by 2023. The 2022 (2023) budget balance development 
presented in Poland’s 2022 convergence programme is slightly below (slightly above) 
the European Commission’s Spring 2022 Economic Forecast, while the projected debt 
ratio is above the European Commission’s figure. 
The Polish fiscal framework is strong overall, but its effectiveness should be 
improved. The constitutional debt rule provides a safeguard against exceeding the 
60% reference value. The medium-term budgetary planning is based on the 
Multiannual State Financial Plan, and furthermore a permanent expenditure rule 
limiting spending growth depending on pre-specified debt thresholds has also been in 
place since 2015. However, recently several new expenditure items have been 
channelled through extra-budgetary funds which do not fall under this rule. Currently, 
Poland is the only EU country that does not have an independent fiscal council. In line 
with the provisions of the fiscal compact, independent institutions responsible for 
monitoring compliance with EU fiscal rules should be set up before joining the euro 
area. 
Poland faces medium risks to fiscal sustainability in the medium and long run, 
as the adequacy of the pension system needs to be ensured. While the 2021 
Fiscal Sustainability Report concluded that risks to fiscal sustainability over the 
medium term were low, the updated assessment that was published as part of the 
European Commission’s country report for Poland on 23 May 2022 points to medium 
risks. Long-term risks were revised upwards compared with the Debt Sustainability 
Monitor 2019, i.e. from low to medium due to the budgetary pressures stemming from 
a projected notable increase in age-related costs and the unfavourable initial 
budgetary position. The 2021 Ageing Report prepared by the Ageing Working Group 
of the EU’s Economic Policy Committee193 shows a 4 percentage point rise in 
age-related expenditure by 2070 under the reference scenario, from 20.1% of GDP in 
2019. The expected increase is driven by healthcare and long-term care spending, 
while pension spending is projected to remain stable. However, amid a marked 
increase in population ageing and the old age dependency ratio, only a substantial 
decline in the benefit ratio can stabilise the pension bill.194 This poses risks of old age 
poverty and could trigger additional social payments to support the elderly, thereby 
weighing on long-term fiscal sustainability. 
 
193  European Commission and Economic Policy Committee, “The 2021 Ageing Report: Economic &amp; 
Budgetary Projections for the EU Member States (2019-2070)”, European Economy Institutional Paper, 
No 148, European Commission, 2021. 
194  The benefit ratio is defined as average pensions in relation to average wages. The old age dependency 
ratio is defined as the ratio between the number of persons aged 65 and over (age when they are 
generally economically inactive) and the number of persons aged between 15 and 64. 
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Looking ahead, fiscal policy should rebuild buffers and advance structural 
reforms to safeguard the long-term sustainability of public finances. While fiscal 
policy should remain agile in its response to the evolving pandemic situation and the 
geopolitical situation, a consistent and prudent fiscal policy will ensure that Poland 
continues to comply with the Stability and Growth Pact and maintains buffers to 
alleviate adverse shocks. Moreover, the Next Generation EU programme needs to be 
implemented effectively in order to support the recovery and to adjust to the structural 
changes that are under way. The role and independence of national institutions 
monitoring compliance with the EU fiscal rules should be strengthened. Efforts to 
simplify labour taxation, reduce the tax wedge, and enhance progressivity and social 
benefits schemes should continue, but their budgetary implications need to be 
carefully assessed. Preserving the long-term sustainability of public finances, while 
also ensuring adequate pension payments and services in the health and long-term 
care sectors, remains a priority. 
5.5.3 Exchange rate developments 
In the two-year reference period from 26 May 2020 to 25 May 2022, the Polish 
zloty did not participate in ERM II, but traded under a flexible exchange rate 
regime. Over the reference period the Polish zloty mostly traded close to its May 2020 
average exchange rate against the euro of 4.5251 zlotys per euro, which is used as a 
benchmark for illustrative purposes in the absence of an ERM II central rate (Chart 
5.5.3). The maximum upward deviation from this benchmark was 3.1%, while the 
maximum downward deviation amounted to 9.4%. On 25 May 2022 the exchange rate 
stood at 4.6210 zlotys per euro, i.e. 2.1% weaker than its average level in May 2020. 
At the end of March 2022 Narodowy Bank Polski entered a swap line arrangement 
with the ECB under which it could borrow up to €10 billion against zlotys in order to 
address potential euro liquidity needs in the Polish financial system. As this 
arrangement helped to reduce the potential risk of financial vulnerabilities, it may also 
have had an impact on exchange rate developments over the end of the reference 
period. Over the past ten years the exchange rate of the Polish zloty against the euro 
has depreciated by 7.6%. 
The exchange rate of the Polish zloty against the euro exhibited, on average, a 
relatively high degree of volatility over the reference period. Overall, exchange 
rate volatility tended to increase somewhat from the end of 2021, likely reflecting 
significant changes in the country’s main policy rates during the last quarter of the 
year. Following a pronounced depreciation in mid-March 2020 in the wake of the initial 
economic impact of the pandemic, the exchange rate of the Polish zloty mostly 
fluctuated in a range of between 4.4 zlotys and 4.6 zlotys per euro over the reference 
period. However, the outbreak of the war in Ukraine at the end of February 2022 
resulted in increased volatility in foreign exchange markets. From mid-2020 to the third 
quarter of 2021 short-term interest rate differentials against the three-month 
EURIBOR remained largely stable and modest, at around 0.8 percentage points, on 
account of the substantial cuts in the policy rates by Narodowy Bank Polski after the 
outbreak of the pandemic. Since the fourth quarter of 2021 decisive increases in the 
policy rates in Poland have resulted in a sizeable increase in short-term interest rate 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 335 – 
Convergence Report, June 2022 137 
differentials against the three-month EURIBOR to 4.0 percentage points in the 
three-month period ending in March 2022. 
The real effective exchange rate of the Polish zloty has depreciated somewhat 
over the past ten years (Chart 5.5.4). The real effective exchange rate weakened 
until 2016, when it began to appreciate. This appreciation continued until 2018 and 
since then it has remained broadly stable. Looking forward, this indicator should be 
interpreted with caution, as Poland is subject to a process of economic convergence, 
which complicates any long-term assessment of real exchange rate developments. 
Poland’s combined current and capital account balance has improved over the 
past ten years, while the country’s net foreign liabilities remain high, although 
they have been declining since 2017 and consist mostly of net direct 
investment liabilities (Table 5.5.3). After standing virtually in balance on average 
over the period 2012-16, the current and capital account subsequently recorded an 
increasing surplus. It reached a relatively large surplus in 2020 of slightly above 5% of 
GDP, which moderated in 2021 to 1.0% of GDP largely due to a reduction in the goods 
trade balance. On the financing side, Poland has received net inflows in combined 
direct and portfolio investment over the past ten years, however, these inflows tended 
to diminish somewhat over the period 2018-20 while increasing again in 2021. Gross 
external debt increased up to 2016 and declined in 2017-21, reaching 56.6% of GDP 
in 2021. Over this period Poland’s net international investment position deteriorated
up to 2017, reaching -61.2% of GDP in that year, but subsequently it improved notably 
and reached -40.2% of GDP in 2021. However, the country’s net foreign liabilities
remain high. Fiscal and structural policies continue to be important for supporting 
external sustainability and maintaining Poland’s attractiveness as a target for foreign 
direct investment, to enhance the competitiveness of the economy. 
The Polish economy is well integrated with the euro area through trade and 
investment linkages. In 2021 exports of goods and services to the euro area 
constituted 58.4% of total exports, while the corresponding figure for imports was 
slightly lower at 56.9%. In the same year the share of the euro area in Poland’s stock
of inward direct investment stood at 77.3%, and its share in the country’s stock of
portfolio investment liabilities was 45.5%. The share of Poland’s stock of foreign
assets invested in the euro area amounted to 57.3% in the case of direct investment 
and 45.4% for portfolio investment in 2021. 
5.5.4 Long-term interest rate developments 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in Poland stood at 3.0% on average and were thus above the reference value of 
2.6% for the interest rate convergence criterion (Chart 5.5.5). 
Overall, long-term interest rates in Poland have declined since 2012, when they 
averaged around 5% (Chart 5.5.5). Over the period 2012-14 the Polish Government 
was able to gradually tighten its fiscal stance amid the impact of the global and euro 
area financial crises pushing up the risk premia incorporated in the long-term interest 
rates on sovereign bonds. After bottoming out at around 2% at the end of 2014, 
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138 
long-term interest rates in Poland increased for two years on the back of strong 
economic activity and gradually increasing price dynamics, which resulted in inflation 
turning positive by the end of 2016 after a period of declining prices. During the period 
2017-18 long-term interest rates declined only very gradually as, after peaking at 
levels slightly below 4% at the start of 2017, the upward pressure exerted by buoyant 
economic activity offset the dampening effect of lower inflation, thus bringing the 
long-term interest rate at the end of 2018 to around 3%. In 2019 long-term interest 
rates were mostly influenced by global trends and declined until the beginning of 2020, 
although domestic growth remained quite robust and inflation was increasing. In the 
second quarter of 2020 long-term interest rates declined to their historical lows at 
slightly above 1%, also because the reference monetary policy rate was swiftly cut 
from 1.5% to 0.1% in response to the outbreak of the COVID-19 pandemic. In addition, 
Narodowy Bank Polski launched purchases of government and 
government-guaranteed securities on the secondary market as part of structural open 
market operations. It also offered bill discount credit aimed at refinancing loans 
granted to enterprises by banks and lowered the reserve requirements to prevent the 
pandemic having a negative impact on credit supply. Since 2021 long-term interest 
rates have been gradually increasing owing to the economic recovery and the rise in 
inflation, which also contributed to bringing forward expectations of tighter monetary 
policy. Since October 2021 Narodowy Bank Polski has responded to higher than 
expected inflation outcomes and, more recently, the higher upside risks arising from 
the possible consequences of the Russian invasion of Ukraine by raising policy rates, 
including the reference interest rate, which stood at 5.25% (from 0.1% in September 
2021) at the end of the review period. As a result, long-term interest rates also 
increased significantly, reaching 6.0%. During the review period credit default swap 
spreads remained well below 100 basis points, which is low by historical standards 
and one of the lowest among the group of peer countries in the region, suggesting a 
benign market perception of sovereign credit risk. Currently, Poland’s government 
debt is rated high quality investment grade by all three main rating agencies. 
Poland’s long-term interest rate differential vis-à-vis the euro area has 
increased recently, reaching 4.6% (Chart 5.5.6). Over the period 2012-13 the faster 
decline in Poland’s long-term interest rates compared with the euro area took the 
differential vis-à-vis the euro area to its lowest level of around 1%. The differential then 
gradually increased again, as a result of the higher dynamism of the Polish economy 
and the associated higher inflation rate, before stabilising at around 200 basis points 
over the period 2016-19. Owing to the clear acceleration in inflation since the summer 
of 2021, the differential reached its historical peak of 4.6% at the end of the review 
period – up from 1.1% in April 2020. At the end of the review period the interest rate 
differential vis-à-vis the euro area AAA yield stood at 5.0%. 
Capital markets in Poland are smaller and much less developed than in the euro 
area (Table 5.5.4). The market for both financial and non-financial corporate debt was 
still much smaller than the respective markets in the euro area at the end of 2021. 
Debt securities issued by financial and non-financial corporations stood at 12.3% and 
2.1% of GDP respectively. In 2021 stock market capitalisation was around 27% of 
GDP, slightly lower than the annual average over the period 2012-21 but still one of 
the highest levels among peer countries. Euro area banks’ provision of funds to the 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 337 – 
Convergence Report, June 2022 139 
Polish banking system is quite limited. The claims of euro area MFIs on Polish banks 
accounted for 3.5% of Polish banks’ liabilities at the end of 2021. The degree of 
financial intermediation in Poland is in line with that of peer countries in the region and, 
as measured by the credit extended by MFIs to the private sector, amounted to slightly 
less than 52% of GDP in 2021 (compared with around 111% in the euro area). Foreign 
ownership of banks in Poland, while remaining elevated, has declined markedly in 
recent years on the back of government initiatives. At the end of 2020 the share of 
foreign banks in total Polish banking sector assets stood at around 44%. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 338 –
Poland - Price developments
S 1 ECB Convergence Report, May 2022 
Chart 5.5.1 HICP inflation and reference value 1) 
(annual percentage changes)
-2
0
2
4
6
8
10
12
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
-2
0
2
4
6
8
10
12
HICP
HICP (12-month moving average)
Reference value
Sources: European Commission (Eurostat) and ECB calculations.
1) The basis of the calculation of the reference value for the period from May 2021 to April 2022 is the unweighted arithmetic average of the annual percentage
changes in the HICP for France, Finland and Greece plus 1.5 percentage points. The reference value is 4.9%.
Table 5.5.1 Measures of inflation and related indicators
(annual percentage changes, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Measures of inflation
 HICP 1.7 0.7 2.8 1.6 1.2 2.1 3.7 5.2 11.6 7.3
HICP excluding unprocessed food and energy 1.7 1.0 2.5 1.2 0.6 2.3 4.2 4.2 8.3 4.9
HICP at constant tax rates 3) 1.6 0.5 2.7 1.6 1.2 2.1 3.5 5.1 - -
 CPI 0.1 -0.9 1.1 2.0 1.7 2.3 3.4 5.1 . .
Private consumption deflator 1.7 0.4 3.0 2.0 1.7 2.4 3.4 5.4 11.8 7.3
 GDP deflator 2.1 0.9 3.2 1.9 1.2 3.2 4.2 5.8 10.0 7.8
 Producer prices 4) 1.6 -0.3 3.6 4.8 2.8 1.6 -0.9 9.8 - -
 Related indicators
Real GDP growth 3.2 2.6 3.7 4.8 5.4 4.7 -2.2 5.9 3.7 3.0
GDP per capita in PPS 5) (euro area = 100) 65.4 63.2 68.1 65.0 66.3 68.4 72.6 . - -
Comparative price levels (euro area = 100) 55.3 54.4 56.4 55.7 56.4 56.9 56.4 . - -
 Output gap 6) -0.2 -1.1 0.7 0.9 2.5 3.2 -2.5 -0.6 -0.5 -0.9
Unemployment rate (%) 7) 6.3 8.8 3.7 5.0 3.9 3.3 3.2 3.4 4.1 3.9
Unit labour costs, whole economy 2.1 1.0 3.2 2.3 3.2 2.4 7.9 0.6 6.0 5.1
Compensation per employee, whole economy 4.6 2.9 6.4 5.8 8.1 7.3 5.6 5.0 9.5 8.0
Labour productivity, whole economy 2.4 1.8 3.0 3.4 4.8 4.8 -2.1 4.4 3.3 2.7
Imports of goods and services deflator 1.7 0.1 3.3 1.4 2.7 1.8 0.1 10.7 14.4 5.1
Nominal effective exchange rate 8) -0.5 -1.0 0.0 3.5 1.9 -1.4 -1.7 -2.4 - -
Money supply (M3) 9) 8.4 7.5 9.4 5.9 8.7 8.7 15.3 8.5 - -
Lending from banks 10) 5.1 5.5 4.8 7.4 6.3 5.8 -1.2 5.7 - -
Stock prices (Warsaw General Index) 11) 84.3 37.7 33.9 23.2 -9.5 0.2 -1.4 21.5 - -
Residential property prices 3.4 -0.7 7.7 3.9 6.6 8.7 10.5 9.2 - -
Sources: European Commission (Eurostat, Directorate-General for Economic and Financial Affairs), national data for CPI, money supply, lending from banks
and ECB calculations based on Refinitiv data for stock prices.
1) Multi-annual averages calculated using the geometric mean, except for GDP per capita in PPS, comparative price levels, output gap and unemployment rate, for which the
arithmetic mean is used.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) The difference between the HICP and the HICP at constant tax rates shows the theoretical impact of changes in indirect taxes (e.g. VAT and excise duties) on the overall rate
of inflation. This impact assumes a full and instantaneous pass-through of tax rate changes to the price paid by the consumer.
4) Domestic sales, total industry excluding construction.
5) PPS stands for purchasing power standards.
6) Percentage difference from potential GDP: a positive (negative) sign indicates that actual GDP is above (below) potential GDP.
7) Definition conforms to International Labor Organization guidelines.
8) EER-42 group of trading partners. A positive (negative) sign indicates an appreciation (depreciation).
9) The series includes repurchase agreements with central counterparties.
10) Adjusted for the derecognition of loans from the MFI statistical balance sheet due to their sale or securitisation.
11) Multi-annual and annual figures represent the percentage change between the end of the given period and the end of the previous period.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 339 – 
Poland - Fiscal developments
S 2 ECB Convergence Report, May 2022 
Chart 5.5.2 General government balance and debt
(as a percentage of GDP)
-11
-9
-7
-5
-3
-1
1
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
10
20
30
40
50
60
70
80
Government balance (left-hand scale)
Government debt (right-hand scale)
Reference values (government balance: -3%; government debt: 60%)
Sources: European System of Central Banks and European Commission (Eurostat).
Table 5.5.2 Government budgetary developments and projections
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Government balance -2.8 -3.3 -2.3 -1.5 -0.2 -0.7 -6.9 -1.9 -4.0 -4.4
 Total revenue 40.1 39.0 41.1 39.8 41.3 41.0 41.3 42.3 39.9 38.6
 Current revenue 39.0 38.0 40.1 39.0 40.1 39.9 40.1 41.4 39.1 37.7
 Direct taxes 7.4 6.9 7.9 7.3 7.8 7.9 7.9 8.4 7.3 6.1
 Indirect taxes 13.6 13.0 14.2 13.8 14.0 13.8 13.9 15.2 14.7 15.0
Net social contributions 13.8 13.4 14.1 13.9 14.1 14.2 14.5 14.0 13.6 13.2
Other current revenue 3) 4.3 4.6 4.0 4.1 4.2 4.0 3.8 3.8 3.6 3.4
 Capital revenue 1.0 1.0 1.0 0.8 1.2 1.1 1.2 1.0 0.8 0.9
 Total expenditure 42.9 42.3 43.4 41.3 41.5 41.8 48.2 44.2 43.9 43.0
 Current expenditure 37.9 37.5 38.3 36.6 36.4 37.1 42.5 39.0 38.2 37.6
Compensation of employees 10.5 10.5 10.4 10.2 10.1 10.3 10.9 10.5 10.2 10.0
 Social benefits 17.0 16.4 17.5 17.0 16.7 17.2 18.6 17.9 17.5 17.1
 Interest payable 1.7 2.1 1.4 1.6 1.4 1.4 1.3 1.1 1.5 1.8
Other current expenditure 4) 8.8 8.5 9.1 7.9 8.2 8.2 11.7 9.4 9.1 8.8
 Capital expenditure 4.9 4.8 5.1 4.6 5.1 4.7 5.7 5.2 5.7 5.4
 of which: Investment 4.3 4.3 4.3 3.8 4.7 4.3 4.5 4.1 4.2 3.9
Cyclically adjusted balance -2.7 -2.8 -2.6 -1.9 -1.5 -2.3 -5.7 -1.6 -3.7 -4.0
One-off and temporary measures 0.0 0.0 0.1 0.0 0.0 0.0 0.3 0.2 0.3 0.0
 Structural balance 5) -2.7 -2.7 -2.7 -1.9 -1.5 -2.3 -5.9 -1.8 -4.0 -4.0
 Government debt 52.3 53.5 51.2 50.6 48.8 45.6 57.1 53.8 50.8 49.8
Average residual maturity (in years) 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 . .
In foreign currencies (% of total) 30.4 33.3 27.4 31.7 30.9 28.4 23.4 22.7 . .
 of which: Euro 23.7 24.5 22.9 25.6 25.1 23.8 20.0 19.9 . .
Domestic ownership (% of total) 51.2 45.2 57.2 47.6 49.9 55.9 65.5 66.9 . .
Medium and long-term maturity (% of total) 6) 99.1 99.4 98.8 99.2 99.0 98.9 98.2 98.8 . .
  of which: Variable interest rate (% of total) 20.0 18.7 21.3 21.3 21.8 23.9 19.2 20.1 . .
 Deficit-debt adjustment -0.2 -1.6 1.1 -1.6 1.1 -0.3 5.5 1.0 . .
Net acquisitions of main financial assets 0.8 -0.1 1.8 0.0 1.1 0.8 5.4 1.5 . .
Currency and deposits 0.6 0.1 1.1 -0.1 0.8 0.4 3.2 1.1 . .
 Debt securities 0.2 0.0 0.3 0.2 0.0 0.3 0.5 0.4 . .
 Loans 0.3 0.1 0.5 0.1 0.4 0.1 1.6 0.1 . .
Equity and investment fund shares or units -0.2 -0.3 -0.1 -0.2 0.0 0.0 0.1 -0.1 . .
Revaluation effects on debt 0.1 0.2 0.0 -1.2 0.6 -0.1 0.7 0.0 . .
 of which: Foreign exchange holding
 gains/losses 0.1 0.1 0.0 -1.4 0.6 -0.1 1.0 0.1 . .
 Other 7) -1.2 -1.7 -0.6 -0.4 -0.6 -0.9 -0.5 -0.6 . .
 Convergence programme: government balance - - - - - - - - -4.3 -3.7
 Convergence programme: structural balance - - - - - - - - -4.2 -3.7
 Convergence programme: government debt - - - - - - - - 52.1 51.5
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast, except for convergence programme data.
3) Sales and other current revenue.
4) Intermediate consumption, subsidies payable and other current expenditure.
5) Cyclically adjusted balance excluding one-off and other temporary measures.
6) Original maturity of more than one year.
7) Time of recording differences and other factors (sector reclassifications and statistical discrepancies).
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 340 – 
Poland - Exchange rate and external developments
S 3 ECB Convergence Report, May 2022 
Chart 5.5.3 Bilateral exchange rate and short-term
interest rate differential
Chart 5.5.4 Effective exchange rates 1) 
(EER-42 group of trading partners; monthly averages; index: Q1 1999 = 100)
(PLN/EUR exchange rate: monthly averages;
difference between three-month interbank interest rates
and three-month EURIBOR: basis points, monthly values)
4.8
4.6
4.4
4.2
4.0
3.8
2012 2014 2016 2018 2020
0.0
1.0
2.0
3.0
4.0
5.0
PLN/EUR exchange rate (left-hand scale)
Interest rate differential (right-hand scale)
95
99
103
107
111
115
2012 2014 2016 2018 2020
105
108
111
114
117
120
Nominal (left-hand scale)
Real (right-hand scale)
Sources: National data and ECB calculations. Source: ECB.
1) The real EER-42 is CPI-deflated. An increase (decrease) in the EER indicates
an appreciation (depreciation).
Table 5.5.3 External developments
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Balance of payments
Current account and capital account balance 3) 1.1 0.0 2.1 0.9 0.8 2.4 5.2 1.0 1.0 1.3
Current account balance -0.9 -2.0 0.2 -0.4 -1.3 0.5 2.9 -0.6 -0.5 -0.2
 Goods -0.3 -0.8 0.2 -0.1 -1.2 0.3 2.4 -0.1 . .
 Services 3.3 2.3 4.3 3.8 4.3 4.5 4.3 4.6 . .
 Primary income -3.7 -3.4 -4.0 -4.1 -4.0 -4.0 -3.5 -4.4 . .
 Secondary income -0.2 -0.2 -0.3 0.0 -0.3 -0.3 -0.3 -0.7 . .
Capital account balance 2.0 2.1 1.8 1.3 2.1 2.0 2.3 1.6 . .
Combined direct and portfolio investment balance 3) -1.8 -2.2 -1.4 -2.3 -1.8 0.0 -0.9 -2.0 . .
 Direct investment -1.9 -1.5 -2.3 -1.4 -2.6 -1.9 -2.1 -3.6 . .
 Portfolio investment 0.1 -0.7 1.0 -0.9 0.8 2.0 1.2 1.7 . .
Other investment balance 0.6 0.0 1.2 3.6 1.0 -0.5 1.9 -0.1 . .
 Reserve assets 1.5 1.5 1.5 -1.5 1.3 1.7 3.1 2.8 . .
Exports of goods and services 52.0 47.7 56.3 54.1 55.2 55.4 55.9 60.7 . .
Imports of goods and services 48.9 46.1 51.7 50.4 52.2 50.6 49.2 56.2 . .
Net international investment position 4) -57.9 -65.6 -50.2 -61.2 -55.9 -49.8 -44.3 -39.9 . .
Gross external debt 4) 66.8 72.4 61.3 67.0 64.2 58.8 60.3 56.2 . .
 Trade with the euro area 5)
Exports of goods and services 56.1 55.1 57.0 56.1 56.7 56.5 57.4 58.4 . .
 Imports of goods and services 57.8 57.8 57.7 58.7 57.7 57.1 58.2 56.9 . .
 Investment position with the euro area 5)
Direct investment assets 4) 61.0 63.9 58.0 55.6 60.1 58.7 58.4 57.3 . .
Direct investment liabilities 4) 78.0 77.5 78.4 78.4 79.0 78.8 78.7 77.3 . .
Portfolio investment assets 4) 47.0 54.4 39.5 42.8 33.7 34.3 41.4 45.4 . .
Portfolio investment liabilities 4) 45.8 45.4 46.1 42.1 44.2 47.5 51.2 45.5 . .
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) Differences between totals and the sum of their components are due to rounding.
4) End-of-period outstanding amounts.
5) As a percentage of the total.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 341 – 
Poland - Long-term interest rate developments
S 4 ECB Convergence Report, May 2022 
Chart 5.5.5 Long-term interest rate 1) 
(monthly averages in percentages)
Chart 5.5.6 Long-term interest rate and HICP inflation
differentials vis-à-vis the euro area
(monthly averages in percentage points)
0
1
2
3
4
5
6
7
2012 2014 2016 2018 2020
0
1
2
3
4
5
6
7
Long-term interest rate
Long-term interest rate (12-month moving average)
Reference value
-2
-1
0
1
2
3
4
5
2012 2014 2016 2018 2020
-2
-1
0
1
2
3
4
5
Long-term interest rate differential
HICP inflation differential
Sources: European System of Central Banks and ECB calculations.
1) The basis of the calculation of the reference value for the period from May
2021 to April 2022 is the unweighted arithmetic average of the interest rate
levels in France, Finland and Greece plus 2 percentage points. The reference
value is 2.6%.
Sources: European System of Central Banks, ECB calculations and European
Commission (Eurostat).
Table 5.5.4 Long-term interest rates and indicators of financial development and integration
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2018 2019 2020 2021 May. 2021 Memo item:
to euro area
Apr. 2022 2021
 Long-term interest rates
 Poland 2) 3.1 3.7 2.5 3.2 2.3 1.5 1.9 3.0 -
 Euro area 3), 4) 1.4 2.2 0.6 1.1 0.4 0.1 0.1 0.4 -
Euro area AAA par curve, ten-year residual maturity 2), 4) 0.6 1.2 0.0 0.5 -0.2 -0.4 -0.3 -0.1 -
 Indicators of financial development and integration
Debt securities issued by financial corporations 5) 5.8 3.7 7.9 5.1 5.0 12.0 12.3 - 66.7
Debt securities issued by non-financial corporations 6) 4.3 4.8 3.7 4.9 3.3 3.0 2.1 - 13.4
Stock market capitalisation 7) 29.2 31.5 26.9 27.5 24.4 24.2 26.7 - 77.7
MFI credit to non-government residents 8) 54.9 55.2 54.6 56.1 54.4 55.0 51.8 - 111.1
Claims of euro area MFIs on resident MFIs 9) 5.2 6.6 3.8 4.1 3.6 3.6 3.5 - 29.5
Sources: European System of Central Banks and ECB calculations.
1) Multi-annual averages calculated using the arithmetic mean.
2) Average interest rate.
3) GDP-weighted average of the euro area long-term interest rates for the purpose of assessing convergence.
4) Included for information only.
5) Outstanding amount of debt securities issued by resident MFIs (excluding the national central bank) and other financial corporations.
6) Outstanding amount of debt securities issued by resident non-financial corporations.
7) Outstanding amount of listed shares issued by residents at market values.
8) MFI (excluding national central bank) credit to domestic non-MFI residents other than general government. Credit comprises outstanding amounts of loans and debt securities.
9) Outstanding amount of deposits and debt securities issued by domestic MFIs (excluding the national central bank) held by euro area MFIs as a percentage of total liabilities 
of domestic MFIs (excluding the national central bank). Total liabilities exclude capital and reserves and remaining liabilities.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 342 – 
 
Convergence Report, June 2022 
 
144 
5.6 Romania 
5.6.1 Price developments 
In April 2022 the 12-month average rate of HICP inflation in Romania was 6.4%, 
i.e. well above the reference value of 4.9% for the criterion on price stability 
(Chart 5.6.1). This rate is expected to increase gradually over the coming months, 
driven mainly by the higher commodity prices, broadening price pressures and further 
aggravation of supply bottlenecks resulting from the Russia-Ukraine war. 
Over the past ten years the 12-month average rate of HICP inflation has 
fluctuated within a relatively wide range, from -1.7% to 6.4%, and the average 
for that period was moderate, standing at 2.2%. Over the years up to 2015, 
inflation was driven by rising compensation per employee. It then declined to 
historically low levels on account of a series of tax cuts, in particular the reduction in 
the value added tax rate on food items, non-alcoholic beverages and food services, 
which took it into negative territory in June 2015. Further tax cuts and a reduction in 
excise duties meant that HICP inflation remained negative throughout 2016, before 
turning positive again at the beginning of 2017, partly owing to favourable base 
effects. In 2018 inflation continued its accelerating trend on the back of strong fiscal 
stimulus and increases in minimum wages, and averaged 4.1% over the year. In 
response to that acceleration in inflation, Banca Naţională a României raised its 
monetary policy rate by 25 basis points three times over the months from January to 
May 2018, up from 1.75% to 2.5%. HICP inflation then fell slightly to 3.9% in 2019, but 
remained elevated as a result of developments in prices for food, tobacco and fuel, as 
well as strong wage growth. It continued its downward trend into 2020, also reflecting 
the coronavirus (COVID-19) pandemic, which dampened economic activity. Having 
expanded by 4.2% in 2019, real GDP contracted by 3.7% in 2020. To support the 
economy, in March 2020 Banca Naţională a României cut its monetary policy rate by 
50 basis points to 2% and narrowed the interest rate corridor to a width of 1 
percentage point. This was the start of a series of reductions in the monetary policy 
rate up to January 2021, bringing it down to 1.25% to support the nascent economic 
recovery. Government support measures mitigated the economic effects of the 
pandemic, preventing a sharp increase in unemployment and sustaining both 
household income and business activity. Inflation rose above the upper limit of the 
target interval, reaching an average level of 4.1% in 2021 (Table 5.6.1). Supply-side 
shocks, particularly in relation to prices for electricity, natural gas and fuel, were the 
main contributing factor to the considerable rise in inflation, especially during the 
second half of the year, followed by prices for processed and unprocessed food. With 
inflationary pressures mounting in the second half of 2021, Banca Naţională a 
României initiated a monetary policy tightening cycle by first ending government bond 
purchases in May and then introducing strict market liquidity controls and intervening 
in the money market through deposit-taking operations. Thereafter, it raised its 
monetary policy rate by 25 basis points in both October and November 2021, bringing 
it up to 1.75%. The monetary policy decision in November was complemented by a 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 343 – 
Convergence Report, June 2022 145 
widening of the symmetric corridor of interest rates around on standing facilities 
around the policy rate to ±0.75 percentage points. 
In the first four months of 2022 the average annual rate of HICP inflation stood 
at 9.1%. The continued increase in the rate of inflation over those months reflected 
mainly external supply-side shocks. Energy prices were the major inflationary factor, 
but were partly contained by the mitigating impact of temporary government measures 
adopted in November 2021. In April 2022 the government introduced a revised cap on 
natural gas and electricity prices for households and firms, which is expected to 
remain in place for a year. Prices for fuel and food, both locally produced and 
imported, strengthened their upward momentum as a result of surging crude oil prices, 
higher energy costs feeding into production, higher prices for international 
commodities owing to bad weather events and disruptions to global trade and value 
chains. Inflationary pressures were also exacerbated by developments in international 
energy and commodities markets linked to Russia’s invasion of Ukraine in late 
February. Given the increasing risks to medium-term inflation expectations triggered 
by supply-side shocks and in the context of declining labour market slack, Banca 
Naţională a României raised its key monetary policy rate further in January, February, 
April and May 2022, by a total of 200 basis points, bringing it up to 3.75%. In addition, 
the interest rate corridor was widened to ±1 percentage point. 
The orientation of monetary policy towards price stability has played an 
important role in shaping inflation dynamics in Romania over the past decade. 
In 2005 Banca Naţională a României shifted to an inflation-targeting framework 
combined with a managed floating exchange rate regime. The annual CPI inflation 
target was initially set at 7.5% and from 2013 was reduced gradually to 2.5%, with a 
1 percentage point variation band around the central target. 
Inflation is expected to continue its upward trend in the near term and remain 
above the upper bound of the target interval over the forecast horizon. 
However, the forecasts are subject to considerable uncertainty in the light of 
the Russia-Ukraine war. Over the longer term there are concerns about the 
sustainability of inflation convergence in Romania. According to the European 
Commission’s Spring 2022 Economic Forecast, average annual inflation is expected 
to increase to 8.9% in 2022, before declining to 5.1% in 2023. The European 
Commission’s inflation outlook points to a gradual acceleration in inflation until the 
second quarter of 2022, owing to high food prices and a greater pass-through of 
energy price increases to other components of the inflation basket. Overall, risks to the 
medium-term inflation outlook are tilted to the upside, owing mostly to international 
factors related to lingering supply chain disruptions and high energy prices. However, 
a weaker than expected cyclical position of the economy at the end of 2021 poses 
downside risks to economic growth and could partly counterbalance some of the 
upward pressure on prices. Looking further ahead, there are concerns about the 
sustainability of inflation convergence in Romania over the longer term, also taking 
into account the marked increase in unit labour costs. The catching-up process is also 
likely to result in positive inflation differentials vis-à-vis the euro area, given that GDP 
per capita and price levels are still lower in Romania than in the euro area, unless this 
is counteracted by an appreciation of the nominal exchange rate. In order to prevent 
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the build-up of excessive price pressures and reduce macroeconomic imbalances, the 
catching-up process must be supported by appropriate policies. In particular, wage 
growth needs to be consistent with productivity growth, among other things, in order to 
safeguard price competitiveness and the attractiveness of Romania to foreign 
investors. 
Achieving an environment that is conducive to sustainable convergence in 
Romania requires stability-oriented economic policies and wide-ranging 
structural reforms. With regard to macroeconomic imbalances, the European 
Commission selected Romania for an in-depth review in its Alert Mechanism Report 
2022, highlighting issues related to its external position and cost competitiveness. The 
relatively weak quality of the country’s institutions and governance, as well as its weak 
business environment, continue to hamper its growth potential, in an environment of 
low productivity. As headwinds related to Romania’s demographic profile and labour 
market (i.e. its ageing population coupled with high migration outflows) are likely to 
persist, Romania’s current growth strategy, based on extensive labour utilisation, 
should be complemented by a growth model that is more focused on fostering 
innovation, as well as knowledge-based and high-value-added industries (e.g. ICT). 
Continued reform efforts aimed at fighting corruption, improving competition and 
enhancing the predictability of the country’s tax, judicial, regulatory and administrative 
systems are needed, as they would also boost the country’s attractiveness to foreign 
creditors by enhancing trust in domestic institutions. Measures should include 
upgrading skill levels by improving access to education for the minorities and the 
under-represented, strengthening the insolvency regime and combating regional 
disparities in living standards to spur a more inclusive growth. Finally, effective 
absorption of EU funds remains key to fostering economic convergence in the medium 
term and to guiding the economy in the upcoming green and digital transition. 
Financial sector policies should be aimed at safeguarding financial stability and 
ensuring that the financial sector makes a sound contribution to economic 
growth. After several profitable years, the performance of the banking sector is 
strong, with banks showing solid capital and liquidity positions, and non-performing 
loans having come closer to EU levels. In the light of improved profitability in the 
domestic banking sector and the consolidation of ample voluntary capital and liquidity 
reserves, the Romanian authorities recalibrated the countercyclical capital buffer from 
0% to 0.5% in 2021 and decided not to extend the restrictions on dividend 
distributions. In order to further bolster confidence in the financial system, the national 
competent authorities should continue to improve their supervisory practices, among 
other things, by following the applicable recommendations from the relevant 
international and European bodies, and by collaborating closely with other national 
supervisors of EU Member States within the supervisory colleges. 
5.6.2 Fiscal developments 
Romania’s general government budget deficit was significantly above the 3% 
reference value in 2021, while its debt was below the 60% reference value. In the 
reference year 2021, the general government budget balance recorded a deficit of 
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7.1% of GDP, i.e. significantly above the 3% reference value. The general government 
debt ratio was 48.8% of GDP, i.e. below the 60% reference value (Table 5.6.2). 
Compared with the previous year, the general government deficit decreased by 
2.2 percentage points and the debt ratio increased moderately by 1.6 percentage 
points of GDP. With regard to other fiscal factors, the deficit ratio exceeded the ratio of 
public investment to GDP in 2021. The budget deficits in 2020 and 2021 were 
substantially affected by the economic impact of the COVID-19 pandemic and the 
fiscal policy measures taken in response to it. 
Romania is subject to an excessive deficit procedure, which was launched in 
April 2020 and kept in abeyance on the basis of the achievement of the required 
targets in 2021. Following a recommendation from the European Commission of 4 
March 2020 on the basis of a planned excessive deficit in 2019, the Council decided 
on 3 April 2020, in accordance with Article 126(6) of the Treaty, that an excessive 
deficit existed in Romania and issued a recommendation to correct the excessive 
deficit by 2022 at the latest. On 20 March 2020, the Commission adopted a 
Communication on the activation of the general escape clause of the Stability and 
Growth Pact. On 18 November 2020, the Commission announced that in the light of 
the continued exceptional uncertainty created by the COVID-19 pandemic and its 
extraordinary macroeconomic and fiscal impact, it considered that no decision on 
further steps in the excessive deficit procedure initiated for Romania could be taken at 
that juncture. On 18 June 2021, the ECOFIN Council adopted a recommendation 
under the excessive deficit procedure for Romania, which involved revising the date 
for correcting the excessive deficit from 2022 to 2024, with the argument being that 
this extension was important so as not to compromise its economic recovery following 
the COVID-19 pandemic. The recommendation indicates that, in order to meet this 
new deadline, Romania would need to achieve general government deficit targets of 
8.0% of GDP in 2021, 6.2% of GDP in 2022, 4.4% of GDP in 2023, and 2.9% of GDP 
in 2024. On the basis of the achievement of the required headline deficit target and the 
required fiscal effort in 2021, the excessive deficit procedure is being kept in 
abeyance. 
Both cyclical and non-cyclical factors contributed to the deterioration in the 
budget balance over the period 2019-21. Romania’s fiscal position appeared highly 
vulnerable even before the COVID-19 pandemic, with the deficit having reached 4.3% 
of GDP in 2019. In 2020 the deficit ratio deteriorated by 5 percentage points and the 
structural balance deteriorated by 2.9 percentage points. This was mainly the result of 
pre-existing expansionary policies (including significant increases in pensions), as 
well as temporary measures taken in the face of the COVID-19 pandemic (albeit these 
were smaller in size than those implemented in other countries) and cyclical factors. In 
2021 the deficit improved by 2.2 percentage points and the structural balance 
improved by 1.5 percentage points. While the strong economic recovery supported 
government revenues throughout the year, these gains were offset by expenditure 
slippages, mainly relating to the COVID-19 crisis measures and measures adopted to 
dampen spiking energy prices. 
The debt-to-GDP ratio, while remaining below the 60% reference value, has 
been increasing since 2019. The debt ratio decreased from 39.2% of GDP in 2014 to 
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148 
34.7% of GDP in 2018 owing to a favourable interest-growth differential and, to a 
lesser extent, some favourable deficit-debt adjustments. In 2019, by contrast, the debt 
ratio increased slightly for the first time since 2014. The debt ratio subsequently 
increased strongly in 2020, before a further moderate increase in 2021, when it 
reached 48.8% of GDP. The increases over the period 2019-21 were largely the result 
of primary deficits, with the favourable interest-growth differential helping to contain 
the debt increase in 2021 (Table 5.6.2). 
The level and structure of government debt indicate that Romania’s fiscal 
balances are protected from sudden changes in interest rates; however, those 
balances are sensitive to exchange rate fluctuations. The share of government 
debt with a short-term maturity is low (5.1% of overall debt in 2021 – Table 5.6.2). After 
decreasing during the global financial crisis, the share of debt with a medium or 
long-term maturity reached a peak of 96.9% in 2019. Taking into account medium and 
long-term debt with a variable interest rate as a percentage of GDP, fiscal balances 
appear relatively insensitive to interest rate changes. The proportion of foreign 
currency-denominated government debt is high (53.3% in 2021). Taking the size of 
the debt in relation to GDP into consideration, it can therefore be concluded that the 
fiscal balances are sensitive to exchange rate movements, mainly the euro/leu 
exchange rate, as a large part of the debt is denominated in euro (85.2% of 
foreign-denominated debt in 2021). 
The European Commission’s Spring 2022 Economic Forecast foresees a 
moderate improvement in the budget balance by 2023 and a notable increase in 
the debt ratio, with significant further consolidation required for Romania to 
correct its excessive deficit situation. According to the European Commission’s 
Spring 2022 Economic Forecast, the deficit is projected to deteriorate to 7.5% of GDP 
in 2022 before improving to 6.3% of GDP in 2023. These fall short of the excessive 
deficit procedure’s intermediate budget deficit targets of 6.2% and 4.4% of GDP 
respectively. Over the period 2022-23, the structural deficit is projected to stand at 
6.5% and 5.4% of GDP in 2022 and 2023 respectively, thus pointing to the need for 
comprehensive further consolidation in order for Romania to return to its medium-term 
objective (a structural deficit of 1% of GDP). Nevertheless, the Stability and Growth 
Pact’s general escape clause, which continues to be applied in 2022 and is also 
expected to remain in place in 2023, provides that “in periods of severe economic 
downturn for the euro area or the Union as a whole, Member States may be allowed 
temporarily to depart from the adjustment path towards the medium-term budgetary 
objective…, provided that this does not endanger fiscal sustainability in the medium 
term”. With regard to the debt ratio, the European Commission forecasts a notable 
increase of 2.1 percentage points of GDP in 2022, followed by a further moderate 
increase of 1.7 percentage points in 2023. The debt ratio is projected to remain below 
the 60% reference value, reaching 52.6% of GDP in 2023, but this would be its highest 
level since 1995. Romania’s April 2022 convergence programme update forecasts a 
deficit of 6.2% of GDP and a debt ratio of 49.4% of GDP for 2022, both of which are 
lower than the European Commission’s forecasts. On the basis of the European 
Commission’s Spring 2022 Economic Forecast, significant further consolidation will be 
required to correct the excessive deficit situation. 
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Romania has strengthened its national fiscal governance framework 
significantly, but the framework has not been respected or applied effectively, 
particularly in the context of policy decisions taken from 2015 onwards. 
Romania’s fiscal governance framework was strengthened following the adoption of 
the fiscal compact (through the implementation of a structural budget balance rule, a 
debt rule and a correction mechanism), the creation of an independent Fiscal Council 
in 2010, and a reform of the tax collection agency. However, Romania has 
systematically and repeatedly derogated from its national fiscal rules and the timeline 
for the adoption of the medium-term fiscal strategy as enshrined in the national fiscal 
framework, thereby rendering these rules largely ineffective. In particular, the 
Romanian authorities should fully support the Fiscal Council by submitting the budget 
on a timely basis and by increasing the transparency of the macroeconomic and fiscal 
forecasts and the budget documentation. The Government should also increase 
efforts to improve its public finance management, reform the public administration and 
make tax policy and administration more efficient. Limited progress has been made in 
public investment project preparation and prioritisation. Moreover, the corporate 
governance of state-owned enterprises has been weakened. Romania’s budgetary 
adjustment would be supported by the full application of the national fiscal framework. 
Romania faces low sustainability risks in the short term, high sustainability 
risks in the medium term and medium sustainability risks in the long term, and 
it needs to address the challenges of its ageing population. The European 
Commission’s 2021 Fiscal Sustainability Report points to low risks over the short term, 
with the assessment of short-term risks improving from high to low compared with the 
European Commission’s 2020 Debt Sustainability Monitor, notably supported by the 
economic recovery in 2021. For the medium term, the high risk classification, 
unchanged compared with the 2020 Debt Sustainability Monitor, reflects the currently 
large deficit, rising debt, and sensitivity to adverse shocks.195 For the long term, the 
assessment of risks has improved from high to medium compared with the 2020 Debt 
Sustainability Monitor due to lower ageing-related costs (which are, however, still 
expected to increase significantly). Indeed, the European Commission’s 2021 Ageing 
Report196 points to a significant increase of 5.1 percentage points of GDP in 
age-related public expenditure over the period 2019-70 under its reference scenario, 
from a level of 14.9% of GDP in 2019. Under the AWG’s risk scenario, the increase in 
the cost of ageing amounted to 9.9 percentage points of GDP. All these developments 
suggest that further reforms are needed to improve the long-term sustainability of 
public finances. 
Looking ahead, additional reforms and a sound fiscal position in line with the 
provisions of the Stability and Growth Pact are needed to safeguard the 
sustainability of public finances over the medium term. Fiscal policy should 
remain agile in its response to the evolving pandemic and given the geopolitical 
situation. At the same time, Romania must ensure compliance with the requirements 
of the excessive deficit procedure through comprehensive further consolidation, while 
 
195  This assessment was confirmed by the updated debt sustainability analysis which was published as part 
of the European Commission’s country report for Romania on 23 May 2022. 
196  European Commission and Economic Policy Committee, “The 2021 Ageing Report: Economic &amp; 
Budgetary Projections for the EU Member States (2019-2070)”, European Economy Institutional Paper, 
No 148, European Commission, 2021. 
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being geared towards enhancing the quality of public finances and reinforcing the 
growth potential of the economy. Moreover, the Next Generation EU programme 
needs to be implemented effectively in order to support the recovery and adjust to the 
structural changes that are under way. The Romanian Government should make 
further efforts to improve the tax collection system, fight tax evasion, increase 
spending efficiency, advance structural fiscal reforms (including in the corporate 
governance of state-owned enterprises), and tackle the projected increase in 
age-related costs. 
5.6.3 Exchange rate developments 
Over the reference period from 26 May 2020 to 25 May 2022, the Romanian leu 
did not participate in ERM II, but traded under a flexible exchange rate regime 
involving a managed floating of the currency’s exchange rate. Over the two-year 
reference period the Romanian leu mostly traded close to its May 2020 average 
exchange rate against the euro of 4.8371 lei per euro, which is used as a benchmark 
for illustrative purposes in the absence of an ERM II central rate (Chart 5.6.3). The 
maximum upward deviation from this benchmark was 0.1%, while the maximum 
downward deviation amounted to 2.4%. On 25 May 2022 the exchange rate stood at 
4.9416 lei per euro, i.e. 2.2% weaker than its average level in May 2020. Furthermore, 
in June 2020 Banca Naţională a României entered a repo line arrangement with the 
ECB under which it could borrow up to €4.5 billion against high quality 
euro-denominated collateral to provide euro liquidity to Romanian financial institutions 
in order to address possible liquidity needs owing to the pandemic. As this 
arrangement helped to reduce the potential risk of financial vulnerabilities, it may also 
have had an impact on exchange rate developments over the reference period. Over 
the past ten years the Romanian leu has depreciated against the euro by 11.3%. 
The exchange rate of the Romanian leu against the euro exhibited, on average, 
a very low degree of volatility over the reference period. In the immediate 
aftermath of the pandemic-related market turmoil, exchange rate volatility increased 
somewhat in the second quarter of 2020. However, it declined to stand at very low 
levels in the third quarter and throughout the remainder of the reference period, with 
only a moderate pick-up in the second quarter of 2021, mostly on account of 
developments related to the emergence of the Delta variant of the coronavirus. 
Although the performance of the Romanian economy has been relatively strong, 
throughout the reference period the leu continued its steady depreciating trend which 
started in late 2016. This mainly reflects risks to the country’s fiscal sustainability, 
weaknesses in its external position and political tensions. The depreciating trend 
gained momentum in mid-March 2020 following the intensification of the COVID-19 
pandemic in Europe, although there have been signs of a stabilisation since the end of 
the third quarter of 2021. Over the reference period short-term interest rate 
differentials against the three-month EURIBOR were relatively wide. After declining 
moderately from the end of 2020, spreads started to follow a notable upward trajectory 
from October 2021 and reached a peak of 4.0 percentage points in the three-month 
period ending in March 2022. This reflected the tighter domestic monetary policy 
stance in view of a widening of inflation differentials vis-à-vis the euro area. Indeed, 
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Banca Naţională a României hiked its monetary policy rate on six occasions between 
October 2021 and May 2022. 
The Romanian leu has depreciated slightly over the past ten years in real 
effective terms (Chart 5.6.4). Looking forward, this indicator should be interpreted 
with caution, as Romania is subject to a process of economic convergence, which 
complicates any long-term assessment of real exchange rate developments. 
Romania’s current and capital account balance has weakened over the past ten 
years, while the country’s net foreign liabilities have declined gradually but
remain high (Table 5.6.3). Following three consecutive EU and IMF financial 
assistance programmes ending in 2015, the combined current and capital account 
balance strengthened in the period to 2016, before deteriorating notably in the 
following four years. This reflected a growing trade deficit on the back of a worsening 
merchandise goods balance in conjunction with a flattening services surplus, in the 
light of a moderation in Romania’s export performance and strong domestic demand,
in particular household consumption. This trend continued after the outbreak of the 
COVID-19 pandemic, which further worsened the trade balance owing to the 
emergence of global supply chain disruptions. On the financing side, from 2012 to 
2015 net inflows in direct and portfolio investment were more than offset by net 
outflows in other investment, and gross external debt declined simultaneously. 
Portfolio investment inflows in the form of debt securities subsequently gained in 
importance. Together with other debt-creating inflows, this led to an increase in gross 
external debt in nominal euro terms from 2015. However, as a result of nominal GDP 
growth, the gross external debt ratio decreased from 59.1% in 2015 to 49.5% in 2019. 
Subsequently, given the Romanian Government’s extraordinary emergency fiscal
spending (financed in part by the issuance of international bonds) and the economic 
contraction witnessed in the country, the gross external debt ratio increased notably to 
stand at 58.3% in 2020, before edging down to 56.4% in 2021. The country’s net
international investment position improved from -53.7% of GDP in 2015 to -43.6% of 
GDP in 2019, before worsening substantially again to -47.9% of GDP in 2020. It then 
improved again in 2021 to a level of -45.7% of GDP. While improving somewhat over 
the last ten years, the country’s net foreign liabilities remain high. Fiscal and structural
policies therefore continue to be important to promote external sustainability and to 
boost domestic economic competitiveness. 
The Romanian economy is well integrated with the euro area through trade and 
investment linkages. In 2021 exports of goods and services to the euro area 
constituted 55.7% of total exports, while the corresponding figure for imports 
amounted to 52.4%. In the same year the share of the euro area in Romania’s stock of
inward direct investment stood at 79.2% and its share in the country’s stock of portfolio
investment liabilities was 58.7%. The share of Romania’s stock of foreign assets
invested in the euro area amounted to 67.2% in the case of direct investment and 
58.5% for portfolio investment in 2021. 
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5.6.4 Long-term interest rate developments 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in Romania stood at 4.7% on average and were thus well above the 2.6% 
reference value for the interest rate convergence criterion (Chart 5.6.5). 
Long-term interest rates in Romania stood at 6.6% in April 2022, an increase of 
390 basis points compared with January and February 2021, which were the 
months when the lowest level was reached during the review period. Between 
2012 and early 2015 long-term interest rates in Romania declined steadily from 
around 7% to a historical low of 2.7% in February 2015. During this period long-term 
interest rates were driven by developments in the euro area, where financial markets 
lowered their assessment of sovereign risk, and by the decrease in inflation 
expectations in Romania amid the steady decline in actual inflation, which then turned 
negative in 2015. The long-term interest rate in Romania then fluctuated between 3% 
and 4% over the period 2015-17 and between 4% and 5% thereafter, until the 
outbreak of the COVID-19 pandemic in spring 2020. During that period, the economy 
was characterised by sustained positive inflation dynamics, sizeable current account 
deficits and uncertainty regarding the sustainability of the Government’s fiscal policy. 
In March 2020 Banca Naţională a României started to purchase government bonds on 
the secondary market as part of a package of measures aimed at mitigating the 
economic impact of the pandemic and consolidating liquidity in the banking system. 
This was to ensure the good functioning of the money market and of other financial 
market segments, as well as the smooth financing of the real economy and the public 
sector. Furthermore, between March 2020 and January 2021 Banca Naţională a 
României cut its policy rate by a cumulative 125 basis points to counter the negative 
impact of the pandemic on economic growth and inflation. After touching their 
historical minimum of 2.7% again in February 2021, long-term interest rates embarked 
on a steep upward path owing to the quick recovery of economic growth as well as 
higher than expected inflation, among other factors. In a context of rising inflation and 
supply-side shocks posing risks to medium-term inflation expectations, Banca 
Naţională a României reversed the course of monetary policy and, in the fourth quarter 
of 2021, began to increase the policy rate, which currently stands at 3.75%, 250 basis 
points higher than its minimum in January 2021. Persistent market concerns about the 
sustainability of domestic government finances is one of the main factors behind the 
high credit default swap spreads for Romanian government bonds, which stood at 200 
basis points in April 2022, one of the highest levels among the group of peer countries 
in the region. Romania’s government debt is rated at the lowest investment-grade 
notch by all three main rating agencies. 
The long-term interest rate differential of Romanian bonds vis-à-vis the euro 
area has steadily increased since the end of 2016. After a period of relatively high 
volatility, the long-term interest rate differential of Romanian sovereign bonds vis-à-vis 
the euro area average stabilised between the end of 2014 and the end of 2016. Since 
then the interest rate differential has increased continuously, excluding a short-lived 
episode from May 2020 to February 2021, to reach levels of more than 5% at the end 
of the review period. 
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Capital markets in Romania are much smaller than in the euro area and are still 
underdeveloped (Table 5.6.4). At the end of 2021 the Romanian corporate debt 
market barely existed, as the outstanding amount of debt securities issued by financial 
and non-financial corporations amounted to only 0.8% and 0.4% of GDP respectively. 
Romania’s equity market is also still quite small, as its stock market capitalisation, at 
11.5% of GDP in 2021, ranks among the lowest in the region. Foreign-owned banks 
play a major role in Romania and accounted for around 71% of total banking assets in 
2020. The degree of financial intermediation is quite small and is the lowest in the 
region, as measured by the credit extended by MFIs to the private sector, which stood 
at 27.4% of GDP in 2021. Over the past decade Romanian banks have gradually 
relied less on euro area banks for their funding needs. The claims of euro area banks 
on Romanian banks have declined from an annual average of around 11% of total 
liabilities of domestic MFIs over the period 2012-21 to 2.2% in 2021. Since 2012 the 
share of MFI loans denominated in domestic currency in total loans extended to the 
private sector has increased consistently, from about 38% at the end of 2012 to 72% in 
February 2022. 
  
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 352 – 
Romania - Price developments
S 1 ECB Convergence Report, May 2022 
Chart 5.6.1 HICP inflation and reference value 1) 
(annual percentage changes)
-4
-2
0
2
4
6
8
10
12
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
-4
-2
0
2
4
6
8
10
12
HICP
HICP (12-month moving average)
Reference value
Sources: European Commission (Eurostat) and ECB calculations.
1) The basis of the calculation of the reference value for the period from May 2021 to April 2022 is the unweighted arithmetic average of the annual percentage
changes in the HICP for France, Finland and Greece plus 1.5 percentage points. The reference value is 4.9%.
Table 5.6.1 Measures of inflation and related indicators
(annual percentage changes, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Measures of inflation           
 HICP 2.2 1.3 3.1 1.1 4.1 3.9 2.3 4.1 8.9 5.1
 HICP excluding unprocessed food and energy 2.1 1.5 2.7 0.9 2.7 3.8 3.3 3.1 7.1 4.8
 HICP at constant tax rates 3) 2.6 2.1 3.1 2.0 3.8 3.7 2.3 3.9 - -
 CPI 2.4 1.2 3.5 1.4 4.6 3.8 2.6 5.1 8.9 5.1
 Private consumption deflator 3.0 2.0 4.0 2.7 3.8 5.4 2.4 5.5 9.1 5.3
 GDP deflator 4.2 2.9 5.4 4.7 6.2 6.8 3.9 5.4 9.5 4.9
 Producer prices 4) 3.4 0.8 6.0 3.1 5.2 5.1 0.2 17.4 - -
 Related indicators           
 Real GDP growth 3.5 3.4 3.5 7.3 4.5 4.2 -3.7 5.9 2.6 3.6
 GDP per capita in PPS 5) (euro area = 100) 57.2 52.1 63.5 59.4 61.4 65.3 68.1 . - -
 Comparative price levels (euro area = 100) 51.9 51.6 52.4 51.9 52.7 52.6 52.4 . - -
 Output gap 6) -1.2 -2.0 -0.4 1.4 1.9 2.0 -4.8 -2.5 -3.0 -2.7
 Unemployment rate (%) 7) 7.0 8.4 5.6 6.1 5.3 4.9 6.1 5.6 5.5 5.3
 Unit labour costs, whole economy 3.1 2.5 3.8 9.5 8.2 6.6 4.7 -9.1 6.4 4.1
 Compensation per employee, whole economy 7.7 6.2 9.3 14.8 12.9 10.9 2.6 5.7 8.3 7.0
 Labour productivity, whole economy 4.5 3.6 5.4 4.8 4.4 4.0 -2.0 16.3 1.7 2.8
 Imports of goods and services deflator 0.8 -1.6 3.3 4.7 3.9 0.8 -1.7 9.2 10.9 3.8
 Nominal effective exchange rate 8) -0.8 -1.0 -0.6 -0.6 0.4 -2.1 0.1 -0.7 - -
 Money supply (M3) 9) 9.9 7.6 12.3 11.1 10.6 9.9 15.1 14.9 - -
 Lending from banks 10) 5.7 2.2 9.3 7.9 10.2 6.7 6.5 15.4 - -
 Stock prices (BET) 11) 201.3 63.4 84.4 9.4 -4.8 35.1 -2.4 34.2 - -
 Residential property prices 2.5 0.2 4.8 6.0 5.6 3.4 4.7 4.4 - -
Sources: European Commission (Eurostat, Directorate-General for Economic and Financial Affairs), national data for CPI, money supply, lending from banks
and ECB calculations based on Refinitiv data for stock prices.
1) Multi-annual averages calculated using the geometric mean, except for GDP per capita in PPS, comparative price levels, output gap and unemployment rate, for which the
arithmetic mean is used.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) The difference between the HICP and the HICP at constant tax rates shows the theoretical impact of changes in indirect taxes (e.g. VAT and excise duties) on the overall rate
of inflation. This impact assumes a full and instantaneous pass-through of tax rate changes to the price paid by the consumer.
4) Domestic sales, total industry excluding construction.
5) PPS stands for purchasing power standards.
6) Percentage difference from potential GDP: a positive (negative) sign indicates that actual GDP is above (below) potential GDP.
7) Definition conforms to International Labor Organization guidelines.
8) EER-42 group of trading partners. A positive (negative) sign indicates an appreciation (depreciation).
9) The series includes repurchase agreements with central counterparties.
10) Adjusted for the derecognition of loans from the MFI statistical balance sheet due to their sale or securitisation.
11) Multi-annual and annual figures represent the percentage change between the end of the given period and the end of the previous period.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 353 – 
Romania - Fiscal developments
S 2 ECB Convergence Report, May 2022 
Chart 5.6.2 General government balance and debt
(as a percentage of GDP)
-11
-9
-7
-5
-3
-1
1
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
10
20
30
40
50
60
70
80
Government balance (left-hand scale)
Government debt (right-hand scale)
Reference values (government balance: -3%; government debt: 60%)
Sources: European System of Central Banks and European Commission (Eurostat).
Table 5.6.2 Government budgetary developments and projections
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Government balance -3.6 -2.0 -5.2 -2.6 -2.8 -4.3 -9.3 -7.1 -7.5 -6.3
 Total revenue 32.9 33.8 32.0 30.8 32.0 31.9 32.7 32.8 33.6 33.3
 Current revenue 31.3 31.9 30.6 29.4 31.0 30.7 31.0 30.9 31.5 31.3
 Direct taxes 5.7 6.2 5.1 6.1 4.9 4.9 4.7 5.1 5.8 5.6
 Indirect taxes 11.6 12.7 10.5 10.3 10.4 10.6 10.4 10.7 10.7 10.6
 Net social contributions 9.8 8.6 11.1 9.4 11.4 11.3 11.9 11.4 11.3 11.4
 Other current revenue 3) 4.2 4.5 3.9 3.7 4.2 4.0 4.0 3.6 3.7 3.7
 Capital revenue 1.7 1.9 1.4 1.4 1.0 1.1 1.7 2.0 2.1 2.0
 Total expenditure 36.6 35.9 37.3 33.5 34.8 36.2 42.0 39.9 41.1 39.6
 Current expenditure 31.3 30.0 32.5 29.9 30.7 31.6 36.0 34.4 33.9 32.5
 Compensation of employees 9.6 8.1 11.1 9.8 11.0 11.3 12.1 11.1 10.2 9.8
 Social benefits 12.0 11.7 12.3 11.6 11.6 11.8 13.4 13.2 12.9 12.5
 Interest payable 1.5 1.7 1.2 1.3 1.0 1.1 1.4 1.4 1.5 1.6
 Other current expenditure 4) 8.2 8.4 7.9 7.2 7.1 7.4 9.1 8.7 9.2 8.7
 Capital expenditure 5.3 5.9 4.8 3.6 4.1 4.6 6.0 5.6 7.2 7.0
  of which: Investment 4.0 4.5 3.5 2.6 2.7 3.5 4.6 4.2 5.9 6.0
 Cyclically adjusted balance -3.3 -1.4 -5.1 -3.1 -3.5 -5.0 -7.8 -6.3 -6.5 -5.4
 One-off and temporary measures 0.0 0.1 -0.1 0.0 -0.3 -0.1 0.0 0.0 0.0 0.0
 Structural balance 5) -3.3 -1.5 -5.0 -3.1 -3.1 -4.9 -7.8 -6.3 -6.5 -5.4
 Government debt 39.0 37.8 40.2 35.1 34.7 35.3 47.2 48.8 50.9 52.6
 Average residual maturity (in years) 6.0 5.0 7.0 6.2 6.6 6.9 7.7 7.4 . .
 In foreign currencies (% of total) 53.6 55.8 51.3 51.9 50.3 48.7 52.3 53.3 . .
  of which: Euro 44.1 45.4 42.9 43.4 41.2 40.4 43.9 45.4 . .
 Domestic ownership (% of total) 50.2 49.0 51.5 51.4 52.2 53.7 49.2 50.8 . .
 Medium and long-term maturity (% of total) 6) 93.9 91.7 96.0 95.0 96.8 96.9 96.5 94.9 . .
  of which: Variable interest rate (% of total) 9.6 12.6 6.5 11.4 6.3 5.5 5.0 4.5 . .
 Deficit-debt adjustment 0.6 0.9 0.3 -0.8 0.3 -0.3 2.6 -0.6 . .
 Net acquisitions of main financial assets 0.5 1.0 -0.1 -0.6 0.0 -1.3 2.1 -0.5 . .
 Currency and deposits 0.5 1.2 -0.2 -0.4 -0.3 -1.5 2.0 -0.6 . .
 Debt securities 0.0 0.0 0.1 0.0 0.1 0.0 0.1 0.1 . .
 Loans 0.2 0.0 0.3 0.4 0.4 0.3 0.2 0.1 . .
 Equity and investment fund shares or units -0.2 -0.2 -0.3 -0.6 -0.3 -0.2 -0.2 -0.2 . .
 Revaluation effects on debt 0.1 -0.1 0.3 0.3 0.2 0.3 0.2 0.3 . .
  of which: Foreign exchange holding    
 gains/losses 0.3 0.2 0.3 0.5 0.0 0.5 0.4 0.4 . .
 Other 7) 0.0 -0.1 0.1 -0.5 0.2 0.7 0.3 -0.4 . .
 Convergence programme: government balance - - - - - - - - -6.2 -4.4
 Convergence programme: structural balance - - - - - - - - -5.4 -3.8
 Convergence programme: government debt - - - - - - - - 49.4 49.7
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast, except for convergence programme data.
3) Sales and other current revenue.
4) Intermediate consumption, subsidies payable and other current expenditure.
5) Cyclically adjusted balance excluding one-off and other temporary measures.
6) Original maturity of more than one year.
7) Time of recording differences and other factors (sector reclassifications and statistical discrepancies).
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 354 – 
Romania - Exchange rate and external developments
S 3 ECB Convergence Report, May 2022 
Chart 5.6.3 Bilateral exchange rate and short-term
interest rate differential
Chart 5.6.4 Effective exchange rates 1) 
(EER-42 group of trading partners; monthly averages; index: Q1 1999 = 100)
(RON/EUR exchange rate: monthly averages;
difference between three-month interbank interest rates
and three-month EURIBOR: basis points, monthly values)
5.2
5.0
4.8
4.6
4.4
4.2
2012 2014 2016 2018 2020
0.0
1.0
2.0
3.0
4.0
5.0
6.0
RON/EUR exchange rate (left-hand scale)
Interest rate differential (right-hand scale)
32
33
34
34
35
36
2012 2014 2016 2018 2020
130
133
136
139
142
145
Nominal (left-hand scale)
Real (right-hand scale)
Sources: National data and ECB calculations. Source: ECB.
1) The real EER-42 is CPI-deflated. An increase (decrease) in the EER indicates
an appreciation (depreciation).
Table 5.6.3 External developments
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Balance of payments
Current account and capital account balance 3) -1.4 0.5 -3.4 -1.9 -3.4 -3.6 -3.1 -4.8 -5.9 -5.7
Current account balance -3.3 -1.7 -4.9 -3.1 -4.6 -4.9 -5.0 -7.0 -7.5 -7.3
 Goods -6.7 -5.3 -8.1 -6.8 -7.5 -8.0 -8.7 -9.6 . .
 Services 3.9 3.6 4.1 4.4 4.1 3.9 4.3 4.0 . .
 Primary income -1.4 -1.2 -1.6 -1.4 -1.8 -1.4 -1.5 -1.7 . .
 Secondary income 0.9 1.2 0.7 0.8 0.6 0.7 0.9 0.4 . .
Capital account balance 1.9 2.2 1.6 1.2 1.2 1.3 1.9 2.2 . .
Combined direct and portfolio investment balance 3) -4.2 -3.8 -4.6 -4.2 -3.8 -3.3 -7.5 -4.3 . .
 Direct investment -2.2 -2.1 -2.3 -2.6 -2.4 -2.2 -1.3 -3.0 . .
 Portfolio investment -2.0 -1.8 -2.3 -1.6 -1.4 -1.1 -6.1 -1.3 . .
Other investment balance 2.7 4.4 0.9 2.3 1.7 1.1 1.4 -2.1 . .
 Reserve assets 0.4 0.1 0.6 0.2 -0.4 -0.1 2.6 0.9 . .
Exports of goods and services 40.5 40.4 40.5 42.1 41.9 40.4 37.2 40.9 . .
Imports of goods and services 43.3 42.1 44.5 44.5 45.3 44.5 41.5 46.5 . .
Net international investment position 4) -52.0 -58.4 -45.7 -47.4 -43.8 -43.6 -47.9 -45.7 . .
Gross external debt 4) 59.4 65.6 53.2 52.9 48.9 49.5 58.3 56.4 . .
 Trade with the euro area 5)
Exports of goods and services 55.7 54.0 57.0 57.0 57.6 57.2 57.7 55.7 . .
 Imports of goods and services 53.8 54.3 53.5 54.5 54.2 52.9 53.3 52.4 . .
 Investment position with the euro area 5)
Direct investment assets 4) 75.6 81.6 70.7 72.7 72.0 70.4 71.3 67.2 . .
Direct investment liabilities 4) 81.2 82.6 80.1 81.7 81.9 79.9 78.1 79.2 . .
Portfolio investment assets 4) 61.4 59.7 62.8 65.1 60.4 64.6 65.5 58.5 . .
Portfolio investment liabilities 4) 56.1 51.7 60.5 58.9 59.6 64.7 60.8 58.7 . .
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean. Owing to the unavailability of data, the multi-annual averages for the "trade with the euro area" series and for the
"direct investment assets", "portfolio investment assets" and "direct investment liabilities" components of the "investment position with the euro area" series are calculated
for the period starting in 2013.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) Differences between totals and the sum of their components are due to rounding.
4) End-of-period outstanding amounts.
5) As a percentage of the total.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 355 – 
Romania - Long-term interest rate developments
S 4 ECB Convergence Report, May 2022 
Chart 5.6.5 Long-term interest rate 1) 
(monthly averages in percentages)
Chart 5.6.6 Long-term interest rate and HICP inflation
differentials vis-à-vis the euro area
(monthly averages in percentage points)
0
1
2
3
4
5
6
7
8
2012 2014 2016 2018 2020
0
1
2
3
4
5
6
7
8
Long-term interest rate
Long-term interest rate (12-month moving average)
Reference value
-4
-2
0
2
4
6
2012 2014 2016 2018 2020
-4
-2
0
2
4
6
Long-term interest rate differential
HICP inflation differential
Sources: European System of Central Banks and ECB calculations.
1) The basis of the calculation of the reference value for the period from May
2021 to April 2022 is the unweighted arithmetic average of the interest rate
levels in France, Finland and Greece plus 2 percentage points. The reference
value is 2.6%.
Sources: European System of Central Banks, ECB calculations and European
Commission (Eurostat).
Table 5.6.4 Long-term interest rates and indicators of financial development and integration
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2018 2019 2020 2021 May. 2021 Memo item:
to euro area
Apr. 2022 2021
 Long-term interest rates
 Romania 2) 4.4 4.7 4.1 4.7 4.5 3.9 3.6 4.7 -
 Euro area 3), 4) 1.4 2.2 0.6 1.1 0.4 0.1 0.1 0.4 -
Euro area AAA par curve, ten-year residual maturity 2), 4) 0.6 1.2 0.0 0.5 -0.2 -0.4 -0.3 -0.1 -
 Indicators of financial development and integration
Debt securities issued by financial corporations 5) 0.3 0.3 0.4 0.2 0.4 0.4 0.8 - 66.7
Debt securities issued by non-financial corporations 6) 0.1 0.1 0.2 0.0 0.0 0.4 0.4 - 13.4
Stock market capitalisation 7) 9.7 10.0 9.4 8.0 9.5 8.5 11.5 - 77.7
MFI credit to non-government residents 8) 29.6 32.7 26.6 26.4 25.3 26.7 27.4 - 111.1
Claims of euro area MFIs on resident MFIs 9) 10.5 16.6 4.4 5.8 4.0 2.6 2.2 - 29.5
Sources: European System of Central Banks and ECB calculations.
1) Multi-annual averages calculated using the arithmetic mean.
2) Average interest rate.
3) GDP-weighted average of the euro area long-term interest rates for the purpose of assessing convergence.
4) Included for information only.
5) Outstanding amount of debt securities issued by resident MFIs (excluding the national central bank) and other financial corporations.
6) Outstanding amount of debt securities issued by resident non-financial corporations.
7) Outstanding amount of listed shares issued by residents at market values.
8) MFI (excluding national central bank) credit to domestic non-MFI residents other than general government. Credit comprises outstanding amounts of loans and debt securities.
9) Outstanding amount of deposits and debt securities issued by domestic MFIs (excluding the national central bank) held by euro area MFIs as a percentage of total liabilities
of domestic MFIs (excluding the national central bank). Total liabilities exclude capital and reserves and remaining liabilities.
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158 
5.7 Sweden 
5.7.1 Price developments 
In April 2022 the 12-month average rate of HICP inflation in Sweden was 3.7%, 
i.e. well below the reference value of 4.9% for the criterion on price stability 
(Chart 5.7.1). This rate is expected to increase gradually over the coming months, 
driven mainly by the higher commodity prices, broadening price pressures and further 
aggravation of supply bottlenecks resulting from the Russia-Ukraine war. 
Over the past ten years the 12-month average rate of HICP inflation has 
fluctuated within a range from 0.2% to 3.7%, and the average for that period was 
subdued, standing at 1.2%. Between 2012 and 2014 consumer price inflation was 
contained, owing to the steady appreciation of the krona in nominal effective terms 
and low external price pressures. In 2015 it picked up from very low levels, driven by 
the lagged effects of the krona’s depreciation in 2014 and strong economic growth 
(Chart 5.7.1). This upward trend was also underpinned by an accommodative 
monetary policy stance, as Sveriges Riksbank reduced its main policy rate, taking it 
into negative territory, and launched a programme of government bond purchases in 
February 2015. Between early 2017 and early 2019, HICP inflation hovered between 
1.4% and 2.5%, as volatile energy prices contributed to fitful inflation growth. In 
December 2018 Sveriges Riksbank raised its repo rate from -0.50% to -0.25%, in the 
light of robust economic growth and accelerating core inflation. Despite a marked 
slowdown in economic activity and a drop in inflation to below the 2% target, owing to 
lower energy prices, the central bank lifted its main policy rate again at the end of 
December 2019, up from -0.25% to 0%. At the same time, core inflation continued to 
accelerate and stood at 1.8% in the fourth quarter of 2019. With the contraction of the 
Swedish economy in the first half of 2020 as a result of the coronavirus (COVID-19) 
pandemic, HICP inflation fell significantly, averaging 0.7% over the whole year. Weak 
cost pressures reflected, among other things, low resource utilisation, the 
strengthening of the real exchange rate, muted import prices and moderate wage 
gains. Social partners delayed negotiations on a multi-annual wage agreement, which 
led to a marked decline in overall compensation growth in the second half of 2020. 
Nevertheless, the major fiscal, macroprudential and monetary policy measures taken 
by the national authorities to offset the economic damage wrought by the pandemic, 
as well as the phasing-out of the pandemic-related restrictions, bolstered a rebound in 
economic activity. Against this background, in 2021 economic activity grew by 4.8% 
and HICP inflation rose by 2.7% – its highest increase since 2008 – owing mainly to 
rising energy prices (Table 5.7.1). 
In the first four months of 2022 the average annual rate of HICP inflation 
increased further and stood at 5.3%. Both core and energy inflation rose 
significantly. Russia’s invasion of Ukraine in late February 2022 drove up energy and 
commodity prices, generating additional inflationary pressures. Against this 
background, the Executive Board of Sveriges Riksbank decided on 28 April 2022 to 
raise its policy rate to 0.25%, up from 0%, to prevent the high inflation from becoming 
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entrenched in price and wage-setting. It also decided to reduce the pace of the central 
bank’s asset purchases during the second half of 2022. 
Policy choices have played an important role in shaping inflation dynamics in 
Sweden over the past decade, most notably the orientation of monetary policy 
towards price stability. Since 1995 Sveriges Riksbank has had an inflation target 
that is quantified as an annual rise of 2.0% in the CPI. In June 2010 the tolerance 
margin of ±1 percentage point was removed from the policy objective. Sweden’s 
institutional framework, which fosters prudent fiscal policy and wage formation, has 
generally lent support to the achievement of price stability. However, in September 
2017 Sveriges Riksbank decided to use inflation measured in terms of the CPIF (the 
CPI with a fixed interest rate) as a formal target variable for monetary policy, while 
keeping the target for monetary policy at 2.0%. It also decided to use a variation band 
of ±1 percentage point to illustrate uncertainty surrounding the development of 
inflation. 
Inflation in Sweden is set to decline over the forecast horizon, but to remain 
above 2.0%. However, the forecasts are subject to considerable uncertainty 
given the current circumstances. According to the European Commission’s Spring 
2022 Economic Forecast, average annual HICP inflation is expected to reach 5.3% in 
2022, before falling to 3.0% in 2023, owing mainly to the easing of global supply 
bottlenecks and a fall in energy and commodity prices in early 2023. However, the 
risks to the inflation outlook are tilted to the upside, as inflationary pressures stemming 
from the Russia-Ukraine war could last longer than previously expected and also 
trigger an upward shift in wage growth and inflation expectations. Looking further 
ahead, monetary policy and the stability-oriented institutional framework should 
continue to support the achievement of price stability in Sweden. 
Maintaining an environment that is conducive to sustainable convergence in 
Sweden requires the continuation of stability-oriented economic policies and 
targeted structural reforms. Despite the significant negative impact of the pandemic 
on the real economy, residential property prices in Sweden have risen sharply since 
spring 2020, mainly on the back of increased demand. This price upturn seems to 
deviate significantly from historical fundamentals such as mortgage rates or 
household disposable income. The European Commission selected Sweden for an 
in-depth review in its Alert Mechanism Report 2022, in particular because of the 
macroeconomic imbalances stemming from the housing market. 
Financial sector policies should be aimed at continuing to safeguard financial 
stability and ensuring that the financial sector makes a sound contribution to 
economic growth. Macro-financial risks have been high in recent years, owing 
primarily to high residential property prices, elevated levels of household 
indebtedness and the large exposure of the banking sector to the housing market. 
Although the resilience of the banking sector has improved in recent years, as banks 
have built up liquidity buffers and increased their capital ratios, the Swedish authorities 
need to tackle the structural factors behind the residential property price dynamics to 
ease macro-financial risks. Against this background, the Swedish Financial 
Supervisory Authority (Finansinspektionen) decided at the end of 2021 to no longer 
offer the option of an exemption from the amortisation requirement and to raise the 
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160 
countercyclical buffer rate. In order to further bolster confidence in the financial 
system, the national competent authorities should continue to improve their 
supervisory practices, among other things, by following the applicable 
recommendations from the relevant international and European bodies, and by 
collaborating closely with other national supervisors of EU Member States within the 
supervisory colleges. 
5.7.2 Fiscal developments 
Sweden’s general government budget deficit was well below the 3% reference 
value in 2021 and its debt ratio was well below the 60% reference value. In the 
reference year 2021, the general government budget recorded a deficit of 0.2% of 
GDP, i.e. well below the 3% deficit reference value and close to a balanced budget. 
The general government debt ratio was 36.7% of GDP, i.e. well below the 60% 
reference value (Table 5.7.2). Compared with the previous year, the deficit decreased 
by 2.5 percentage points of GDP and the debt ratio declined notably by 2.9 percentage 
points. With regard to other fiscal factors, the deficit ratio did not exceed the ratio of 
public investment to GDP in 2021. The budget entered into deficit territory in 2020 and 
2021 due to the economic impact of the COVID-19 pandemic and the fiscal policy 
measures taken in response to it. 
Sweden is currently subject to the preventive arm of the Stability and Growth 
Pact. Sweden has never been subject to an ECOFIN Council decision on the 
existence of an excessive deficit. The European Commission’s Spring 2022 Economic 
Forecast assessed that the structural balance remained within the medium-term 
objective in 2021. 
Both cyclical and non-cyclical factors relating to the COVID-19 pandemic 
contributed to the deterioration in the budget balance over the period 2019-21. 
After structural surpluses were recorded from 2016 until 2019, the European 
Commission’s estimates (Table 5.7.2) indicate that the structural balance deteriorated 
by 0.8 percentage points in 2020, mostly on account of higher expenditure due to the 
policy response to the COVID-19 crisis. Cyclical factors also contributed to the overall 
increase in the budget deficit by 3.3 percentage points in 2020. From 2020 to 2021, 
the structural balance returned to surplus territory, reaching 0.5% of GDP, and the 
cyclical component improved by 1.6 percentage points. 
Despite the COVID-19 crisis, the government debt-to-GDP ratio has remained 
well below the 60% reference value over the past few years. From 2017 to 2019, 
the debt ratio in Sweden had decreased steadily, moving from 40.7% to 34.9% of 
GDP, mostly owing to primary surpluses and favourable interest-growth differentials. 
However, the response to the pandemic pushed this ratio up again to 39.6% in 2020, 
on the back of a primary deficit and an unfavourable interest-growth differential. This 
course was already reversed in 2021, with the government debt ratio decreasing to 
36.7% of GDP (Table 5.7.2). 
Sweden’s government debt structure shows that fiscal balances are relatively 
sensitive to interest rate fluctuations, but relatively insensitive to exchange rate 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 359 – 
Convergence Report, June 2022 161 
fluctuations. The share of government debt with a short-term maturity is relatively 
high (24.9% in 2021 – Table 5.7.2). Taking into account the share of debt with a 
variable interest rate and the level of the debt ratio, fiscal balances are relatively 
sensitive to changes in interest rates. Moreover, the proportion of government debt 
denominated in foreign currency is noticeable (17.3% in 2021). However, taking the 
small size of foreign currency-denominated debt as a percentage of GDP into 
consideration, this leaves fiscal balances relatively insensitive to exchange rate 
movements. 
The European Commission’s Spring 2022 Economic Forecast predicts a slight 
deterioration in the budget balance for 2022, followed by an improvement in 
2023, and a notable decrease in the public debt ratio. According to the 
Commission’s latest forecast, the budget balance is expected to slightly deteriorate to 
a deficit of 0.5% of GDP in 2022, before improving to a surplus of 0.5% of GDP in 
2023, thus remaining well below the reference value of a deficit of 3% in 2022 and 
being in surplus in 2023. The expected moderate deterioration in the general 
government balance in 2022 stems from the fiscal measures implemented to mitigate 
the effects of the pandemic, the surge in inflation, and the consequences of the 
Russian invasion of Ukraine. In 2022 and 2023, the structural deficit is expected to 
remain within the medium-term objective (a structural deficit of 1% of GDP). The 
government debt ratio is projected to decrease notably in the coming years to 33.8% 
of GDP in 2022 and 30.5% of GDP in 2023, thus remaining well below the 60% 
reference value. The projected budget balance developments and debt ratios for 2022 
and 2023 presented in Sweden’s 2022 convergence programme are close to those 
shown in the European Commission’s Spring 2022 Economic Forecast. 
Sweden has a strong fiscal governance framework. Following the last revision of 
the fiscal framework, which entered into force in 2019, the general government surplus 
target is now ⅓% of GDP over the business cycle. This target is much more ambitious 
than the structural balance targets of the EU fiscal framework. In addition, a debt 
anchor was introduced into the fiscal framework in 2019, targeting a debt ratio of 35% 
(Maastricht definition). A deviation from the debt anchor by 5 percentage points or 
more in either direction requires the government to submit a report to Parliament 
explaining the causes of the deviation and presenting an action plan to address it. The 
debt level of 35% leaves a significant safety margin to the Maastricht reference value 
of 60% of GDP. The Swedish fiscal framework also includes a three-year rolling 
nominal expenditure ceiling for central government and the pension system, and a 
balanced budget requirement for local governments. Overall, the national fiscal 
framework is strong and compliance with the revised surplus target would support the 
medium-term sustainability of public finances in line with the requirements of the 
Stability and Growth Pact. 
Sweden faces low risks to the sustainability of public finances over the medium 
and long term. The analysis laid out in the European Commission’s 2021 Fiscal 
Sustainability Report points to low risks over the medium197 and long term.198 This 
197  This assessment was confirmed by the updated debt sustainability analysis which was published as part
of the European Commission’s country report for Sweden on 23 May 2022.
198  However, this assessment does not necessarily reflect the uncertainty surrounding the long-term 
assumptions.
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162 
positive assessment stemmed largely from a favourable initial budgetary position that 
partly mitigates the projected increase in ageing-related costs, as well as low 
government debt. A notable increase in age-related public expenditure by 2.3 
percentage points of GDP is expected over the period 2019-70 according to the 
reference scenario from the 2021 Ageing Report prepared by the Ageing Working 
Group (AWG) of the EU’s Economic Policy Committee,199 from a level of 24.1% of 
GDP in 2019. This rise is mainly driven by long-term care costs. Under the AWG’s risk 
scenario, the increase in the cost of ageing amounted to 7.2 percentage points of 
GDP, which is above the EU average. 
Looking ahead, Sweden should build on its strong track record and comply 
with the requirements of the preventive arm of the Stability and Growth Pact. 
While fiscal policy should remain agile in its response to the evolving pandemic 
situation and given the geopolitical situation, Sweden should continue to anchor sound 
public finances in its rule-based fiscal framework, which would be supported by 
compliance with its target of a budget surplus, on average, over the business cycle, 
thus ensuring compliance with its medium-term objective in the years to come. 
5.7.3 Exchange rate developments 
In the two-year reference period from 26 May 2020 to 25 May 2022, the Swedish 
krona did not participate in ERM II, but traded under a flexible exchange rate 
regime. Over the reference period the Swedish currency mostly traded significantly 
above its May 2020 average exchange rate against the euro of 10.5970 kronor per 
euro, which is used as a benchmark for illustrative purposes in the absence of an ERM 
II central rate (Chart 5.7.3). The maximum upward deviation from this benchmark was 
6.6%, while the maximum downward deviation amounted to 2.7%. On 25 May 2022 
the exchange rate stood at 10.5419 kronor per euro, i.e. 0.5% stronger than its 
average level in May 2020. Over the reference period Sveriges Riksbank maintained a 
swap agreement with the ECB for borrowing up to €10 billion in exchange for Swedish 
kronor, which had been in place since 20 December 2007 with the aim of facilitating 
the functioning of financial markets and providing euro liquidity to them if needed. As 
this agreement helped to reduce the potential risk of financial vulnerabilities, it might 
also have had an impact on the exchange rate of the Swedish krona against the euro 
over the reference period. Over the past ten years the exchange rate of the Swedish 
krona against the euro has depreciated by 17.2%. 
The exchange rate of the Swedish krona against the euro exhibited, on average, 
a relatively high degree of volatility over the two-year reference period. Overall, 
the krona steadily strengthened against the euro in 2020, supported by the relative 
resilience of the Swedish economy in the context of the COVID-19 pandemic. During 
2021 the exchange rate of the krona remained broadly stable, fluctuating around a 
level of about 10.2 kronor per euro. Towards the end of the year it appreciated 
temporarily, then weakened again and in early 2022 it stood at a level of 10.3 kronor 
 
199  European Commission and Economic Policy Committee, “The 2021 Ageing Report: Economic &amp; 
Budgetary Projections for the EU Member States (2019-2070)”, European Economy Institutional Paper, 
No 148, European Commission, 2021. 
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163 
per euro. The exchange rate of the krona further depreciated following the 
disturbances in foreign exchange markets after Russia’s invasion of Ukraine, before 
appreciating again from early March 2022 to reach a level of around 10.3 kronor per 
euro at the end of the reference period. During the reference period short-term interest 
rate differentials against the three-month EURIBOR were overall modest and stood at 
0.5 percentage points in the three-month period ending in March 2022. 
The real effective exchange rate of the Swedish krona has depreciated over the 
past ten years (Chart 5.7.4). 
Over the past ten years Sweden has recorded relatively large current account 
surpluses and since 2018 its net international investment position has been 
significantly positive (Table 5.7.3). In 2021 the surplus in the combined current and 
capital account of the balance of payments stood at 5.7% of GDP, reflecting surpluses 
in the goods and primary income balances. The corresponding net capital outflows in 
the financial account were mainly in direct investment and other investment. Gross 
external debt, which is concentrated in monetary and financial institutions, stood at 
173.3% of GDP in 2021. Over the past ten years Sweden has recorded a slightly 
positive net international investment position on average. Indeed, since 2018 its net 
international investment position has turned positive, reaching 17.8% of GDP in 2021. 
The Swedish economy is well integrated with the euro area through trade and 
investment linkages. In 2021 exports of goods and services to the euro area 
constituted 46.6% of total exports, while the corresponding figure for imports was 
lower, at 42.2%. In the same year the share of the euro area in Sweden’s stock of 
inward direct investment stood at 56.2% and its share in the country’s stock of portfolio 
investment liabilities was 43.7%. The share of Sweden’s stock of foreign assets 
invested in the euro area amounted to 38.7% in the case of direct investment and 
33.9% for portfolio investment in 2021. 
5.7.4 Long-term interest rate developments 
Over the reference period from May 2021 to April 2022, long-term interest rates 
in Sweden stood at a slightly positive level of 0.4% on average and thus 
remained well below the 2.6% reference value for the interest rate convergence 
criterion (Chart 5.7.5). 
Long-term interest rates in Sweden have been on a downward path since 2012, 
falling from around 2% to 1.5% at the end of the reference period. After a period 
of gradual but moderate increases in 2012-13, owing to high levels of risk appetite and 
a gradual shift from safe to risky assets, long-term interest rates declined by more than 
200 basis points until March 2015. Since then long-term interest rates in Sweden have 
moved broadly in line with the domestic economic cycle and global developments. 
After increasing moderately over the period 2016-18 owing to the recovery of 
economic growth and inflation, long-term interest rates in Sweden followed the global 
downward trend in 2019 and fluctuated around 0% until the end of 2020, with 
temporary periods in which they turned slightly negative. In response to the COVID-19 
pandemic, in 2020 Sveriges Riksbank announced, among other measures, an 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 362 – 
 
Convergence Report, June 2022 
 
164 
increase in the envelope of its quantitative easing programme until the end of 2021. 
The programme includes government and corporate bonds as well as commercial 
paper purchases and aims to counteract the negative economic effects of the 
pandemic, ensure loose financing conditions and foster market functionality. The repo 
rate was set to 0% in August 2020, 50 basis points above its lowest level, which was 
set in February 2016. Sveriges Riksbank’s monetary policy stance remained 
accommodative from August 2020 to April 2022, thus helping to dampen the upward 
pressure on Swedish long-term interest rates stemming from the recovery of the 
global economy and the upturn in inflation and inflation expectations. At the end of 
April 2022 the central bank announced an increase in its repo rate to 0.25% and the 
inauguration of a tightening cycle amid rising and persistent inflation and with the 
objective of preventing the high inflation from becoming entrenched in price and 
wage-setting. As a result, the long-term interest rate stood at 1.5% in April 2022. 
Sweden’s government debt is rated at the top investment-grade notch by all three 
main rating agencies. 
Sweden’s long-term interest rate differential vis-à-vis the highest-rated euro 
area countries is very small. As a result of its sound fiscal policy and its balanced 
and healthy economy, Sweden enjoys the same credibility as the highest rated euro 
area countries. Historically, the interest rate differential vis-à-vis the euro area average 
was negative, albeit quite small. However, in the last quarter of 2020 it turned slightly 
positive and remained so until April 2022, when it stood at 10 basis points. The 
differential vis-à-vis the best-rated euro area government bonds was 50 basis points. 
Capital markets in Sweden are highly developed, with corporate bond issuance 
and stock market capitalisation accounting for a higher percentage of GDP than 
in the euro area (Table 5.7.4). Relative to GDP, outstanding amounts of debt 
securities issued by non-financial corporations in Sweden are over twice those in the 
euro area. The size of the Swedish stock market, as a percentage of GDP, is also 
more than twice that of the euro area. Sweden’s banks tend to fund their activities by 
borrowing from euro area banks only to a limited extent. Claims of euro area MFIs 
accounted for 8.7% of Swedish banks’ total liabilities in 2021. The degree of financial 
intermediation in Sweden is high. At the end of 2021 bank credit to the private sector 
amounted to 140.3% of GDP, much higher than the corresponding figure in the euro 
area of 111.1%. 
  
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 363 – 
Sweden - Price developments
S 1 ECB Convergence Report, May 2022 
Chart 5.7.1 HICP inflation and reference value 1) 
(annual percentage changes)
-1
0
1
2
3
4
5
6
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
-1
0
1
2
3
4
5
6
HICP
HICP (12-month moving average)
Reference value
Sources: European Commission (Eurostat) and ECB calculations.
1) The basis of the calculation of the reference value for the period from May 2021 to April 2022 is the unweighted arithmetic average of the annual percentage
changes in the HICP for France, Finland and Greece plus 1.5 percentage points. The reference value is 4.9%.
Table 5.7.1 Measures of inflation and related indicators
(annual percentage changes, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Measures of inflation
 HICP 1.2 0.7 1.8 1.9 2.0 1.7 0.7 2.7 5.3 3.0
HICP excluding unprocessed food and energy 1.2 0.8 1.5 1.5 1.2 1.6 1.5 1.6 4.1 3.0
HICP at constant tax rates 3) 1.2 0.7 1.7 1.7 1.8 1.6 0.6 2.6 - -
 CPI 1.0 0.3 1.6 1.8 2.0 1.8 0.5 2.2 5.7 4.0
Private consumption deflator 1.3 0.8 1.9 1.8 2.5 2.1 1.1 1.9 5.7 4.0
 GDP deflator 1.9 1.5 2.4 2.1 2.4 2.5 1.8 3.0 4.3 3.9
 Producer prices 4) 1.8 -0.4 4.1 4.1 5.5 2.7 -2.2 11.0 - -
 Related indicators
Real GDP growth 1.8 1.9 1.6 2.6 2.0 2.0 -2.9 4.8 2.3 1.4
GDP per capita in PPS 5) (euro area = 100) 116.3 118.4 113.6 113.7 112.4 111.9 116.6 . - -
Comparative price levels (euro area = 100) 121.7 123.9 119.0 124.5 118.4 116.7 116.3 . - -
 Output gap 6) -0.9 -1.0 -0.8 0.7 0.5 0.4 -4.2 -1.4 -0.8 -1.2
Unemployment rate (%) 7) 7.7 7.8 7.5 6.8 6.5 7.0 8.5 8.8 7.8 7.0
Unit labour costs, whole economy 2.1 1.9 2.4 1.9 3.5 1.5 4.3 0.8 2.6 3.2
Compensation per employee, whole economy 2.8 2.5 3.1 2.1 3.8 3.0 2.5 4.3 2.7 3.7
Labour productivity, whole economy 0.7 0.7 0.7 0.1 0.3 1.4 -1.7 3.5 0.1 0.5
Imports of goods and services deflator 0.9 -0.5 2.3 4.0 6.0 2.8 -4.2 3.4 12.2 5.1
Nominal effective exchange rate 8) -0.8 -1.1 -0.5 -0.8 -4.2 -3.7 3.1 3.5 - -
Money supply (M3) 9) 7.2 5.1 9.3 8.5 3.0 7.5 19.2 8.9 - -
Lending from banks 10) 5.2 4.9 5.6 6.9 4.7 5.2 4.5 6.5 - -
Stock prices (OMXS30) 11) 144.9 53.6 59.5 3.9 -10.7 25.8 5.8 29.1 - -
Residential property prices 5.9 7.4 4.4 6.6 -0.9 2.5 4.2 10.2 - -
Sources: European Commission (Eurostat, Directorate-General for Economic and Financial Affairs), national data for CPI, money supply, lending from banks
and ECB calculations based on Refinitiv data for stock prices.
1) Multi-annual averages calculated using the geometric mean, except for GDP per capita in PPS, comparative price levels, output gap and unemployment rate, for which the
arithmetic mean is used.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) The difference between the HICP and the HICP at constant tax rates shows the theoretical impact of changes in indirect taxes (e.g. VAT and excise duties) on the overall rate
of inflation. This impact assumes a full and instantaneous pass-through of tax rate changes to the price paid by the consumer.
4) Domestic sales, total industry excluding construction.
5) PPS stands for purchasing power standards.
6) Percentage difference from potential GDP: a positive (negative) sign indicates that actual GDP is above (below) potential GDP.
7) Definition conforms to International Labor Organization guidelines.
8) EER-42 group of trading partners. A positive (negative) sign indicates an appreciation (depreciation).
9) The series includes repurchase agreements with central counterparties.
10) Adjusted for the derecognition of loans from the MFI statistical balance sheet due to their sale or securitisation.
11) Multi-annual and annual figures represent the percentage change between the end of the given period and the end of the previous period.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 364 –
Sweden - Fiscal developments
S 2 ECB Convergence Report, May 2022 
Chart 5.7.2 General government balance and debt
(as a percentage of GDP)
-11
-9
-7
-5
-3
-1
1
3
5
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
30
40
50
60
70
80
90
Government balance (left-hand scale)
Government debt (right-hand scale)
Reference values (government balance: -3%; government debt: 60%)
Sources: European System of Central Banks and European Commission (Eurostat).
Table 5.7.2 Government budgetary developments and projections
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Government balance -0.3 -0.6 0.0 1.4 0.8 0.6 -2.7 -0.2 -0.5 0.5
 Total revenue 50.0 49.9 50.2 50.6 50.7 49.7 49.9 50.0 48.7 47.7
 Current revenue 49.7 49.5 49.9 50.4 50.4 49.5 49.6 49.6 48.3 47.3
 Direct taxes 18.2 18.0 18.5 19.0 18.6 18.1 18.4 18.4 17.9 17.7
 Indirect taxes 21.9 21.8 22.0 22.3 22.3 21.9 21.7 21.9 21.8 21.7
Net social contributions 3.3 3.3 3.4 3.3 3.4 3.4 3.4 3.4 3.0 2.9
Other current revenue 3) 6.2 6.4 6.0 5.9 6.1 6.1 6.1 5.9 5.6 5.1
 Capital revenue 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.4
 Total expenditure 50.3 50.5 50.2 49.2 49.8 49.1 52.6 50.2 49.1 47.2
 Current expenditure 45.5 45.9 45.1 44.5 44.7 44.0 47.2 45.1 44.0 42.2
Compensation of employees 12.7 12.6 12.7 12.6 12.7 12.6 13.1 12.7 12.0 11.8
 Social benefits 16.6 17.1 16.1 16.5 16.2 15.8 16.5 15.8 15.5 15.3
 Interest payable 0.5 0.7 0.4 0.4 0.5 0.4 0.3 0.2 0.1 0.2
Other current expenditure 4) 15.7 15.5 15.8 14.9 15.4 15.2 17.3 16.4 16.4 14.8
 Capital expenditure 4.8 4.6 5.1 4.7 5.1 5.1 5.4 5.1 5.1 5.0
 of which: Investment 4.6 4.4 4.8 4.6 4.9 4.9 5.0 4.8 4.8 4.8
Cyclically adjusted balance 0.2 -0.1 0.4 1.0 0.6 0.4 -0.4 0.5 0.0 1.2
One-off and temporary measures 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
 Structural balance 5) 0.2 -0.1 0.4 1.0 0.6 0.4 -0.4 0.5 0.0 1.2
 Government debt 40.0 41.8 38.2 40.7 38.9 34.9 39.6 36.7 33.8 30.5
Average residual maturity (in years) - - - - - - - - . .
In foreign currencies (% of total) 22.8 24.4 21.2 23.4 24.6 21.8 18.6 17.3 . .
 of which: Euro 9.1 8.9 9.3 8.8 9.7 10.0 9.1 8.7 . .
Domestic ownership (% of total) 70.4 64.0 76.8 76.9 76.1 73.6 76.5 80.9 . .
Medium and long-term maturity (% of total) 6) 74.5 73.4 75.6 74.7 79.3 79.4 69.4 75.1 . .
  of which: Variable interest rate (% of total) 11.1 11.7 10.5 10.6 11.3 10.9 9.0 10.5 . .
 Deficit-debt adjustment 1.1 1.8 0.4 1.8 0.7 -1.7 1.6 -0.3 . .
Net acquisitions of main financial assets 1.0 1.5 0.5 2.9 -1.3 -2.0 3.2 -0.3 . .
Currency and deposits 0.2 0.3 0.1 0.5 -0.2 -0.3 1.1 -0.4 . .
 Debt securities 0.3 0.4 0.2 2.7 -1.1 -0.7 -0.6 0.7 . .
 Loans 0.6 1.2 0.1 0.3 0.6 -0.9 1.0 -0.5 . .
Equity and investment fund shares or units -0.2 -0.5 0.1 -0.6 -0.6 -0.1 1.7 -0.1 . .
Revaluation effects on debt 0.3 0.5 0.1 -0.2 0.8 0.3 -0.4 0.2 . .
 of which: Foreign exchange holding
 gains/losses 0.2 0.4 0.0 -0.4 0.6 0.2 -0.5 0.2 . .
 Other 7) -0.2 -0.1 -0.2 -0.9 1.2 -0.1 -1.1 -0.2 . .
 Convergence programme: government balance - - - - - - - - -0.5 0.7
 Convergence programme: structural balance - - - - - - - - -0.4 0.5
 Convergence programme: government debt - - - - - - - - 33.5 30.7
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast, except for convergence programme data.
3) Sales and other current revenue.
4) Intermediate consumption, subsidies payable and other current expenditure.
5) Cyclically adjusted balance excluding one-off and other temporary measures.
6) Original maturity of more than one year.
7) Time of recording differences and other factors (sector reclassifications and statistical discrepancies).
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 365 –
Sweden - Exchange rate and external developments
S 3 ECB Convergence Report, May 2022 
Chart 5.7.3 Bilateral exchange rate and short-term
interest rate differential
Chart 5.7.4 Effective exchange rates 1) 
(EER-42 group of trading partners; monthly averages; index: Q1 1999 = 100)
(SEK/EUR exchange rate: monthly averages;
difference between three-month interbank interest rates
and three-month EURIBOR: basis points, monthly values)
11.0
10.4
9.8
9.2
8.6
8.0
2012 2014 2016 2018 2020
-0.5
0.0
0.5
1.0
1.5
2.0
SEK/EUR exchange rate (left-hand scale)
Interest rate differential (right-hand scale)
85
91
97
103
109
115
2012 2014 2016 2018 2020
75
81
87
93
99
105
Nominal (left-hand scale)
Real (right-hand scale)
Sources: National data and ECB calculations. Source: ECB.
1) The real EER-42 is CPI-deflated. An increase (decrease) in the EER indicates
an appreciation (depreciation).
Table 5.7.3 External developments
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2017 2018 2019 2020 2021 2022 2) 2023 2)
 Balance of payments
Current account and capital account balance 3) 4.3 4.0 4.6 2.9 2.8 5.5 6.1 5.7 5.0 5.9
Current account balance 4.3 4.1 4.5 3.0 2.7 5.5 6.1 5.5 4.8 5.8
 Goods 3.1 2.8 3.4 2.1 2.0 3.9 4.6 4.5 . .
 Services 0.9 1.5 0.3 0.6 0.3 0.6 0.0 -0.1 . .
 Primary income 2.1 1.5 2.6 1.7 2.0 2.9 3.5 3.0 . .
 Secondary income -1.7 -1.6 -1.8 -1.5 -1.6 -1.9 -2.1 -1.9 . .
Capital account balance 0.0 -0.1 0.1 0.0 0.0 0.0 0.1 0.2 . .
Combined direct and portfolio investment balance 3) 1.4 -0.6 3.3 3.2 0.7 3.5 3.2 6.0 . .
 Direct investment 1.2 1.2 1.3 2.7 2.6 1.3 0.9 -1.1 . .
 Portfolio investment 0.1 -1.8 2.0 0.5 -1.8 2.2 2.3 7.1 . .
Other investment balance 0.9 1.5 0.4 2.2 -0.1 1.4 2.2 -3.7 . .
 Reserve assets 0.4 0.7 0.0 0.1 -0.1 -1.2 0.1 1.0 . .
Exports of goods and services 44.8 43.8 45.8 43.8 45.8 48.2 44.8 46.6 . .
Imports of goods and services 40.8 39.6 42.1 41.1 43.5 43.8 40.2 42.2 . .
Net international investment position 4) 0.9 -9.3 11.1 -0.9 8.1 16.2 14.1 17.8 . .
Gross external debt 4) 178.2 184.3 172.1 181.8 172.9 167.0 165.6 173.3 . .
 Trade with the euro area 5)
Exports of goods and services 39.5 39.8 39.2 40.7 40.4 38.5 38.1 38.4 . .
 Imports of goods and services 48.9 48.4 49.4 49.5 48.9 49.1 49.8 49.9 . .
 Investment position with the euro area 5)
Direct investment assets 4) 47.3 48.9 45.8 47.8 46.4 46.2 44.8 43.7 . .
Direct investment liabilities 4) 56.9 57.6 56.1 57.6 56.8 55.4 54.7 56.2 . .
Portfolio investment assets 4) 36.1 37.1 35.2 36.4 36.1 34.7 34.8 33.9 . .
Portfolio investment liabilities 4) 40.2 38.0 42.5 41.2 44.2 43.9 44.3 38.7 . .
Sources: European System of Central Banks and European Commission (Eurostat, Directorate-General for Economic and Financial Affairs).
1) Multi-annual averages calculated using the arithmetic mean.
2) Data from the European Commission’s Spring 2022 Economic Forecast.
3) Differences between totals and the sum of their components are due to rounding.
4) End-of-period outstanding amounts.
5) As a percentage of the total.
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 366 –
Sweden - Long-term interest rate developments
S 4 ECB Convergence Report, May 2022 
Chart 5.7.5 Long-term interest rate 1) 
(monthly averages in percentages)
Chart 5.7.6 Long-term interest rate and HICP inflation
differentials vis-à-vis the euro area
(monthly averages in percentage points)
-1
0
1
2
3
2012 2014 2016 2018 2020
-1
0
1
2
3
Long-term interest rate
Long-term interest rate (12-month moving average)
Reference value
-3
-2
-1
0
1
2
2012 2014 2016 2018 2020
-3
-2
-1
0
1
2
Long-term interest rate differential
HICP inflation differential
Sources: European System of Central Banks and ECB calculations.
1) The basis of the calculation of the reference value for the period from May
2021 to April 2022 is the unweighted arithmetic average of the interest rate
levels in France, Finland and Greece plus 2 percentage points. The reference
value is 2.6%.
Sources: European System of Central Banks, ECB calculations and European
Commission (Eurostat).
Table 5.7.4 Long-term interest rates and indicators of financial development and integration
(as a percentage of GDP, unless otherwise indicated)
2012-2021 1) 2012-2016 1) 2017-2021 1) 2018 2019 2020 2021 May. 2021 Memo item:
to euro area
Apr. 2022 2021
 Long-term interest rates
 Sweden 2) 0.8 1.3 0.3 0.7 0.0 0.0 0.3 0.4 -
 Euro area 3), 4) 1.4 2.2 0.6 1.1 0.4 0.1 0.1 0.4 -
Euro area AAA par curve, ten-year residual maturity 2), 4) 0.6 1.2 0.0 0.5 -0.2 -0.4 -0.3 -0.1 -
 Indicators of financial development and integration
Debt securities issued by financial corporations 5) 103.5 109.6 97.5 93.3 95.0 99.9 94.8 - 66.7
Debt securities issued by non-financial corporations 6) 23.2 19.6 26.8 24.8 27.3 28.7 29.5 - 13.4
Stock market capitalisation 7) 141.4 121.9 160.9 115.5 146.7 175.2 229.2 - 77.7
MFI credit to non-government residents 8) 133.4 129.5 137.4 134.9 134.8 142.2 140.3 - 111.1
Claims of euro area MFIs on resident MFIs 9) 8.7 8.5 8.9 9.5 9.3 8.9 8.7 - 29.5
Sources: European System of Central Banks and ECB calculations.
1) Multi-annual averages calculated using the arithmetic mean.
2) Average interest rate.
3) GDP-weighted average of the euro area long-term interest rates for the purpose of assessing convergence.
4) Included for information only.
5) Outstanding amount of debt securities issued by resident MFIs (excluding the national central bank) and other financial corporations.
6) Outstanding amount of debt securities issued by resident non-financial corporations.
7) Outstanding amount of listed shares issued by residents at market values.
8) MFI (excluding national central bank) credit to domestic non-MFI residents other than general government. Credit comprises outstanding amounts of loans and debt securities.
9) Outstanding amount of deposits and debt securities issued by domestic MFIs (excluding the national central bank) held by euro area MFIs as a percentage of total liabilities 
of domestic MFIs (excluding the national central bank). Total liabilities exclude capital and reserves and remaining liabilities.
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 367 – 
 
Convergence Report, June 2022 
 
169 
6 Statistical methodology of convergence 
indicators 
The examination of the convergence process is highly dependent on the quality 
and integrity of the underlying statistics; the compilation and reporting of 
statistics, particularly government finance statistics (GFS), must not be subject 
to any political or other external interference. Member States are invited to 
consider the quality and integrity of their statistics as a matter of priority, to ensure that 
a proper system of checks and balances is in place when compiling these statistics 
and to apply high standards with respect to governance and quality in the domain of 
statistics. 
National statistical authorities in each Member State and the EU statistical 
authority within the European Commission (Eurostat) should enjoy 
professional independence and ensure that European statistics are impartial 
and of a high quality. This is in line with the principles laid down in Article 338(2) of 
the Treaty, the Regulation on European statistics200 and the European Statistics Code 
of Practice201. Article 2(1) of the Regulation on European statistics states that the 
development, production and dissemination of European statistics shall be governed 
by the following statistical principles: a) professional independence, b) impartiality, 
c) objectivity, d) reliability, e) statistical confidentiality, and f) cost effectiveness. 
Pursuant to Article 11 of the Regulation, these statistical principles are elaborated 
further in the European Statistics Code of Practice. 
Against this background, this chapter reviews the quality and integrity of the 
convergence indicators in terms of the underlying statistics. It provides 
information on the statistical methodology of the convergence indicators, as well as on 
the compliance of the underlying statistics with the standards necessary for an 
appropriate assessment of the convergence process. 
6.1 Institutional features relating to the quality of statistics for 
the assessment of the convergence process 
The governance of the European Statistical System (ESS) has been 
progressively improved, in particular with the adoption of the European 
 
200  Regulation (EC) No 223/2009 of the European Parliament and of the Council of 11 March 2009 on 
European statistics and repealing Regulation (EC, Euratom) No 1101/2008 of the European Parliament 
and of the Council on the transmission of data subject to statistical confidentiality to the Statistical Office 
of the European Communities, Council Regulation (EC) No 322/97 on Community Statistics, and Council 
Decision 89/382/EEC, Euratom establishing a Committee on the Statistical Programmes of the European 
Communities (OJ L 87, 31.3.2009, p. 164), as amended by Regulation (EU) 2015/759 of the European 
Parliament and of the Council of 29 April 2015 (OJ L 123, 19.5.2015, p.90). 
201  The European Statistics Code of Practice was endorsed by the European Commission in its 
Recommendation of 25 May 2005 on the independence, integrity and accountability of the national and 
Community statistical authorities (COM(2005) 217 final), and revised by the European Statistical System 
Committee in September 2011 and November 2017. 
Drucksache 20/2296 Deutscher Bundestag – 20. Wahlperiode– 368 – 
 
Convergence Report, June 2022 
 
170 
Statistics Code of Practice in 2005. In the specific context of the EU fiscal 
surveillance system and of the excessive deficit procedure (EDP), Council Regulation 
(EU) No 679/2010202 granted Eurostat new competences for the regular monitoring 
and verification of public finance data, which it exercises by conducting more in-depth 
dialogue visits to Member States and by extending such visits to public entities 
supplying upstream public finance data to the national statistical institutes (NSIs). 
Furthermore, the legislative package of six legal texts adopted in 2011 to 
strengthen the economic governance structure of the euro area and the EU as a 
whole requires the compilation of high-quality statistical information, which 
needs to be produced under robust quality management.203 In this context, the 
European Statistics Code of Practice was revised in September 2011 in order to 
distinguish between the principles to be implemented by ESS members and the 
principles relating to the institutional environment that are to be implemented by 
Member State governments. In 2017 it was revised again in order to emphasise that 
the NSIs and Eurostat coordinate all activities involved in the development, production 
and dissemination of European statistics (produced in accordance with the Regulation 
on European statistics204) at the level of their national statistical systems and the ESS 
respectively. 
In 2015 the Regulation on European statistics was amended205 in order to, 
among other things, clarify that the principle of professional independence of 
NSIs applies unconditionally. Statistics must indeed be developed, produced and 
disseminated in an independent manner, free of any pressures from political or 
interest groups or from EU or national authorities, and existing institutional frameworks 
must not be allowed to restrict this principle. 
The independence of other statistical authorities responsible for the 
compilation of European statistics (e.g. ministries of finance) also needs to be 
assured. Other statistical authorities’ responsibility for the publication of statistics 
needs to be clearly identified in order to distinguish statistical releases from political 
statements. In Poland and Romania, the Ministries of Finance compile EDP debt data. 
In Bulgaria, the Ministry of Finance compiles quarterly government debt data, while 
the NSI compiles annual government debt. The institutional responsibilities for the 
 
202  Council Regulation (EU) No 679/2010 of 26 July 2010 amending Regulation (EC) No 479/2009 as 
regards the quality of statistical data in the context of the excessive deficit procedure (OJ L 198, 
30.7.2010, p. 1). 
203  On 13 December 2011 the reinforced Stability and Growth Pact (SGP) entered into force with a new set 
of rules for economic and fiscal surveillance. These measures, known as the “six-pack”, consist of five 
regulations and one directive proposed by the European Commission and approved in October 2010 by 
all 27 Member States at the time and the European Parliament. 
204  European statistics are developed, produced and disseminated by both the ESS and the ESCB but under 
separate legal frameworks reflecting their respective governance structures. The members of the ESCB 
are not involved in the production of European statistics pursuant to the Regulation on European 
statistics. However, with a view to minimising the reporting burden and guaranteeing the coherence 
necessary to produce European statistics, the ESS and the ESCB cooperate closely, while complying 
with the statistical principles set out in Article 2(1) of the Regulation on European statistics. Given that 
some European statistics may be compiled by NCBs in their capacity as members of the ESCB, the NSIs 
and the NCBs also cooperate closely under national arrangements with a view to ensuring the necessary 
cooperation between the ESS and the ESCB and to guaranteeing the production of complete and 
coherent European statistics. 
205  Regulation (EU) 2015/759 of the European Parliament and of the Council of 29 April 2015 amending 
Regulation (EC) No 223/2009 on European statistics (OJ L 123, 19.5.2015, p. 90). 
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compilation of EDP data and GFS in the countries are shown in Table 6.1. In Romania, 
the Law on the organisation and functioning of official statistics includes the principle 
of professional independence and applies to all statistical processes and products. In 
Bulgaria and Poland, although the independence of the compilers at the Ministries of 
Finance is not guaranteed by law, the monitoring and quality assurance of the EDP 
data and GFS compiled by the Ministries of Finance form part of the coordination role 
of the NSI. 
In their letter on ERM II participation dated 4 July 2019, the Croatian authorities 
committed to improving the collection, production and dissemination of 
statistics by strengthening the institutional and methodological capacities in 
relation to the quality of national accounts and GFS/EDP reporting. This included 
specific deliverables, such as the adoption of a new Official Statistics Act to strengthen 
the professional independence of the Head of the NSI and free access to all 
administrative data sources, a new Memorandum of Understanding (signed in 
February 2020) between the compilers of statistics and data providers (the NSI, 
Ministry of Finance and NCB) to improve procedures and the timeliness of data 
exchange, and the adoption of a revision policy for national accounts statistics. In July 
2020 it was confirmed that the Croatian authorities had fulfilled these statistical 
commitments.206 
Table 6.1 
Quality and integrity of convergence statistics 
Bulgaria 
Institutional features relating to the quality and integrity of the statistics used in assessing the convergence process 
Legal independence of the 
national statistical institute 
Under the Law on Statistics, statistics are based on the principles of professional independence, 
impartiality, objectivity, reliability, statistical confidentiality and cost effectiveness. Under Article 8 of 
the Law on Statistics, the President of the NSI is appointed by the Prime Minister. The term of office 
is fixed (seven years; reappointment is possible, only once). 
Administrative supervision 
and budget autonomy 
The NSI has the status of a state agency and is directly subordinated to the Council of Ministers. It 
has budget autonomy on the basis of an annual amount assigned from the state budget. 
Legal mandate for data 
collection 
The Law on Statistics determines the main principles of data collection. 
Legal provisions regarding 
statistical confidentiality 
Under Articles 25 to 27a of the Law on Statistics, the confidentiality of the statistical data is assured. 
HICP inflation 1) 
Compliance with legal 
minimum standards 
Eurostat made a compliance monitoring visit in 2013 and published a report in 2015 confirming that 
the methods used for producing the HICP are satisfactory. A follow-up report outlining the issues 
that had been addressed by Bulgaria was published in 2018. There were no apparent instances of 
non-compliance with the HICP methodology. 
Other issues Eurostat considered the representativeness of the HICP to be generally appropriate. 
Government finance statistics 
Data coverage Revenue, expenditure, deficit and debt data are provided for the period 2012-21. 
Outstanding statistical issues No major outstanding statistical issues identified. Eurostat made an EDP visit in 2021 and 
published the final findings on its website. 
Institution responsible for the 
compilation of statistics 
The NSI compiles the non-financial and annual financial accounts of government, as well as annual 
government debt. The Ministry of Finance compiles quarterly government debt and the NCB 
compiles the quarterly financial accounts of government. 
 
206  See Letter from Executive Vice-President of the European Commission Valdis Dombrovskis and 
Commissioner for the Economy Paolo Gentiloni to ERM II parties, on the assessment of Croatia’s 
implementation of the commitments it undertook before joining ERM II, European Commission, 8 July 
2020, available at: 
https://ec.europa.eu/info/sites/default/files/economy-finance/com_opinion_on_hr_erm-ii.pdf. 
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Czech Republic 
Institutional features relating to the quality and integrity of the statistics used in assessing the convergence process
Legal independence of the 
national statistical institute 
Under Article 5 of the State Statistical Service Act, statistics are based on objectivity, impartiality 
and independence. Under Article 3, the Head of the NSI is appointed by the President of the 
Republic. 
Administrative supervision 
and budget autonomy 
The NSI is a central statistical agency within the public administration. It has budget autonomy on 
the basis of an annual amount assigned from the state budget. 
Legal mandate for data 
collection 
The State Statistical Service Act determines the main principles of data collection.
Legal provisions regarding 
statistical confidentiality 
Under Articles 16, 17 and 18 of the State Statistical Service Act, the confidentiality of the statistical 
data is assured. 
HICP inflation 1) 
Compliance with legal 
minimum standards 
Eurostat made a compliance monitoring visit in 2019 and published a report in January 2020 
confirming that, in general, the methods used for producing the HICP are satisfactory. There were 
no apparent instances of non-compliance with the HICP methodology. 
Other issues Eurostat considered the representativeness of the HICP in terms of accuracy and reliability to be 
generally adequate. 
Government finance statistics
Data coverage Revenue, expenditure, deficit and debt data are provided for the period 2012-21. 
Outstanding statistical issues The sector classification of a new unit (the National Development Fund), which was established in 
2021, is still under discussion. Eurostat made an EDP visit in 2021 and will publish the final findings 
on its website. 
Institution responsible for the 
compilation of statistics 
The NSI compiles the non-financial and financial accounts of government, as well as government 
debt. 
Croatia 
Institutional features relating to the quality and integrity of the statistics used in assessing the convergence process
Legal independence of the 
national statistical institute
Under Article 5 of the Official Statistics Act, statistics are based on the principles of relevance, 
impartiality, reliability, transparency, timeliness, professional independence, cost effectiveness, 
consistency, publicity, statistical confidentiality, the use of individual data for exclusively statistical 
purposes, and public accountability. The Head of the NSI is appointed by the Government and is 
accountable to the Government. 
Administrative supervision 
and budget autonomy 
The NSI is a state administration organisation which performs its tasks autonomously in conformity 
with the law. It has budget autonomy on the basis of an annual amount assigned from the state 
budget. 
Legal mandate for data 
collection 
The Official Statistics Act determines the main principles of data collection.
Legal provisions regarding 
statistical confidentiality 
Under Article 59 of the Official Statistics Act, the confidentiality of the statistical data is assured. 
HICP inflation 1) 
Compliance with legal 
minimum standards 
Eurostat made a compliance monitoring visit in 2015 and published a report in that year confirming 
that, in general, the methods used for producing the HICP are in line with requirements. A follow-up 
report outlining the issues that had been addressed by Croatia was published in 2018. 
Other issues Eurostat considered that comparability with the HICP of other countries can be regarded as 
assured. A follow-up report published in 2018 showed that good progress had been made
regarding the recommendations for further improvements to the Croatian HICP as set out in the 
compliance monitoring report. 
Government finance statistics
Data coverage Revenue, expenditure, deficit and debt data are provided for the period 2012-21. 
Outstanding statistical issues No major outstanding statistical issues identified. Eurostat made an EDP visit in 2021 and will 
publish the final findings on its website. 
Institution responsible for the 
compilation of statistics 
The NSI compiles the non-financial accounts of government. The NCB compiles government debt 
and the financial accounts of government. 
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Hungary 
Institutional features relating to the quality and integrity of the statistics used in assessing the convergence process
Legal independence of the 
national statistical institute 
Under Act CLV of 2016 on Official Statistics, statistics are compiled following the principles of 
objectivity, independence and confidentiality. The Head of the NSI is appointed by the Prime 
Minister. The term of office is fixed (six years; reappointment is possible, only twice). 
Administrative supervision 
and budget autonomy 
The NSI is a public administration under the immediate supervision of the Government. It has 
budget autonomy on the basis of an annual amount assigned from the state budget. 
Legal mandate for data 
collection 
Act XLVI on Statistics determines the main principles of data collection.
Legal provisions regarding 
statistical confidentiality 
Under Article 17 of Act XLVI on Statistics, the confidentiality of the statistical data is assured. 
HICP inflation 1) 
Compliance with legal 
minimum standards 
Eurostat made a compliance monitoring visit in 2019 and published a report in March 2020 
confirming that, in general, the methods used for producing the HICP are satisfactory. Some 
instances of non-compliance with the HICP methodology were identified, but those were
considered by Eurostat to be limited and unlikely to have a major impact in practice on the annual 
average rates of change in the HICP. 
Other issues Eurostat considered the representativeness of the HICP in terms of accuracy and reliability to be 
generally adequate. 
Government finance statistics
Data coverage Revenue, expenditure, deficit and debt data are provided for the period 2012-21. 
Outstanding statistical issues No major outstanding statistical issues identified. Eurostat made an EDP visit in 2021 and 
published the final findings on its website. 
Institution responsible for the 
compilation of statistics 
The NSI compiles the non-financial accounts of government. The NCB compiles government debt 
and the financial accounts of government. 
Poland 
Institutional features relating to the quality and integrity of the statistics used in assessing the convergence process
Legal independence of the 
national statistical institute
Under Article 1 of the Law on Public Statistics, statistics are based on reliability, objectivity and 
transparency. 
The Head of the NSI is selected by open competition and appointed by the President of the Council 
of Ministers. The term of office is fixed (five years). 
Administrative supervision 
and budget autonomy 
The NSI is a central agency within the public administration under supervision of the President of 
the Council of Ministers. It has budget autonomy on the basis of an annual amount assigned from 
the state budget. 
Legal mandate for data 
collection 
The Law on Official Statistics determines the main principles of data collection.
Legal provisions regarding 
statistical confidentiality 
Under Articles 10, 11, 12, 38, 39 and 54 of the Law on Official Statistics, the confidentiality of the 
statistical data is assured. 
HICP inflation 1) 
Compliance with legal 
minimum standards 
Eurostat made a compliance monitoring visit in 2015 and published a report in 2016 confirming that 
the methods used for producing the HICP are of a good standard and in line with legal 
requirements. 
Other issues In the 2016 report, Eurostat made further recommendations for increasing the accuracy and 
reliability of the Polish HICP. A follow-up report issued in 2018 showed that most recommendations
had been implemented or were in the process of being implemented. 
Government finance statistics
Data coverage Revenue, expenditure, deficit and debt data are provided for the period 2012-21. 
Outstanding statistical issues No major outstanding statistical issues identified. Eurostat made an EDP visit in 2020 and 
published the final findings on its website. 
Institution responsible for the 
compilation of statistics 
The NSI compiles the non-financial and financial accounts of government. The Ministry of Finance
compiles government debt. 
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Romania 
Institutional features relating to the quality and integrity of the statistics used in assessing the convergence process
Legal independence of the 
national statistical institute
The autonomy of official statistics is stated in the Statistical Law, together with the principles of 
confidentiality, transparency, reliability, proportionality, statistical deontology and cost/efficiency 
ratio. The Head of the NSI is appointed by the Prime Minister. The term of office is fixed (six years; 
reappointment is possible, only once). 
Administrative supervision 
and budget autonomy 
Under the Statistical Law, the NSI is a specialised institution, subordinated to the Government. It is 
financed via the state budget. 
Legal mandate for data 
collection 
Under the Statistical Law, “the official statistics in Romania are implemented and coordinated by 
the NSI”. 
Legal provisions regarding 
statistical confidentiality 
The Statistical Law states that “during statistical research, from collection to dissemination, the 
official statistics services and statisticians have the obligation to adopt and implement all the 
necessary measures for protecting the data referring to individual statistics subjects (natural or 
legal persons), data obtained directly from statistical research or indirectly through administrative 
sources or from other suppliers”. 
HICP inflation 1) 
Compliance with legal 
minimum standards 
Eurostat made a compliance monitoring visit in 2018 and published a report in February 2020 
confirming that, in general, the methods used for producing the HICP are satisfactory. There were 
no apparent instances of non-compliance with the HICP methodology. 
Other issues Eurostat considered the representativeness of the HICP in terms of accuracy and reliability to be 
generally adequate. 
Government finance statistics
Data coverage Revenue, expenditure, deficit and debt data are provided for the period 2012-21. 
Outstanding statistical issues No major outstanding statistical issues identified. Eurostat made an EDP visit in 2021 and 
published the final findings on its website. 
Institution responsible for the 
compilation of statistics 
The NSI compiles the non-financial accounts of government. The Ministry of Finance compiles 
government debt. The NCB compiles the financial accounts of government. 
Sweden 
Institutional features relating to the quality and integrity of the statistics used in assessing the convergence process
Legal independence of the 
national statistical institute
Under Section 3 of the Official Statistics Act, statistics are objective and available to the public. The 
Head of the NSI is appointed by the Government. The term of office is fixed (six years; three-year
reappointment possible, only once). 
Administrative supervision 
and budget autonomy 
The NSI is a central statistics agency, subordinated to, but not part of, the Ministry of Finance. 
Approximately half of its turnover is provided by the Ministry of Finance, the other half stems from 
charging government agencies and commercial customers for statistical production and advice.
Legal mandate for data 
collection 
The Official Statistics Act determines the main principles of data collection.
Legal provisions regarding 
statistical confidentiality 
Under Sections 5 and 6 of the Official Statistics Act, the confidentiality of the statistical data is 
assured. 
HICP inflation 1) 
Compliance with legal 
minimum standards 
Eurostat made a compliance monitoring visit in 2011 and published a report in 2013 confirming that, 
in general, the methods used for producing the HICP are satisfactory. Some instances of 
non-compliance with the HICP methodology were identified, but those were considered by Eurostat 
to be limited and unlikely to have a major impact in practice on the annual average rates of change 
in the HICP. 
Other issues Eurostat considered the representativeness of the HICP in terms of accuracy and reliability to be 
generally adequate. 
Government finance statistics
Data coverage Revenue, expenditure, deficit and debt data are provided for the period 2012-21. 
Outstanding statistical issues There is a public unit currently classified as an MFI, which may be subject to a reclassification into 
the general government sector. Eurostat made an EDP visit in 2019 and published the final findings 
on its website. 
Institution responsible for the 
compilation of statistics 
The NSI compiles the non-financial and financial accounts of government, as well as government 
debt. 
1) See Eurostat’s website for the full reports on the findings and recommendations of the HICP compliance monitoring visits for each
country. 
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6.2 HICP inflation
This section considers the methodology and quality of the statistics underlying 
the measurement of price developments, specifically the HICP. The HICP was 
developed for the purpose of assessing convergence in terms of price stability on a 
comparable basis. It is published for all EU Member States by Eurostat.207 The HICP 
covering the euro area as a whole has been the main measure of price developments 
for the monetary policy of the ECB since January 1999. 
Article 1 of Protocol (No 13) on the convergence criteria (annexed to the 
Treaties) requires price convergence to be measured by means of the CPI on a 
comparable basis, taking into account differences in national definitions. The 
framework regulation introduced to establish HICPs, Council Regulation (EC) No 
2494/95208, was adopted in October 1995 and subsequently replaced by Regulation 
(EU) 2016/792209, which entered into force in June 2016. The HICPs have also been 
harmonised on the basis of EU Council and European Commission regulations. They 
use common standards for the coverage of the items, the territory and the population 
included (all these elements are major reasons for differences between national 
CPIs). Common standards have also been established in several other areas, for 
example the treatment of new goods and services. 
The HICPs use annually updated expenditure weights (or, until 2011, less 
frequent updates if this did not have a significant effect on the index) and cover 
all goods and services included in household final monetary consumption 
expenditure. The latter is derived from the national accounts domestic concept of 
household final consumption expenditure but excludes owner-occupied housing. The 
prices observed are the prices households actually pay for goods and services in 
monetary transactions and thus include all taxes (minus subsidies) on products, e.g. 
VAT and excise duties. Expenditure on health, education and social services is 
covered to the extent that it is financed (directly or through private insurance) by 
households and not reimbursed by the government. The “HICP – administered prices” 
includes only prices which are directly set or significantly influenced by the 
government, including national regulators. It is based on a common definition and 
compilation, and is published by Eurostat. 
Eurostat must ensure that the statistical practices used to compile national 
HICPs comply with HICP methodological requirements and that good practices 
in the field of consumer price indices are being followed. Eurostat carries out 
compliance monitoring visits and publishes its findings in information notes made 
available on its website. 
207  See Eurostat’s website for details on the HICP legislative framework. Eurostat has also published 
recommendations and a methodological manual.
208  Council Regulation (EC) No 2494/95 of 23 October 1995 concerning harmonized indices of consumer
prices (OJ L 257, 27.10.1995, p. 1).
209  Regulation (EU) 2016/792 of the European Parliament and of the Council of 11 May 2016 on harmonised
indices of consumer prices and the house price index, and repealing Council Regulation (EC) No 
2494/95 (OJ L 135, 24.5.2016, p. 11).
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6.3 Government finance statistics
This section describes the methodology and quality of the statistics used to 
measure fiscal developments. GFS are based mainly on national accounts 
concepts as defined in the ESA 2010210 and Commission Regulation (EU) 
No 220/2014211. They refer to the institutional sector “general government” as defined
in the ESA 2010. This comprises central government, state government (in Member 
States with a federal structure), local government and social security funds. It typically 
does not include public corporations. 
The general government deficit (−)/surplus (+) is equal to the ESA 2010 item 
“net lending (+)/net borrowing (−)”, which in turn is equal to “total revenue” 
minus “total expenditure”. The primary government deficit/surplus is the 
government deficit/surplus excluding interest expenditure. 
The general government debt is the sum of the outstanding gross liabilities at 
nominal value (face value) in currency and deposits, debt securities (e.g. 
government bills, notes and bonds) and loans. It excludes financial derivatives, 
such as swaps212, as well as trade credits213 and other liabilities not represented by a 
financial document, such as overpaid tax advances. It also excludes contingent 
liabilities, such as government guarantees and pension commitments. While 
government debt is a gross concept in the sense that neither financial nor 
non-financial assets are deducted from liabilities, it is consolidated within the general 
government sector and therefore does not include government debt held by other 
government units. 
Government deficit and debt ratios are expressed as a percentage of GDP at 
current market prices. 
6.3.1 Data source
The NCBs provide the ECB with detailed GFS data under the ECB’s GFS 
Guideline214. Although the Guideline is only legally binding for the euro area NCBs, 
the non-euro area EU NCBs also transmit GFS data to the ECB by the same deadlines 
and using the same procedures. The Guideline lays down requirements for the 
transmission of annual data with detailed breakdowns of annual revenue and 
expenditure and the deficit-debt adjustment. In addition, it requests figures on general 
210  See Regulation (EU) No 549/2013 of the European Parliament and of the Council of 21 May 2013 on the
European system of national and regional accounts in the European Union (OJ L 174, 26.6.2013, p. 1).
211  Commission Regulation (EU) No 220/2014 of 7 March 2014 amending Council Regulation (EC)
No 479/2009 as regards references to the European system of national and regional accounts in the 
European Union (OJ L 69, 8.3.2014, p. 101).
212  However, on the basis of a Eurostat guidance note released in 2008, lump sums received by government
under off-market interest rate swaps are treated as government loans. 
213  A 2012 Eurostat decision stipulates that trade credits that are refinanced without recourse to the original
holder and trade credits that are renegotiated beyond the simple extension of the initial maturity need to 
be reclassified as loans and are thus included in the EDP general government debt.
214  Guideline (EU) 2020/1552 of the European Central Bank of 14 October 2020 amending Guideline 
ECB/2013/23 on government finance statistics (ECB/2020/50) (OJ L 354, 26.10.2020, p. 22).
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government debt with breakdowns by instrument, by initial and residual maturity and 
by holder. 
6.3.2 Methodological issues 
The GFS must comply with the ESA 2010 and reflect decisions and guidelines 
issued by Eurostat for specific cases involving the general government sector. 
The borderline classification cases between the financial, non-financial and general 
government sectors continue to be examined closely by Eurostat and national 
statistical compilers and may lead to further reclassifications and changes in the EDP 
and GFS data. 
In the Czech Republic and Hungary, there are MFIs that are reclassified into the 
general government sector for EDP purposes. These units are classified as part of 
the financial sector in other statistical data compiled by the NCB (e.g. monetary and 
financial statistics, and balance of payments statistics). The resultant discrepancy in 
sector classification between those statistics and GFS is well documented and has 
been made known to users. 
In the Czech Republic, a new unit (the National Development Fund) was 
established in 2021 and licenced by the NCB to act as a self-managed 
investment fund. The sector classification of this unit is still under discussion. 
In Sweden, a public unit is currently classified as part of the financial sector and 
is on the ECB’s list of MFIs but may be reclassified into the general government 
sector subject to the outcome of methodological discussions at the European 
level. 
6.4 Exchange rates 
Article 3 of Protocol (No 13) on the convergence criteria defines what is meant 
by the criterion on participation in the exchange rate mechanism of the 
European Monetary System. The bilateral exchange rates of the Member States’ 
currencies vis-à-vis the euro are daily reference rates recorded by the ECB at 
14:15 CET and published on the ECB’s website.215 Nominal and real effective 
exchange rates (EERs) are constructed by applying trade weights (based on a 
geometric weighting) to the bilateral nominal and real exchange rates of the Member 
States’ currencies vis-à-vis the currencies of 42 trading partners. Both nominal and 
real EER statistics are published by the ECB. 
 
215  Since 1 July 2016 the reference rates have been published at around 16:00 CET (for details see “ECB 
introduces changes to euro foreign exchange reference rates”, press release, ECB, 7 December 2015). 
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6.5 Long-term interest rates 
Article 4 of Protocol (No 13) on the convergence criteria requires interest rates 
to be measured on the basis of long-term government bonds or comparable 
securities, taking into account differences in national definitions. While Article 5 
assigns the responsibility for providing the statistical data for the application of the 
Protocol to the European Commission, the ECB, given its expertise in the area, assists 
in this process by defining representative long-term interest rates and collecting the 
data from the NCBs for transmission to the Commission. This is a continuation of the 
work carried out by the EMI as part of the preparations for Stage Three of EMU in 
close cooperation with the Commission. The conceptual work resulted in the definition 
of seven key features to be considered in the calculation of long-term interest rates, as 
presented in Table 6.2. Long-term interest rates refer to bonds denominated in 
national currency. 
Table 6.2 
Statistical framework for defining long-term interest rates for the purpose of assessing 
convergence 
Concept Recommendation 
Bond issuer The bond should be issued by the central government. 
Maturity As close as possible to ten years’ residual maturity. Any replacement of bonds should minimise 
maturity drift; the structural liquidity of the market must be considered. 
Coupon effects No direct adjustment. 
Taxation Gross of tax. 
Choice of bonds The selected bonds should be sufficiently liquid. This requirement should determine the choice 
between benchmark or sample approaches, depending on national market conditions. 
Yield formula The “redemption yield” formula should be applied. 
Aggregation Where there is more than one bond in the sample, a simple average of the yields should be used to 
produce the representative rate. 
 
6.6 Other factors 
The last paragraph of Article 140(1) of the Treaty states that the reports of the 
European Commission and the ECB shall take account of, in addition to the 
four main criteria, the results of the integration of markets, the situation and 
development of the national balance of payments and an examination of the 
development of unit labour costs and other price indices. Whereas, for the four 
main criteria, Protocol (No 13) stipulates that the Commission will provide the data to 
be used for the assessment of compliance and describes those statistics in more 
detail, it makes no reference to the provision of statistics for these “other factors”. 
With regard to the results of the integration of markets, two sets of indicators 
are used. These are i) statistics on financial development and integration referring to 
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the structure of the financial system,216 and ii) statistics on financial and non-financial 
integration with the euro area.217 
The data covering the structure of the financial system are provided by the 
NCBs. The data underlying the indicators concerning the debt securities issued by 
resident financial corporations (MFIs excluding the national central bank and 
non-monetary financial corporations) and non-financial corporations are reported by 
the respective NCBs in accordance with the methodology set out in Guideline 
ECB/2021/15218. The indicator relating to stock market capitalisation refers to listed 
shares issued by resident corporations following the methodology given in the same 
Guideline. The indicators concerning MFI credit to residents and claims of euro area 
MFIs on resident MFIs are based on available data collected by the ECB as part of the 
MFI balance sheet statistics collection framework. The data are obtained from the 
countries under review and, for the latter indicator, also from the euro area countries 
covered by Regulation (EU) No 2021/379219. Historical data are compiled by the 
relevant NCBs, where appropriate. For the indicators mentioned in this paragraph, the 
statistical data relating to the euro area cover the countries that had adopted the euro 
at the time to which the statistics relate. 
Balance of payments and international investment position statistics are 
compiled in accordance with the concepts and definitions laid down in the sixth 
edition of the IMF’s Balance of Payments and International Investment Position 
Manual (BPM6) and with compilation guidance provided by the ECB and 
Eurostat.220 This Convergence Report examines developments in the current (goods, 
services, primary income and secondary income) and capital accounts; the sum of the 
balances of these two accounts corresponds to the net lending/net borrowing of the 
total economy. In addition, developments in the main components of the financial 
account are presented together with the net international investment position and 
gross external debt of each country. Exports and imports of goods and services are 
presented vis-à-vis both the rest of the world and the euro area countries. Direct and 
portfolio investment assets and liabilities with the euro area are also directly identified. 
Forecasted data are taken from the European Commission’s Economic Forecast.221 
The Convergence Report also looks at the development of unit labour costs and 
other price indices. With regard to producer price indices, these data refer to 
domestic sales of total industry excluding construction. The statistics are collected on 
a harmonised basis under the EU Regulation on European business statistics222. 
216  Debt securities issued by resident corporations, stock market capitalisation, MFI credit to 
non-government residents and claims of euro area MFIs on resident MFIs. 
217  External trade and investment position with the euro area. 
218  Guideline (EU) 2021/834 of the European Central Bank of 26 March 2021 on statistical information to be 
reported on securities issues (ECB/2021/15) (OJ L 208, 11.6.2021, p. 311).
219  Regulation (EU) 2021/379 of the European Central Bank of 22 January 2021 on the balance sheet items
of credit institutions and of the monetary financial institutions sector (recast) (ECB/2021/2) (OJ L 73, 
3.3.2021, p. 16).
220  For further details, see “European Union Balance of Payments and International Investment Position 
statistical sources and methods (“B.o.p. and i.i.p. book”)”, ECB, Frankfurt am Main, 2016.
221  The economic forecasts made by the Directorate-General for Economic and Financial Affairs (DG 
ECFIN) on behalf of the European Commission.
222  Regulation (EU) No 2019/2152 of the European Parliament and of the Council of 27 November 2019 on
European business statistics (OJ L 327, 17.12.2019, p. 1).
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180 
Statistics on unit labour costs (calculated as compensation per employee divided by 
GDP chain-linked volumes per person employed) are derived from data provided 
under the ESA 2010 transmission programme. 
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7 Examination of compatibility of national 
legislation with the Treaties 
The following country assessments report only on those provisions of national 
legislation which the ECB considered to be problematic from the perspective of their 
compatibility with provisions on the independence of NCBs in the Treaty (Article 130) 
and the Statute (Articles 7 and 14.2), provisions on confidentiality (Article 37 of the 
Statute), prohibitions on monetary financing (Article 123 of the Treaty) and privileged 
access (Article 124 of the Treaty), and the single spelling of the euro as required by EU 
law. They also cover the perspective of legal integration of the NCBs into the 
Eurosystem (in particular as regards Articles 12.1 and 14.3 of the Statute).223 
7.1 Bulgaria 
7.1.1 Compatibility of national legislation 
The following legislation forms the legal basis for Българска народна банка 
(Bulgarian National Bank) and its operations: 
• the Bulgarian Constitution,224 
• the Law on Българска народна банка (Bulgarian National Bank) (hereinafter the 
“Law on BNB”).225 
The Law on counter-corruption and unlawfully acquired assets forfeiture (hereinafter 
the “Law on counter-corruption”)226 applies to public office holders. 
There have been several changes in relation to the points identified in the ECB’s 
Convergence Report of June 2020, also addressing some of the recommendations 
made in previous Convergence Reports. 
7.1.2 Independence of the NCB 
With regard to the independence of Българска народна банка (Bulgarian National 
Bank), the Law on BNB and the Law on counter-corruption need to be adapted as set 
out below. 
 
223  According to Section 2.2.2.1 of this Convergence Report. 
224  Constitution of the Republic of Bulgaria, Darjaven vestnik issue 56, 13.7.1991.  
225  Law on Българска народна банка (Bulgarian National Bank), Darjaven vestnik issue 46, 10.6.1997. 
226  Darjaven vestnik issue 7, 19.01.2018. 
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Institutional independence 
Article 44 of the Law on BNB prohibits European Union institutions, bodies, offices or 
agencies, the Council of Ministers or the governments of other EU Member States, as 
well as any other bodies and institutions from giving instructions to Българска 
народна банка (Bulgarian National Bank), the Governor or the members of the 
Governing Council. This provision is in line with Article 130 of the Treaty and Article 7 
of the Statute.227 
Personal independence 
Article 14(1) of the Law on BNB lists the grounds on which members of the Governing 
Council may be relieved from office; it provides that the National Assembly or 
Bulgaria’s President may relieve a member of the Governing Council, including the 
Governor, from office if they no longer fulfil the conditions required for the performance 
of their duties or if they have been found guilty of serious misconduct. Article 14(3) of 
the Law on BNB provides that the decision to relieve the Governor of Българска 
народна банка (Bulgarian National Bank) from office may be referred to the Court of 
Justice of the European Union on the grounds of infringement of the Treaties or of a 
rule of law relating to their application. Article 14 of the Law on BNB therefore complies 
with Article 14.2 of the Statute.228 
The Law on counter-corruption repealed the Law on the prevention of conflicts of 
interests in January 2018. Article 80(1) of the Law on counter-corruption initially 
replicated Article 33(1) of the Law on the prevention of conflicts of interests, providing 
that the ascertainment of a conflict of interests by an enforceable legal act is a ground 
for relieving the Governor, Deputy Governors and the other members of the Governing 
Council of Българска народна банка (Bulgarian National Bank) from office. Thus, the 
Law on counter-corruption specified a ground for relieving an individual from office that 
is in addition to the two grounds contained in Article 14.2 of the Statute. Therefore, the 
Law on counter-corruption was deemed incompatible with the Treaty and the Statute 
and needed to be brought into line with them.229 Article 80(1) of the Law on 
counter-corruption was amended in 2021230 to specify that the ascertainment of a 
conflict of interest by an enforceable instrument is a ground for relieving the Governor, 
Deputy Governors and the other members of the Governing Council of Българска 
народна банка (Bulgarian National Bank) from office, unless otherwise provided for in 
the Constitution or in the Statute. Even though this specification aligns with EU law, 
the ECB suggested to explicitly clarify that the provision of Article 80(1) of the Law on 
counter-corruption must not apply to the Governor, the Deputy Governors and the 
other members of the Governing Council of Българска народна банка (Bulgarian 
National Bank)231 for the sake of legal certainty and transparency. Article 80(2) of the 
Law on counter-corruption provides that the relieve from office must follow the 
 
227  See paragraph 3.2 of Opinion CON/2018/53. 
228  See paragraph 3.1 of Opinion CON/2018/53. 
229  See paragraph 3.1 of Opinion CON/2021/2 as well as Opinion CON/2009/13. 
230  Darjaven vestnik issue 12, 12.02.2021. 
231  See paragraph 3.1 of Opinion CON/2021/2. 
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procedure established in the relevant laws. It is understood that in the case of the 
Governor, Deputy Governors and the other members of the Governing Council of 
Българска народна банка (Bulgarian National Bank) this refers to Article 14(1) of the 
Law on BNB. 
The Law on BNB is silent on the right of national courts to review a decision to dismiss 
any member, other than the Governor, of the decision-making bodies of Българска
народна банка (Bulgarian National Bank), who is involved in the performance of 
ESCB-related tasks. In accordance with general Bulgarian law, as indicated by the 
Supreme Court of Cassation,232 national courts may not annul the decision to dismiss 
any member, other than the Governor, of the decision-making bodies of Българска
народна банка (Bulgarian National Bank), but such national courts may only award 
compensation for the damages caused by the dismissal decision. 
In this regard it must be taken into account that the rationale of personal independence 
is to shield the members of the decision-making bodies of ESCB central banks from 
political interference when exercising the powers conferred upon them by the Treaty 
and the Statute. Therefore, Article 130 of the Treaty, which guarantees the 
independence of members of the decision-making bodies of Българска народна
банка (Bulgarian National Bank), requires that they have access to effective legal 
remedies for cases concerning their dismissal, including – but not limited to – 
compensation. Bulgarian law should thus provide for a remedy capable of annulling 
unlawful decisions to dismiss any member, other than the Governor, of the 
decision-making bodies of Българска народна банка (Bulgarian National Bank). Any 
relevant legislation needs to be amended to ensure consistency with Article 130 of the 
Treaty and the Statute. 
Article 12(1) and (2) of the Law on BNB provide for the National Assembly’s powers to 
elect the Governor and the Deputy Governors of Българска народна банка
(Bulgarian National Bank). In 2009, the National Assembly claimed and acted upon 
the claim that it has the power to annul or amend its previous decisions, including 
decisions concerning the election of the Governor and Deputy Governors of 
Българска народна банка (Bulgarian National Bank) taken under Article 12(1) and 
(2) of the Law on BNB. In practice, any proper election or appointment of members of
an NCB’s decision-making body should enable them to assume office following their
election. Once elected or appointed, the Governor and the other members of the
Governing Council of Българска народна банка (Bulgarian National Bank) may not 
be relieved from office under conditions other than those mentioned in Article 14.2 of 
the Statute, even if they have not yet taken up their duties. 
7.1.3 Confidentiality
Article 4(2) of the Law on BNB provides that Българска народна банка (Bulgarian 
National Bank) may not disclose or transmit to other persons any information it 
obtained that constitutes a banking, professional, commercial or other legally 
protected secret for the banks and the other participants in monetary and credit 
232  Order of the Supreme Court of Cassation No 541 of 17 December 2019 in civil case No 2980/2019.
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transactions, except in two cases: (i) exchange of information within the framework of 
the close cooperation established with the ECB under Article 7 of Council Regulation 
(EU) No 1024/2013;233 and (ii) exchange of information with the Single Resolution 
Board in accordance with Regulation (EU) No 806/2014.234 Article 23(2) of the Law on 
BNB provides that the employees of Българска народна банка (Bulgarian National 
Bank) shall observe secrecy requirements concerning negotiations, deals contracted, 
the amount of assets on customers’ deposits and their transactions, and information 
received by the Bank, as well as any circumstances concerning the activities of the 
Bank and its customers, which constitute business, banking, professional, commercial 
or other legally protected secrets, even after termination of their employment contract. 
Under Article 37 of the Statute, professional secrecy is an ESCB-wide matter. 
Therefore, the ECB assumes that Articles 4(2) and 23(2) of the Law on BNB are 
without prejudice to the confidentiality obligations towards the ECB and the ESCB. 
7.1.4 Monetary financing and privileged access
Article 45(1) of the Law on BNB provides that Българска народна банка (Bulgarian 
National Bank) may not extend credit or guarantees in any form whatsoever to, or 
purchase debt instruments directly from, the Council of Ministers, municipalities, other 
government or municipal institutions, organisations or undertakings in the public 
sector, European Union institutions, bodies, offices or agencies, the central 
government, regional, local or other public authorities, other bodies governed by 
public law or public sector entities of EU Member States. Article 45(3) of the Law on 
BNB provides that Българска народна банка (Bulgarian National Bank) may not 
purchase in the primary and/or secondary markets debt instruments issued by the 
Bulgarian government or municipalities, or by Bulgarian government or municipal 
institutions, organisations or public sector entities. 
The prohibition of monetary financing prohibits the direct purchase of public sector 
debt, but such purchases in the secondary market are allowed, in principle, as long as 
such secondary market purchases are not used to circumvent the objective of Article 
123 of the Treaty. For this reason, Article 45(3) of the Law on BNB should be amended 
and references to “primary” and “secondary” markets should be deleted.235 
Furthermore, while acknowledging the particularities arising out of the currency-board 
regime, i.e. the prohibition on Българска народна банка (Bulgarian National Bank)
extending credit to credit institutions other than in the context of emergency liquidity 
operations, it is recommended that the scope of the exemption in Article 45(2) of the 
Law on BNB addressed to publicly owned and municipal credit institutions is brought 
into line with the scope of the exemption under Article 123(2) of the Treaty. That article 
233  Council Regulation (EU) No 1024/2013 of 15 October 2013 conferring specific tasks on the European
Central Bank concerning policies relating to the prudential supervision of credit institutions (OJ L 287, 
29.10.2013, p. 63).
234  Regulation (EU) No 806/2014 of the European Parliament and of the Council of 15 July 2014 establishing
uniform rules and a uniform procedure for the resolution of credit institutions and certain investment firms 
in the framework of a Single Resolution Mechanism and a Single Resolution Fund and amending 
Regulation (EU) No 1093/2010 (OJ L 225, 30.7.2014, p. 1).
235  See paragraph 3.3 of Opinion CON/2018/53.
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of the Treaty provides that the prohibition of monetary financing under Article 123(1) of 
the Treaty does not apply to publicly owned credit institutions which, in the context of 
the supply of reserves by central banks, must be given the same treatment by national 
central banks as private credit institutions.236 
Pursuant to the Law on credit institutions,237 Българска народна банка (Bulgarian
National Bank) operates a central credit register (Article 56) and a bank account 
register (Article 56a). The costs of obtaining information from these registers by 
government and judicial authorities are to be borne by the State budget. In past 
Convergence Reports the ECB considered that in order to further ensure compatibility 
with the prohibition of monetary financing, the Law on credit institutions would benefit 
from a limitation of the liability of Българска народна банка (Bulgarian National Bank) 
in relation to the operation of the two registers.238 The provisions of both Articles 56 
and 56a have been amended to waive the liability of Българска народна банка
(Bulgarian National Bank) in relation to the operation of the two registers. Instead of 
Българска народна банка (Bulgarian National Bank), the State will be liable for 
damages resulting from the operation of the two registers in accordance with the 
general regime for State liability.239 This makes the rules compliant with the prohibition 
of monetary financing. 
7.1.5 Legal integration of the NCB into the Eurosystem
With regard to the legal integration of Българска народна банка (Bulgarian National 
Bank) into the Eurosystem, the Law on BNB needs to be adapted in the respects set 
out below. 
Tasks
Monetary policy 
Article 2(1) and Article 16, items 4 and 5 and Articles 28, 30, 31, 32, 35, 38, 41 and 61 
of the Law on BNB, which provide for the powers of Българска народна банка 
(Bulgarian National Bank) in the field of monetary policy and instruments for the 
implementation thereof, do not recognise the ECB’s powers in this field.
Article 33 of the Law of BNB, which empowers Българска народна банка (Bulgarian 
National Bank) to enter into certain financial transactions, also fails to recognise the 
ECB’s powers in this field.
236  See paragraph 3.3 of Opinion CON/2018/53.
237  Darjaven vestnik issue 59, 21.07.2006.
238  See paragraph 3.1.6 of Opinion CON/2015/46, paragraph 3.2.1 of Opinion CON/2016/19 and paragraph 
2.2 of Opinion CON/2016/57.
239  See paragraph 3.2 of Opinion CON/2021/2.
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Collection of statistics 
Article 4(1) and Article 42 of the Law on BNB, which provide for the powers of 
Българска народна банка (Bulgarian National Bank) relating to the collection of 
statistics, do not recognise the ECB’s powers in this field. 
Official foreign reserve management 
Article 20(1) and Articles 28, 31 and 32 of the Law on BNB, which provide for the 
powers of Българска народна банка (Bulgarian National Bank) with regard to the 
management of official foreign reserves, do not recognise the ECB’s powers in this 
field. 
Payment systems 
Articles 2(4) and 40(1) of the Law on BNB, which provide for the powers of Българска 
народна банка (Bulgarian National Bank) with regard to the promotion of the smooth 
operation of payment systems, do not recognise the ECB’s powers in this field. 
Issue of banknotes 
Article 2(5), Article 16, item 9, and Articles 24 to 27 of the Law on BNB, which provide 
for the powers of Българска народна банка (Bulgarian National Bank) with regard to 
the issue of banknotes and coins, do not recognise the Council’s and the ECB’s 
powers in this field. 
Financial provisions 
Appointment of independent auditors 
Article 49(4) of the Law on BNB, which provides that the external auditor is appointed 
by the Governing Council for a term of three years on the basis of a procedure 
complying with the Law on public procurement, does not recognise the Council’s and 
the ECB’s powers under Article 27.1 of the Statute. 
Financial reporting 
Article 16, item 11 and Articles 46 and 49 of the Law on BNB do not reflect the 
obligation to comply with the Eurosystem’s regime for financial reporting of NCB 
operations, pursuant to Article 26 of the Statute. 
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Exchange rate policy 
Articles 28, 31, 32 of the Law on BNB, which provide for the powers of Българска 
народна банка (Bulgarian National Bank) with regard to the exchange rate policy, do 
not recognise the Council’s and the ECB’s powers in this field. 
International cooperation 
Article 5, Article 16, item 12 and Article 37(4) of the Law on BNB, which provide for the 
powers of Българска народна банка (Bulgarian National Bank) with regard to 
international cooperation, do not recognise the ECB’s powers in this field. 
Miscellaneous 
Articles 61 and 62 of the Law on BNB do not recognise the ECB’s powers to impose 
sanctions. 
7.1.6 Conclusions 
The Law on BNB does not comply with all the requirements for central bank 
independence, the monetary financing prohibition, and legal integration into the 
Eurosystem. Bulgaria is a Member State with a derogation and must therefore comply 
with all adaptation requirements under Article 131 of the Treaty. 
7.2 Czech Republic 
7.2.1 Compatibility of national legislation 
The following legislation forms the legal basis for Česká národní banka and its 
operations: 
• the Czech Constitution,240 
• the Law on Česká národní banka (hereinafter the “Law on CNB”).241 
The assessment takes into account amendments made to the Law on CNB by Law No 
219/2021 and minor changes made by Laws No 192/2020, No 238/2020, 
No 353/2021 and No 417/2021 . It also takes into account the current Law 
No 166/1993 Coll. on the Supreme Audit Office (hereinafter the “Law on NKU”). 
 
240  Constitutional Law No 1/1993 Coll. 
241  Law No 6/1993 Coll. 
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In relation to the points identified in the ECB’s Convergence Report of June 2020, the 
comments made in that report are largely repeated, with the exception set out below. 
7.2.2 Independence of the NCB 
With regard to Česká národní banka’s independence, the Law on CNB needs to be 
adapted as set out below. 
Functional independence 
Article 2(1) of the Law on CNB provides that in addition to the primary objective of 
price stability, Česká národní banka’s objective is “to ensure financial stability and the 
safe and sound operation of the financial system in the Czech Republic”. In line with 
Article 127(1) of the Treaty, the secondary objective of Česká národní banka should 
be stated to be without prejudice to Česká národní banka’s primary objective of 
maintaining price stability. 
Institutional independence 
Article 3 of the Law on CNB obliges Česká národní banka to submit a report on 
monetary development to the Chamber of Deputies at least twice a year for review; the 
Law on CNB also provides for an optional extraordinary report to be prepared 
pursuant to a Chamber of Deputies resolution. The Chamber of Deputies has the 
power to acknowledge the report or ask for a revised report; such a revised report 
must comply with the Chamber of Deputies’ requirements. These parliamentary 
powers could potentially breach the prohibition on giving instructions to NCBs 
pursuant to Article 130 of the Treaty and Article 7 of the Statute. 
In addition, Article 47(5) of the Law on CNB requires Česká národní banka to submit a 
revised report if the Chamber of Deputies rejects its annual financial report. This 
revised report must comply with the Chamber of Deputies’ requirements. Such 
parliamentary powers breach the prohibition on approving, annulling or deferring 
decisions. Article 3 and Article 47(5) of the Law on CNB are therefore incompatible 
with central bank independence and should be adapted accordingly. 
Further, Article 130 of the Treaty and Article 7 of the Statute are partially mirrored in 
the Law on CNB. Article 9(1) of the Law on CNB expressly prohibits Česká národní 
banka and its Board from seeking or taking instructions from the President of the 
Republic, from Parliament, from the Government, from administrative authorities of 
the Czech Republic, from the bodies, institutions or other entities of the European 
Union, from governments of the Member States or from any other body, but it does not 
expressly prohibit the Government from seeking to influence the members of Česká 
národní banka’s decision-making bodies in situations where this may have an impact 
on Česká národní banka’s fulfilment of its ESCB-related tasks. In this respect the Law 
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on CNB needs to be adapted to be fully consistent with Article 130 of the Treaty and 
Article 7 of the Statute. 
Pursuant to the Law on NKU, the Supreme Audit Office (NKU) is empowered to audit 
Česká národní banka’s financial management as regards its operating expenditure 
and expenditure for the purchase of property. The ECB understands that: (i) the NKU’s 
auditing powers in relation to Česká národní banka are without prejudice to Article 9 of 
the Law on CNB, which concerns the general prohibition on Česká národní banka
seeking or taking instructions from other entities; and (ii) the NKU has no power to 
interfere with either the external auditors’ opinion or with Česká národní banka’s 
ESCB-related tasks. 
In so far as this understanding is correct, the NKU’s auditing powers vis-à-vis Česká
národní banka are not incompatible with central bank independence. 
Česká národní banka is assigned certain tasks relating to preparedness for crisis 
situations and to their resolution. Pursuant to Article 13 of Law No 240/2000 Coll. on 
the management of crisis situations, and to Article 23 of Law No 241/2000 Coll. on 
economic measures for crisis situations (hereinafter together referred to as the “Laws 
on management of crisis situations and on economic measures for crisis situations”), 
Česká národní banka is obliged, among other things, to discuss with the government 
proposals for crisis measures which affect Česká národní banka, to adopt a crisis plan 
and to establish and operate a crisis headquarters. To ensure compatibility with the 
principle of central bank independence, those provisions of Law No 240/2000 Coll. 
and Law No 241/2000 Coll. should be amended to make it clear that they are without 
prejudice to the independent exercise by Česká národní banka of its ESCB-related 
tasks. 
Personal independence
The Law on CNB, in particular Article 6, does not explicitly refer to the Governor’s right
in the case of dismissal to seek a remedy before the Court of Justice of the European 
Union in accordance with Article 14.2 of the Statute. The ECB understands that 
although the Law on CNB is silent on the jurisdiction of the Court of Justice of the 
European Union to hear cases with regard to decisions to dismiss the Governor, 
Article 14.2 of the Statute applies. It is noted in this regard that Article 14.2 of the 
Statute is cited in a footnote to Article 6(10) of the Law on CNB, which deals with 
relieving a Česká národní banka board member from office.
The Law on CNB is also silent on the right of national courts to review a decision to 
dismiss any member, other than the Governor, from Česká národní banka’s Board
who is involved in the performance of ESCB-related tasks. Even though this right may 
be available under general law, providing specifically for such a right of review would 
increase legal certainty. 
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7.2.3 Monetary financing and privileged access
Under Article 33a of the Law on CNB, Česká národní banka, upon request, may 
exceptionally provide the Financial Market Guarantee System (FMGS) with short-term 
credit guaranteed by government bonds or other securities underwritten by the 
Government and owned by the FMGS, for a maximum of three months, in order to 
address an urgent situation, where the FMGS does not have sufficient funds to 
perform its tasks and this situation might jeopardise the stability of the financial 
market. Even if such funding is discretionary, temporary and in the interests of 
financial stability,242 it remains the case that Article 123(1) of the Treaty prohibits any 
type of credit facility in favour of “bodies governed by public law”. Given the features of 
the FMGS, the provisions laid down in the Law on CNB are not compatible with the 
monetary financing prohibition and should be amended accordingly.243 The FMSG 
qualifies as a “body governed by public law” within the meaning of Article 123(1) of the 
Treaty, as has been recently clarified. In particular, the FMGS has all of the following 
characteristics: (a) it is established for the specific purpose of meeting needs in the 
general interest, not having an industrial or commercial character; (b) it has legal 
personality; and (c) it is closely dependent on the public sector entities referred to in 
Article 123(1) of the Treaty, given that, although only a minority of the members of 
FMGS’s governing body are representatives of the Ministry of Finance, the Ministry of 
Finance has in fact the right to appoint and dismiss all the members of the FMGS’s 
governing body. 
As outlined in Section 7.2.2, Česká národní banka has been assigned certain tasks 
relating to national preparedness for crisis situations and to their resolution under the 
Laws on management of crisis situations and on economic measures for crisis 
situations. No provision is made for the costs incurred by Česká národní banka in 
carrying out such tasks to be met by the State. If they were to go beyond the internal 
contingency planning tasks of a central bank and to the extent that such tasks would 
be performed on behalf of, and in the exclusive interest of, the government, they would 
be government tasks, rather than central banking tasks. Therefore, in such a case, a 
mechanism for the reimbursement of Česká národní banka for any costs incurred in 
the performance of those tasks would need to be introduced in order to comply with 
the monetary financing prohibition. 
7.2.4 Legal integration of the NCB into the Eurosystem
With regard to Česká národní banka’s legal integration into the Eurosystem, the Law 
on CNB and Law No 2/1969 Coll., establishing ministries and other central 
administrative bodies of the Czech Republic (hereinafter the “Law on competences”)
need to be adapted as set out below. 
242  See paragraphs 3.1.2 and 3.1.3 of Opinion CON/2015/22, and paragraph 3.2. of Opinion CON/2016/60. 
243  See supra, page [XX] and Opinions CON/2020/24 and CON/2021/17. 
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Economic policy objectives
Article 2(1) of the Law on CNB, the last sentence of which provides that without 
prejudice to its primary objective, Česká národní banka shall support the general 
economic policies of the Government leading to sustainable economic growth and the 
general economic policies in the EU with a view to contributing to the achievement of 
the objectives of the EU, is not fully compatible with Article 127(1) of the Treaty and 
Article 2 of the Statute. The Law on CNB should make it clear that the objective of 
financial stability and the objective of supporting the general economic policies of the 
Government leading to sustainable growth are subordinate not only to the primary 
objective of price stability as specified in Section 6.2.2.1 but also to the secondary 
objective of the ESCB. 
Tasks
Monetary policy 
Article 2(2)(a), Article 5(1) and Part Five (namely Articles 23 to 26) of the Law on CNB, 
which provide for Česká národní banka’s powers in the field of monetary policy and 
instruments for the implementation thereof, do not recognise the ECB’s powers in this 
field. 
Articles 28, 29, 32 and 33 of the Law on CNB, which empower Česká národní banka to 
enter into certain financial transactions, also fail to recognise the ECB’s powers in this
field. 
Official foreign reserve management 
Article 35(c) and Articles 36 and 47a of the Law on CNB, which provide for Česká 
národní banka’s powers relating to foreign reserve management, do not recognise the 
ECB’s powers in this field. Article 4(1) of the Law on competences, according to which 
the Ministry of Finance is the central administrative body for, inter alia, “foreign 
exchange affairs including the State’s claims and obligations towards foreign entities” 
does not recognise the ECB’s powers in this field.
Payment systems 
Article 2(2)(c) and Articles 38 and 38a of the Law on CNB, which provide for Česká 
národní banka’s powers relating to the smooth operation of payment systems, do not 
recognise the ECB’s powers in this field. Article 4(1) of the Law on competences, 
according to which the Ministry of Finance is the central administrative body for, inter 
alia, “payments systems”, does not recognise the ECB’s powers in this field. 
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Issue of banknotes 
Article 2(2)(b) of the Law on CNB, which empowers Česká národní banka to issue 
banknotes and coins, and Part Four of the Law on CNB, namely Articles 12 to 22, 
which specify Česká národní banka’s powers in this field and the related implementing 
instruments, do not recognise the Council’s and the ECB’s powers in this field. 
Financial provisions 
Appointment of independent auditors 
Article 48(2) of the Law on CNB, which provides that Česká národní banka’s annual 
financial statements are audited by auditors selected on the basis of an agreement 
between Česká národní banka’s Board and the Minister for Finance, does not 
recognise the Council’s and the ECB’s powers under Article 27.1 of the Statute. 
Financial reporting 
Article 48 of the Law on CNB does not reflect Česká národní banka’s obligation to 
comply with the Eurosystem’s regime for financial reporting of NCB operations, 
pursuant to Article 26 of the Statute. 
Exchange rate policy 
Article 35 of the Law on CNB, which authorises Česká národní banka to conduct 
exchange rate policy, does not recognise the Council’s and the ECB’s powers in this 
field. Article 4 of the Law on competences also fails to recognise the Council’s and the 
ECB’s powers in this field. 
International cooperation 
Article 2(3) of the Law on CNB, which empowers Česká národní banka to cooperate 
and negotiate agreements with the central banks of other countries, international 
financial institutions and other foreign and international organisations performing 
similar tasks to those performed by Česká národní banka, does not recognise the 
ECB’s powers in this field. 
Miscellaneous 
Article 37 of the Law on CNB, which provides for the respective legislative powers of 
Česká národní banka and the Ministry of Finance in areas relating, inter alia, to 
currency, the circulation of money, the financial market, the adoption of the euro in the 
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Czech Republic, the payment system, foreign exchange management, and the status, 
competence, organisation and activities of Česká národní banka, does not recognise 
the Council’s and the ECB’s powers in this field.
Article 46a of the Law on CNB, which sets out the sanctions against third parties which 
fail to comply with their statistical obligations, does not recognise the Council’s and the 
ECB’s powers to impose sanctions. 
7.2.5 Conclusions
The Law on CNB, the Law on competences and the Laws on management of crisis 
situations and on economic measures for crisis situations do not comply with all the 
requirements for central bank independence, the monetary financing prohibition and 
legal integration into the Eurosystem. The Czech Republic is a Member State with a 
derogation and must therefore comply with all adaptation requirements under 
Article 131 of the Treaty. 
7.3 Croatia
7.3.1 Compatibility of national legislation
The following legislation forms the legal basis for Hrvatska narodna banka and its 
operations: 
• the Croatian Constitution,244
• the Law on Hrvatska narodna banka (hereinafter the “Law on HNB”).245
There have been several changes in relation to the points identified in the ECB’s 
Convergence Report of June 2020, also addressing the recommendations made in 
previous Convergence Reports. 
7.3.2 Independence of the NCB
With regard to Hrvatska narodna banka’s institutional independence, the Law on HNB 
has been adapted to implement the recommendations made in previous Convergence 
Reports, as set out below. 
244  Constitution of the Republic of Croatia, OG 5/2014. - Decision of the Constitutional Court No SuP-O-2014 
of 14 January 2014.
245  Law on Hrvatska narodna banka OG 75/2008 of 01 July 2008. Amendments to the Law on Hrvatska 
narodna banka OG 54/2013 of 7 May 2013. Amendments to the Law on Hrvatska narodna banka OG 
47/2020 of 17 April 2020.
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Institutional and personal independence
Article 71 of the Law on HNB mirrors Article 130 of the Treaty and Article 7 of the 
Statute. In particular Article 71(2) of the Law on HNB expressly prohibits the Croatian 
Government from seeking to influence the members of Hrvatska narodna banka’s 
decision-making bodies in the performance of their tasks. 
7.3.3 Legal integration of the NCB into the Eurosystem
With regard to the legal integration of Hrvatska narodna banka into the Eurosystem, 
the Law on HNB has been adapted to implement the recommendations made in 
previous Convergence Reports, as set out below. 
International cooperation
Pursuant to Article 104(9) of the Law on HNB, Hrvatska narodna banka’s Council
decides on Hrvatska narodna banka’s membership of international institutions and 
organisations. The Law on HNB explicitly prescribes that this power of Hrvatska 
narodna banka’s Council is without prejudice to the ECB’s powers under Article 6(1) of
the Statute. 
7.3.4 Conclusions
The Law on HNB has been amended to reflect and implement the recommendations 
made in the ECB’s Convergence Report of June 2020. As a result, the national 
legislation is consistent with the Treaty and the Statute. 
7.4 Hungary
7.4.1 Compatibility of national legislation
The following legislation forms the legal basis for the Magyar Nemzeti Bank and its 
operations: 
• The consolidated version of the Fundamental Law of Hungary,246
• Law CXXXIX of 2013 on the Magyar Nemzeti Bank (hereinafter the “Law on the
MNB”).247
246  Magyarország Alaptörvénye, Magyar Közlöny 2013/163. (X.3.). 
247  2013. évi CXXXIX. törvény a Magyar Nemzeti Bankról, Magyar Közlöny 2013/158. (IX.26.). Law CXXXIX 
of 2013 on the Magyar Nemzeti Bank repealed Law CCVIII of 2011 on the Magyar Nemzeti Bank with 
effect from 1 October 2013. See Opinions CON/2013/56 and CON/2013/71.
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There have been no major changes in relation to the points identified in the ECB's 
Convergence Report of June 2020, and those comments are therefore repeated in this 
year's assessment. Although the Law on the MNB has been amended several times 
since that Convergence Report, no additional points are necessary in this year's 
assessment. 
7.4.2 Independence of the NCB 
With regard to the Magyar Nemzeti Bank’s independence, the Law on the MNB and 
Law XXVII of 2008248 need to be adapted as set out below. 
Institutional independence 
After introducing significant changes in 2013-2015,249 minor amendments were made 
to the Law on the MNB. In the past two years, the Magyar Nemzeti Bank has been 
entrusted with supervisory tasks in relation to financial service providers and their 
identification and reporting obligations,250 and with tasks arising from the 
implementation of EU legislation.251 The mandate of the Magyar Nemzeti Bank has 
been extended in order to support, as a secondary objective, the government’s policy 
 
248  Law XXVII of 2008 on the oath of certain public officials (2008. évi XXVII. törvény 
egyes közjogi tisztségviselők esküjéről és fogadalmáról).  
249  The most notable amendment was the integration of the Hungarian Financial Supervisory Authority 
(HFSA) into the Magyar Nemzeti Bank as a general legal successor to the HFSA’s scope of competence, 
rights and obligations (see Articles 176 to 183 of the Law on the MNB as well as Opinions CON/2013/56 
and CON/2013/71). Further amendments concerned the allocation of new tasks to the Magyar Nemzeti 
Bank, such as: resolution tasks (Law XXXVII of 2014); supervisory tasks involving the verification of 
compliance with the new legal measures applicable to consumer loan contracts (Law XL of 2014); 
mediation of complaints and the initiation of legal proceedings in the public interest (Law XL of 2014 and 
Law LXXXV of 2015). The combination of the changes to the institutional framework of the Magyar 
Nemzeti Bank and the frequency of changes to the Law on the MNB, not always backed by robust 
justification of the need to amend the Magyar Nemzeti Bank’s institutional framework, were mentioned in 
previous Convergence Reports as adversely affecting the organisational and governance stability of the 
Magyar Nemzeti Bank and having an impact on its institutional independence. The principle of central 
bank independence requires that a central bank has a stable legal framework to enable it to function. 
250  Law XLIII of 2021 on the establishment and operation of the reporting framework of financial and other 
service providers relating to their identification tasks. 
251  Article 40(32)-(37) of the Law on the MNB covers the following EU secondary legislation: Regulation (EU) 
2019/2033 of the European Parliament and of the Council of 27 November 2019 on the prudential 
requirements of investment firms and amending Regulations (EU) No 1093/2010, (EU) No 575/2013, 
(EU) No 600/2014 and (EU) No 806/2014 (OJ L 314, 5.12.2019, p. 1); Regulation (EU) 2019/2088 of the 
European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the 
financial services sector (OJ L 317, 9.12.2019, p. 1); Regulation (EU) 2019/2089 of the European 
Parliament and of the Council of 27 November 2019 amending Regulation (EU) 2016/1011 as regards 
EU Climate Transition Benchmarks, EU Paris-aligned Benchmarks and sustainability-related disclosures 
for benchmarks (OJ L 317, 9.12.2019, p. 17); Regulation (EU) 2020/852 of the European Parliament and 
of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, 
and amending Regulation (EU) 2019/2088 (OJ L 198, 22.6.2020, p. 13); Regulation (EU) 2020/1503 of 
the European Parliament and of the Council of 7 October 2020 on European crowdfunding service 
providers for business, and amending Regulation (EU) 2017/1129 and Directive (EU) 2019/1937 (OJ L 
347, 20.10.2020, p. 1); Regulation (EU) 2021/168 of the European Parliament and of the Council of 10 
February 2021 amending Regulation (EU) 2016/1011 as regards the exemption of certain third-country 
spot foreign exchange benchmarks and the designation of replacements for certain benchmarks in 
cessation, and amending Regulation (EU) No 648/2012 (OJ L 49, 12.2.2021, p. 6). 
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related to environmental sustainability.252 Given the nature of these changes, –
including the supervisory tasks in relation to the identification and reporting obligations 
of financial service providers, it is unlikely that these changes will have a material 
impact on the institutional framework and organisational and governance stability of 
the Magyar Nemzeti Bank. 
Personal independence 
The ECB’s Convergence Reports of 2010, 2012, 2014, 2016, 2018 and 2020 noted 
that Law XXVII of 2008 specifies the wording of the oath that the members of the 
Monetary Council – including the Governor – are required to take. Pursuant to Article 
9(7), in conjunction with Articles 10(3) and 11(2) of the Law on the MNB which entered 
into force on 1 October 2013, the Governor and the Deputy Governors of the Magyar 
Nemzeti Bank must take an oath before Hungary’s President, while other members of 
the Monetary Council take an oath before the Parliament. Law XXVII of 2008 specifies 
the wording of the oath to be taken by public officials appointed by the Parliament.253 
Therefore, it is not clear whether the Governor and Deputy Governors take the same 
oath as the other members of the Monetary Council. 
The Magyar Nemzeti Bank’s Governor acts in a dual capacity as a member of both the 
Magyar Nemzeti Bank’s Monetary Council and the ECB decision-making bodies. The 
wording of the oath should take into account and reflect the status, obligations and 
duties of the Governor as a member of the ECB’s decision-making bodies. 
Furthermore, the other members of the Monetary Council are also involved in the 
performance of ESCB-related tasks. The oath taken should not hinder the Governor, 
Deputy Governors and other members of the Monetary Council from performing 
ESCB-related tasks. Law XXVII of 2008 and Articles 9(7), 10(3) and 11(2) of the Law 
on the MNB need to be adapted in this regard.254 
In addition, in accordance with Article 152(2) of the Law on the MNB, by way of 
exception from the general rule laid down in Article 152(1), all employees of the 
Magyar Nemzeti Bank, including the members of the Monetary Council, may: (1) hold 
membership of any kind in some but not all of the entities255 subject to the Magyar 
Nemzeti Bank’s supervisory powers, which fall under the scope of the laws 
 
252  Article 3(2) of the Law on the MNB stipulates that without prejudice to its primary objective of achieving 
and maintaining price stability, the Magyar Nemzeti Bank shall support, as a secondary objective, the 
government’s policy related to environmental sustainability using instruments at its disposal. See Opinion 
CON/2021/12. 
253  Law XXVII of 2008 on the oath of certain public officials. The wording of the oath is: “I, … [name of the 
person taking the oath], hereby undertake to be faithful to Hungary and to its Fundamental Law, I will 
comply and ensure compliance with its laws, I will fulfil my office as a … [name of the position] for the 
benefit of the Hungarian people. [Depending on the belief of the person taking the oath] So help me God!” 
254  Law XXVII of 2008 was amended by Law XIV of 2014, but these changes did not affect the assessment 
of the Hungarian law laid down in this section. 
255  These entities are voluntary mutual insurance funds, private pension funds, cooperative credit institutions 
and insurance associations. 
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enumerated in Article 39 of the Law on the MNB; 256 (2) have an employment 
relationship or any other work-related relationship, including by being executive officer 
or a supervisory board member, in a financial institution in which the Magyar Nemzeti 
Bank holds shares; and (3) be a supervisory board member of a non-profit business 
association the purpose of which is the resolution of entities subject to Article 39. In 
addition, pursuant to Article 153(1) of the Law on the MNB, employees of the Magyar 
Nemzeti Bank, including the members of the Monetary Council, performing the 
Magyar Nemzeti Bank’s basic tasks can maintain an employment relationship, 
including by being an executive officer or a supervisory board member, with financial 
institutions owned by the Magyar Nemzeti Bank. Furthermore, pursuant to Article 
153(6) of the Law on the MNB,257 by way of exception from Article 152, Article 153(1) 
to (5) and Articles 154 to 156 of the Law on the MNB, the members of the Monetary 
Council may, without being subject to a formal disclosure requirement (unless it 
amounts to an employment relationship), be an executive officer or a member of a 
supervisory board of a business association under the majority ownership of the 
Magyar Nemzeti Bank, as well as a member of the management, board of trustees or 
supervisory board of a foundation established by the Magyar Nemzeti Bank. On the 
basis that it gives rise to potential conflicts of interest, the exception provided for in 
Article 152(2) - in conjunction with Article 153(1) - and Article 153(6) of the Law on the 
MNB should be removed in relation to the entities subject to the Magyar Nemzeti 
Bank’s supervisory powers that fall under the scope of the laws enumerated in Article 
39 of the Law on the MNB, in order to safeguard the personal independence of the 
members of the Monetary Council. Furthermore, in relation to entities that are not 
subject to the Magyar Nemzeti Bank’s supervisory powers and do not fall under the 
scope of the laws enumerated in Article 39 of the Law on the MNB, it should be 
clarified that the memberships or relationships specified in the abovementioned 
provisions of the Law on the MNB are not permitted if they give rise to a conflict of 
interest. 
In addition, Article 153(4) of the Law on the MNB stipulates that all employees of the 
Magyar Nemzeti Bank, including the members of the Monetary Council, must notify 
the Magyar Nemzeti Bank when acquiring financial instruments subject to the Law 
CXXXVIII of 2007 on Investment Service Providers and Commodity Traders and the 
Rules of their Services except for state bonds and securities issued by open-ended 
public investment funds. The notification must be made within three working days of 
acquiring the instruments. In order to avoid any potential conflict of interest, however, 
 
256  These acts are as follows: (a) the Law on voluntary mutual insurance funds; (b) the Law on the Hungarian 
Export-Import Bank Corporation and the Hungarian Export Credit Insurance Corporation; (c) the Law on 
credit institutions and financial enterprises; (d) the Law on home savings and loan associations; (e) the 
Law on mortgage loan companies and mortgage bonds; (f) the Law on private pensions and Private 
Pension Funds; (g) the Law on the Hungarian Development Bank Limited Company; (h) the Law on credit 
institutions and financial enterprises; (i) the Law on the capital markets; (j) the Law on insurance 
institutions and the insurance business;(k) the Law on the distance marketing of consumer financial 
services; (l) the Law on occupational retirement pensions and institutions for occupational retirement 
provision; (m) the Law on investment firms and commodity dealers, and on the regulations governing 
their activities; (n) the Law on collective investment trusts and their managers, and on the amendment of 
financial regulations; (o) the Law on reinsurance; (p) the Law on the pursuit of the business of payment 
services; (q) the Law on insurance against civil liability in respect of the use of motor vehicles; (r) the Law 
on the central credit information system; (s) the Law on settlement finality in payment and securities 
settlement systems; (t) the Law on payment service providers. 
257  As introduced by Law LXXXV of 2015 on amendments to specific acts in order to enhance the 
development of the system of financial intermediation, 2015. évi LXXXV.  
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this notification obligation should cover all instruments including state bonds and 
securities issued by open-ended public investment funds. 
In addition, Article 156(7) of the Law on the MNB in conjunction with Article 152(1), 
sets out post-employment conflict of interest rules for the members of the Monetary 
Council. It provides the members of the Monetary Council with an exemption from the 
cooling-off period of six months with regard to any membership or shareholder 
relationship, employment relationship or work-related contractual relationship, 
executive officer relationship or supervisory board membership with any of the entities 
subject to the Magyar Nemzeti Bank’s supervisory powers, which fall under the scope 
of the laws enumerated in Article 39 of the Law on the MNB and in which the 
Hungarian State or the Magyar Nemzeti Bank has a majority stake.258 Providing for 
such an exemption may give rise to potential conflicts of interest for the members of 
the Monetary Council. In order to safeguard those members' personal independence, 
the exemption from the post-employment restrictions provided for in Article 156(7) of 
the Law on the MNB should be removed as regards the entities subject to the Magyar 
Nemzeti Bank’s supervisory powers and should be amended to clarify that such 
membership is not permitted if it gives rise to a conflict of interest as regards the other 
entities covered by Article 156(7) of the Law on the MNB. 
Article 157 of the Law on the MNB defines the rules that members of the Monetary 
Council must abide by when submitting their declarations of wealth. The Governor and 
the Deputy Governors must also follow these rules, by reference to the application of 
the provisions laid down in Law XXXVI of 2012 on the Parliament governing the 
declaration of wealth of members of the Parliament and related proceedings. Pursuant 
to Article 90(3) of Law XXXVI of 2012, which applies to the members of the Monetary 
Council by virtue of Article 157(2) of the Law on the MNB, in the case of 
non-compliance with the obligation to submit a declaration of wealth, the members of 
the Monetary Council will be prohibited from carrying out their duties and, as a 
consequence, they will not be entitled to receive their remuneration for the period of 
non-compliance. The sanction provided for in Article 90(3) of Law XXXVI of 2012 in 
effect allows the members of the Monetary Council to be temporarily removed from 
office for grounds other than those pursuant to Article 14.2 of the Statute. The 
provisions of Article 157(2) of the Law on the MNB should be adapted so that the 
members of the Monetary Council may not be dismissed for reasons other than those 
laid down in Article 14.2 of the Statute.259 
Financial independence 
Article 183 of the Law on the MNB, read in conjunction with Article 176, provided that 
on 1 October 2013 all employees of the HFSA would be employees of the Magyar 
Nemzeti Bank and that the Magyar Nemzeti Bank was to bear the financial obligations 
arising from any employment relations which HSFA staff transferred to the Magyar 
Nemzeti Bank may have had with the HFSA in the past. This provision alone, taken 
 
258  Introduced to Article 156(7) of the Law on the MNB by Article 174 of Law LXXXV of 2015. 
259  See paragraphs 2.3 to 2.5 of Opinion CON/2014/8. 
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together with the mass redundancy scheme provided for under Article 183(10) of the 
Law on the MNB and the aim of eliminating positions not essential for the discharge of 
duties in order to optimise staff management, is incompatible with the Magyar Nemzeti 
Bank’s financial independence and more specifically its autonomy in staff matters. It 
impeded the Magyar Nemzeti Bank’s ability to decide on employing and retaining
necessary and qualified staff for the Magyar Nemzeti Bank. See, also, the following 
Section regarding compatibility with the prohibition on monetary financing.260 
7.4.3 Monetary financing and privileged access
Article 36 of the Law on the MNB provides that if circumstances arise which jeopardise 
the financial system’s stability due to a credit institution’s operations, the Magyar 
Nemzeti Bank may extend an emergency loan to such credit institution subject to 
observing the prohibition on monetary financing in Article 146 of the Law on the MNB. 
However, it would be useful to specify that such loans are granted independently and 
at the Magyar Nemzeti Bank’s full discretion, which may make such extensions 
conditional if necessary and against adequate collateral, thus introducing an additional 
safeguard which should minimise the possibility of the Magyar Nemzeti Bank suffering 
any loss. 
Article 37 of the Law on the MNB provides that on request, the Magyar Nemzeti Bank 
at its full discretion may provide a loan to the National Deposit Insurance Fund, subject 
to the prohibition on monetary financing in Article 146 of the Law on the MNB, in urgent 
260  As noted in the section on institutional independence, over the past years the Magyar Nemzeti Bank has
been entrusted with several new tasks. The legal provisions entrusting the Magyar Nemzeti Bank with 
these new tasks that required additional human and financial resources within a relatively short period of 
time were seen, in previous Convergence Reports, as an instrument to influence the Magyar Nemzeti 
Bank's ability to fulfil its mandate, both operationally and financially. Therefore, this raised concerns as 
regards the provisions' compliance with the principle of financial independence. Any allocation of new 
tasks should be supplemented by the necessary resources to carry them out. See paragraph 2.2 of 
Opinion CON/2014/62 and paragraph 3.4 of Opinion CON/2014/72. It is also important to note that, as 
introduced by Law LXIX of 2017, the Magyar Nemzeti Bank also acts, within its existing tasks, as a 
competent authority to implement several delegated acts related to Directive 2014/65/EU of the 
European Parliament and of the Council of 15 May 2014 on markets in financial instruments and 
amending Directive 2002/92/EC and Directive 2011/61/EU (OJ L 173, 12.6.2014, p. 349) and Regulation 
(EU) No 600/2014 of the European Parliament and of the Council of 15 May 2014 on markets in financial 
instruments and amending Regulation (EU) No 648/2012 (OJ L 173, 12.6.2014, p. 84). The Magyar 
Nemzeti Bank also implements Regulation (EU) 2016/1011 of the European Parliament and of the 
Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or 
to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU 
and Regulation (EU) No 596/2014 (OJ L 171, 29.6.2016, p. 1), and shall function as a competent 
authority as referred to in Article 16 of Regulation (EU) 2015/2365 of the European Parliament and of the 
Council of 25 November 2015 on transparency of securities financing transactions and of reuse and 
amending Regulation (EU) No 648/2012 (OJ L 337, 23.12.2015, p. 1). In addition, the Magyar Nemzeti 
Bank implements the following Regulations: Regulation (EU) 2017/2402 of the European Parliament and 
of the Council of 12 December 2017 laying down a general framework for securitisation and creating a 
specific framework for simple, transparent and standardised securitisation, and amending Directives 
2009/65/EC, 2009/138/EC and 2011/61/EU and Regulations (EC) No 1060/2009 and (EU) No 648/2012 
(OJ L 347, 28.12.2017, p. 35); Regulation (EU) 2017/1129 of the European Parliament and the Council of 
14 June 2017 on the prospectus to be published when securities are offered to the public or admitted to 
trading on a regulated market, and repealing Directive 2003/71/EC (OJ L 168, 30.6.2017, p. 12); and 
Regulation (EU) 2019/1156 of the European Parliament and of the Council of 20 June 2019 on facilitating 
cross-border distribution of collective investment undertakings and amending Regulations (EU) No 
345/2013, (EU) No 346/2013 and (EU) No 1286/2014 (OJ L 188, 12.7.2019, p. 55). The Magyar Nemzeti 
Bank also acts in compliance with Regulation (EU) 2017/1131 of the European Parliament and of the 
Council of 14 June 2017 on money market funds (OJ L 169, 30.6.2017, p. 8) and with Regulation (EU) 
2017/1991 of the European Parliament and of the Council of 25 October 2017 amending Regulation (EU) 
No. 345/2013 on European venture capital funds and Regulation (EU) No. 346/2013 on European social 
entrepreneurship funds (OJ L 293, 10.11.2017, p. 1).
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and exceptional cases threatening the stability of the financial system as a whole and 
the smooth completion of cash transactions, the term of which loan may not be longer 
than three months. Law LXXXV of 2015 extended the scope of Article 37 in order to 
enable such emergency short-term loan facilities to be provided to the Hungarian 
Investor Protection Fund, under the same conditions as to the National Deposit 
Insurance Fund. This provision is compatible with the monetary financing prohibition. 
As also already clarified in ECB opinions,261 it may be useful to specify that such loans 
are extended against adequate collateral, thus introducing an additional safeguard 
which should minimise the possibility of the Magyar Nemzeti Bank suffering any loss. 
The integration of the HFSA into the Magyar Nemzeti Bank took place on 1 October 
2013. Based on Articles 176 to 181 of the Law on the MNB, all of the HFSA’s assets 
were transferred to the Magyar Nemzeti Bank. The Magyar Nemzeti Bank also 
became a general legal successor to all obligations of the HFSA including, inter alia, 
its contractual relationships, pending procurement procedures, out-of-court redress 
procedures, tax-related administrative procedures as well as any other type of legal 
procedure (including pending administrative legal procedures)262. As a consequence, 
any payment obligation from a legal relationship or a requirement to pay 
compensation following any judgment handed down by a Hungarian court granting 
compensation to an individual or entity challenging a prior decision of the HFSA is to 
be borne by the Magyar Nemzeti Bank. 
Although Article 177(6) of the Law on the MNB provides for compensation by the State 
to the Magyar Nemzeti Bank for all expenses resulting from the above-mentioned 
obligations that would exceed the assets taken over from the HFSA, the Law on the 
MNB does not specifically lay down the procedure and deadlines applicable to 
financing by the State and reimbursement of the Magyar Nemzeti Bank. This can only 
be considered to be an ex-post financing scheme. The provisions applying to the 
assignment of the obligations of the HFSA to the Magyar Nemzeti Bank were not 
accompanied by measures that would fully insulate the Magyar Nemzeti Bank from all 
financial obligations resulting from any activities and contractual relationships of the 
HFSA originating prior to the transfer of tasks, and the provisions of the Law on the 
MNB introduced a time gap between the costs arising and the Hungarian State 
reimbursing the Magyar Nemzeti Bank, should the expenses incurred at the Magyar 
Nemzeti Bank exceed the value of assets taken over from the HFSA. As mentioned in 
previous Convergence Reports, such a scenario would constitute a breach of the 
prohibition on monetary financing laid down in Article 123 of the Treaty as well as of 
the principle of financial independence under Article 130. Hence the Magyar Nemzeti 
Bank must be insulated from all financial obligations resulting from the prior activities 
or legal relationships of the HFSA. 
Article 183 of the Law on the MNB read in conjunction with Article 176 of the Law on 
the MNB provides that the Magyar Nemzeti Bank bears the financial obligations 
arising from the employment relationships which HFSA staff transferred to the Magyar 
Nemzeti Bank may have had with the HFSA in the past. In order to comply with Article 
123 of the Treaty, the Magyar Nemzeti Bank should be insulated from all obligations 
 
261  See, for example, paragraph 9.3 of Opinion CON/2011/104. 
262  See paragraph 3.7 of Opinion CON/2008/83. 
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arising out of employment relationships between any new Magyar Nemzeti Bank staff 
member and the HFSA, in the light of the mass redundancy scheme provided for 
under Article 183(10) of the Law on the MNB263. 
7.4.4 Single spelling of the euro
In several Hungarian legal acts264 the name of the single currency is spelled in a way 
("euró"), which is inconsistent with EU law. Under the Treaties a single spelling of the 
word “euro” in the nominative singular case is required in all EU and national 
legislative provisions, taking into account the existence of different alphabets. The 
Hungarian legal acts in question should therefore be amended accordingly.265 
The ECB expects that the correct spelling of the word “euro” will be applied in 
Hungarian legal acts and the euro changeover law. Only when all national legal acts 
use the correct spelling of the word “euro” will Hungary comply with the Treaties.
7.4.5 Legal integration of the NCB into the Eurosystem
With regard to the Magyar Nemzeti Bank’s legal integration into the Eurosystem, the
Law on the MNB needs to be adapted as set out below. 
Economic policy objectives
Article 3(2) of the Law on the MNB provides that the Magyar Nemzeti Bank supports, 
without prejudice to the primary objective of price stability, the maintenance of the 
stability of the financial intermediary system, the enhancement of its resilience, its 
sustainable contribution to economic growth and the Government’s general economic 
policies and environmental sustainability policy. This provision is incompatible with 
Article 127(1) of the Treaty and Article 2 of the Statute as it does not reflect the 
secondary objective of supporting the general economic policies in the EU. 
Tasks
Monetary policy 
Article 41 of the Fundamental Law of Hungary and Article 1(2) and Articles 4, 9, 16 to 
22, 159 and 171 of the Law on the MNB establishing the Magyar Nemzeti Bank’s 
263  Although this concern and the one explained in the previous paragraph remain, they are obviously less
strong than they were in the immediate years that followed the integration of the HFSA into the Magyar 
Nemzeti Bank as, due to the passage of time, it is less likely that Magyar Nemzeti Bank has to assume 
new financial obligations resulting from the legal succession of HFSA.
264  For example, the Laws on the 2022 general budget in Hungary. 
265  Opinion CON/2006/55. 
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powers in the field of monetary policy and instruments for the implementation thereof 
do not recognise the ECB’s powers in this field. 
Collection of statistics 
Although Article 4(7) of the Law on the MNB refers to the Magyar Nemzeti Bank’s 
obligation to transfer specific statistical data to the ECB in accordance with Article 5 of 
the Statute, Article 1(2), as well as Articles 30 and 171(1) of the Law on the MNB 
establishing the Magyar Nemzeti Bank’s powers relating to the collection of statistics 
do not recognise the ECB’s powers in this field. 
Official foreign reserve management 
Article 1(2), Article 4(3), (4) and (12), Article 9 and Article 159(2) of the Law on the 
MNB, which provide for the Magyar Nemzeti Bank’s powers in the field of foreign 
reserve management, do not recognise the ECB’s powers in this field. 
Payment systems 
Article 1(2), Article 4(5) and (12), Articles 27 and 28, and Article 171(2) and (3) of the 
Law on the MNB establishing the Magyar Nemzeti Bank’s powers with regard to the 
promotion of the smooth operation of payment systems do not recognise the ECB’s 
powers in this field. 
Issue of banknotes 
Article K of the Fundamental Law and Article 1(2), Article 4(2) and (12), Articles 9, 23 
to 26 and Article 171(1) of the Law on the MNB establishing the Magyar Nemzeti 
Bank’s exclusive right to issue banknotes and coins do not recognise the Council’s 
and the ECB’s powers in this field. 
Financial provisions 
Appointment of independent auditors 
Article 144 of the Law on the MNB providing that the President of the State Audit Office 
must be consulted before the Magyar Nemzeti Bank’s auditor is elected or his or her 
dismissal is proposed, Article 6(1) of the Law on the MNB, which provides for the 
shareholder’s power to appoint and dismiss the auditor, and Article 15 of the Law on 
the MNB do not recognise the Council’s and the ECB’s powers under Article 27.1 of 
the Statute. 
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Financial reporting 
Article 12(4)(b) of the Law on the MNB and Law C of 2000,266 in conjunction with 
Government Decree 221/2000 (XII.19),267 do not reflect the Magyar Nemzeti Bank’s 
obligation to comply with the Eurosystem’s regime for financial reporting of NCB 
operations, pursuant to Article 26 of the Statute. 
Exchange rate policy 
Article 1(2), 4(4) and (12), Articles 9, 22 and 147 of the Law on the MNB lay down the 
Government’s and the Magyar Nemzeti Bank’s respective powers in the area of 
exchange rate policy. These provisions do not recognise the Council’s and the ECB’s 
powers in this field. 
International cooperation 
Article 1(2), 135(5) of the Law on the MNB providing that, upon authorisation by the 
Government, the Magyar Nemzeti Bank may undertake tasks arising at international 
financial organisations, unless otherwise provided for by a legislative act, fails to 
recognise the ECB’s powers as far as issues under Article 6 of the Statute are 
concerned. 
Miscellaneous 
Articles 75 and 76 of the Law on the MNB do not recognise the ECB’s powers to 
impose sanctions. 
With regard to Article 132 of the Law on the MNB, which entitles the Magyar Nemzeti 
Bank to be consulted on draft national legislation related to its tasks, it is noted that 
consulting the Magyar Nemzeti Bank does not obviate the need to consult the ECB 
under Articles 127(4) and 282(5) of the Treaty. 
As set out in Section 7.4.2, Article 9(7) of the Law on the MNB requires the members 
of the Monetary Council to make an oath in accordance with the wording specified in 
Article 1 of Law XXVII of 2008. Article 9(7) of the Law on the MNB needs to be adapted 
to comply with Article 14.3 of the Statute.268 
 
266  A számvitelről szóló törvény, Magyar Közlöny 2000/95. (IX. 21.). 
267  A Magyar Nemzeti Bank éves beszámoló készítési és könyvvezetési kötelezettségének sajátosságairól 
szóló kormányrendelet, Magyar Közlöny 2000/125. (XII.19.). 
268  See paragraph 3.7 of Opinion CON/2008/83. 
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7.4.6 Conclusions
The Fundamental Law of Hungary, the Law on the MNB and Law XXVII of 2008 do not 
comply with all the requirements for central bank independence, the prohibition on 
monetary financing, and legal integration into the Eurosystem. Other Hungarian legal 
acts do not comply with the requirements for the single spelling of the euro. Hungary is 
a Member State with a derogation and must therefore comply with all adaptation 
requirements under Article 131 of the Treaty. 
7.5 Poland
7.5.1 Compatibility of national legislation
The following legislation forms the legal basis for Narodowy Bank Polski and its 
operations: 
• the Polish Constitution,269
• the Law on Narodowy Bank Polski (hereinafter the “Law on NBP”),270
• the Law on the Bank Guarantee Fund, deposit guarantee system and
compulsory restructuring (hereinafter the “Law on the Fund”),271
• the Law on banking (hereinafter the “Law on banking”),272
• the Law on settlement finality in the payment and settlement systems and on the
supervision of such systems.273
No major new legislation has been enacted in relation to the points identified in the 
ECB’s Convergence Report of June 2020, and those comments are therefore largely 
repeated in this year’s assessment. The Law on NBP has been amended several 
times since the last Convergence Report. These changes did not result in the need to 
add additional points in the current assessment, as they do not affect the issues 
covered in it. However, an additional incompatibility of the existing legislation was 
discovered and is addressed in Section 7.5.4. 
269  Konstytucja Rzeczypospolitej Polskiej of 2 April 1997, Dziennik Ustaw of 1997, No 78, item 483, with 
further amendments.
270  Ustawa o Narodowym Banku Polskim of 29 August 1997. Consolidated version published in Dziennik
Ustaw of 2022, item 492.
271  Ustawa o Bankowym Funduszu Gwarancyjnym, systemie gwarantowania depozytów oraz przymusowej 
restrukturyzacji of 10 June 2016. Consolidated version published in Dziennik Ustaw of 2022, item 793.
272  Ustawa Prawo bankowe of 29 August 1997. Consolidated version published in Dziennik Ustaw of 2021,
item 2439.
273  Ustawa o ostateczności rozrachunku w systemach płatności i systemach rozrachunku papierów 
wartościowych oraz zasadach nadzoru nad tymi systemami of 24 August 2001. Consolidated version 
published in Dziennik Ustaw of 2019, item 212, with further amendments.
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7.5.2 Independence of the NCB
With regard to Narodowy Bank Polski’s independence, the Polish Constitution, the 
Law on NBP and the Law on the State Tribunal274 need to be adapted in the respects 
set out below. 
Institutional independence
The Law on NBP does not prohibit Narodowy Bank Polski and members of its 
decision-making bodies from seeking or taking outside instructions; it also does not 
expressly prohibit the Government from seeking to influence members of Narodowy 
Bank Polski’s decision-making bodies in situations where this may have an impact on 
Narodowy Bank Polski’s fulfilment of its ESCB-related tasks. In this respect, the Law 
on NBP needs to be adapted to comply with Article 130 of the Treaty and Article 7 of 
the Statute. Even though the Polish Constitutional Court has confirmed275 that while 
the Polish Constitution does not expressly lay down the principle of Narodowy Bank 
Polski's independence, such principle can be implicitly derived from the Constitution's 
provisions relating to Narodowy Bank Polski. Legal certainty would nevertheless be 
increased by making explicit provision for this principle in the Polish Constitution on 
the occasion of a future amendment. 
Article 11(3) of the Law on NBP, which provides that Narodowy Bank Polski’s
President represents Poland’s interests within international banking institutions and, 
unless the Council of Ministers decides otherwise, within international financial 
institutions, needs to be adapted to comply with Article 130 of the Treaty and Article 7 
of the Statute. 
Article 23(1)(2) of the Law on NBP, which obliges Narodowy Bank Polski’s President 
to forward draft monetary policy guidelines to the Council of Ministers and the Minister 
for Finance, needs to be adapted to comply with Article 130 of the Treaty and Article 7 
of the Statute. 
The Supreme Audit Office (NIK), a constitutional body, has wide powers under Article 
203(1) of the Polish Constitution to control the activities of, among others, all public 
administrative authorities and  Narodowy Bank Polski as regards their legality, 
economic prudence, efficiency and diligence. The scope of the NIK’s control should be 
clearly defined, should be without prejudice to the activities of Narodowy Bank Polski’s 
independent external auditors,276 should comply with the prohibition on giving 
instructions to an NCB and its decision-making bodies and should not interfere with 
the NCB’s ESCB-related tasks. In particular, it should be ensured that when auditing 
Narodowy Bank Polski, the application by the NIK of the “efficiency criterion” does not
extend to an evaluation of Narodowy Bank Polski’s activities related to its primary 
274  Ustawa o Trybunale Stanu of 26 March 1982. Consolidated version published in Dziennik Ustaw of 2022,
item 762.
275  Judgment of 16 July 2009 of the Polish Constitutional Court. Kp 4/08. 
276  For the activities of the NCB’s independent external auditors see, as an example, Article 27.1 of the 
Statute.
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objective of price stability.277 Article 203(1) of the Constitution needs to be adapted to 
comply with Article 130 of the Treaty and Article 7 of the Statute. 
Personal independence
Article 9(5) of the Law on NBP regulates the dismissal of Narodowy Bank Polski’s 
President by the Sejm (lower house of Parliament), if he or she has: 
• been unable to fulfil his or her duties due to prolonged illness,
• been convicted of a criminal offence under a final court sentence,
• submitted an untruthful disclosure declaration, confirmed by a final court
judgment,278
• been prohibited by the State Tribunal from occupying executive positions or
holding posts of particular responsibility in state bodies.279
Moreover, under Article 25(3) in conjunction with Article 3 and Article 1(1)(3) of the 
Law on the State Tribunal, Narodowy Bank Polski’s President may also be removed 
from office if he or she violates the Constitution or a law.280 
The grounds listed above are in addition to the two grounds for dismissal provided for 
in Article 14.2 of the Statute. Therefore, Article 9(5) of the Law on NBP and the 
relevant provisions of the Law on the State Tribunal need to be adapted to comply with 
Article 14.2 of the Statute. 
With regard to security of tenure and grounds for dismissal of other members of 
Narodowy Bank Polski’s decision-making bodies involved in the performance of 
ESCB-related tasks (i.e. the members of the Management Board, and in particular the 
First Deputy President, and the members of the Monetary Policy Council), Article 
13(5) and Article 17(2b), second sentence, of the Law on NBP provide the following 
grounds for dismissal: 
• an illness which permanently prevents them from performing their
responsibilities,
• a conviction for a criminal offence under a final court sentence,
• submission of an untruthful lustration declaration, and this has been confirmed by
a final court judgment,281
277  See paragraph 3.6 of Opinion CON/2011/9. 
278  The provision was added with effect from 15 March 2007 by Article 37a of the Law on disclosure of
information relating to documents of state security services from the period 1944-1990 (Ustawa o
ujawnianiu informacji o dokumentach organów bezpieczeństwa państwa z lat 1944-1990 oraz treści tych 
dokumentów of 18 October 2006. Consolidated version published in Dziennik Ustaw of 2007, No 63, item 
425).
279  The resolution of the Sejm producing an indictment of the President of Narodowy Bank Polski before the 
State Tribunal results, by operation of law, in suspension of the President from office (Article 11(1), 
second sentence in connection with Article 1(1)(3) of the Law on the State Tribunal).
280  The indictment by the Sejm of the President of Narodowy Bank Polski before the State Tribunal results,
by operation of law, in suspension of the President from office, see previous footnote.
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• non-suspension of membership of a political party or trade union. 
The grounds listed above are in addition to the two grounds for dismissal provided for 
in Article 14.2 of the Statute. Article 13(5) of the Law on NBP therefore needs to be 
adapted to comply with Article 14.2 of the Statute. Article 14(3) of the Law on NBP, 
which reaffirms the possibility of dismissal of a member of the Monetary Policy Council 
of Narodowy Bank Polski for a conviction for a criminal offence, also needs to be 
adapted to comply with Article 14.2 of the Statute. 
The President of Narodowy Bank Polski acts in dual capacity as a member of 
Narodowy Bank Polski’s decision-making bodies and of the relevant decision-making 
bodies of the ECB. Article 9(3) of the Law on NBP, which specifies the wording of the 
oath sworn by Narodowy Bank Polski’s President, needs to be adapted to reflect the 
status and the obligations and duties of the President of Narodowy Bank Polski as 
member of the relevant decision-making bodies of the ECB. 
The Law on NBP is silent on the right of national courts to review a decision to dismiss 
any member of the NCB’s decision-making bodies who is involved in the performance 
of ESCB-related tasks. Even though this right may be available under general Polish 
law, providing specifically for such a right of review would increase legal certainty. 
Financial independence 
In March 2019 the Law amending the Law on prohibitions regarding conducting of 
business activities by public officials and the Law on NBP282 entered into force. 
According to Article 66(3) of the amended Law on NBP, the upper salary limit (salary 
cap) for all employees (excluding members of the Management Board of Narodowy 
Bank Polski) is set at 60% of the salary of the President of Narodowy Bank Polski (the 
salary of the President is determined on the basis of other provisions which have not 
been amended). However, amendments included in any legislative proposal that lead 
to reductions in remuneration are not compatible with the principle of financial 
independence if the ability of the relevant national central bank to employ and retain 
staff to perform independently the tasks conferred on it by the Treaty and the Statute is 
affected. Any adopted legislative solution should provide for a cooperation mechanism 
with Narodowy Bank Polski, to ascertain if it considers that an exception to a cap on 
remuneration is required. Such an exception should be decided upon in close and 
effective cooperation with Narodowy Bank Polski, taking due account of its views, to 
ensure its ongoing ability to independently carry out its tasks.283 As such close and 
effective cooperation with Narodowy Bank Polski is not provided for in the present 
 
281  This provision was added with effect from 15 March 2007 by Article 37a of the Law on disclosure of 
information relating to documents of state security services from the period 1944-1990 (Ustawa o 
ujawnianiu informacji o dokumentach organów bezpieczeństwa państwa z lat 1944-1990 oraz treści tych 
dokumentów of 18 October 2006.Consolidated version published in Dziennik Ustaw of 2007, No 63, item 
425). 
282  Ustawa z dnia 22 lutego 2019 r. o zmianie ustawy o ograniczeniu prowadzenia działalności gospodarczej 
przez osoby pełniące funkcje publiczne oraz ustawy o Narodowym Banku Polskim, Dz. U. 2019 item 371. 
283  See paragraph 2.2.3 of Opinion CON/2019/3. 
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legal framework regarding the salary cap, the legislation does not satisfy the 
requirements of Article 130 of the Treaty and Article 7 of the Statute. 
7.5.3 Confidentiality 
Article 23(7) of the Law on NBP specifies instances in which data collected from 
individual financial institutions, as well as statistical surveys, studies and assessments 
enabling identification of individual entities, are subject to disclosure by Narodowy 
Bank Polski to external parties. One such instance covers disclosure to “unspecified 
recipients”, under “separate applicable provisions”.284 Such disclosure may potentially 
affect data protected under the ESCB’s confidentiality regime and therefore the Law 
on NBP should be adapted to fully comply with Article 37 of the Statute.285 
In addition, since NIK has wide powers under Article 203(1) of the Polish Constitution 
to control the activities of Narodowy Bank Polski, as mentioned in Chapter 7.5.2.1, NIK 
also has wide access to Narodowy Bank Polski’s confidential information and 
documents. However, pursuant to Article 37 of the Statute in conjunction with Article 
130 of the Treaty, NIK's access to Narodowy Bank Polski’s confidential information 
and documents must be limited to that necessary for the performance of NIK's 
statutory tasks. Such access must also be without prejudice both to the ESCB’s 
independence and to its confidentiality regime, to which the members of the NCBs’ 
decision-making bodies and staff are subject. In addition, the relevant Polish 
legislation should be amended to stipulate that NIK shall safeguard the confidentiality 
of information and documents disclosed by Narodowy Bank Polski to an extent 
corresponding to that applied by Narodowy Bank Polski. 
7.5.4 Monetary financing and privileged access 
Article 42(1) in conjunction with Article 3(2)(5) of the Law on NBP provides for 
Narodowy Bank Polski’s powers to grant refinancing credit to banks satisfying 
specified conditions.286 In addition, Article 42(3) of the Law on NBP allows Narodowy 
Bank Polski to grant refinancing credit for the purpose of implementing a bank 
recovery plan, which is initiated in the event of a bank infringing, or being likely to 
infringe, certain requirements relating to, among other things, own funds and liquidity 
ratio.287 Granting of refinancing credit is in all cases subject to the general rules of the 
Law on banking, with the modifications resulting from the Law on NBP.288 Safeguards 
currently contained in such rules aiming at ensuring timely repayment of the credit do 
not fully exclude an interpretation that would allow an extension of refinancing credit to 
 
284  Article 23(7)(3) of the Law on NBP. 
285  See Opinion CON/2008/53. 
286  Narodowy Bank Polski’s decision whether to grant refinancing credit is based on its assessment of the 
bank’s ability to repay the principal amount and the interest on time (Article 42(2) of the Law on NBP). 
287  Article 142(1) and (2) of the Law on banking. 
288  Article 42(7) of the Law on NBP. 
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a bank undergoing recovery proceedings which then becomes insolvent.289 More 
explicit safeguards in relation to all financial institutions receiving liquidity support from 
Narodowy Bank Polski are needed to avoid incompatibility with the monetary financing 
prohibition under Article 123 of the Treaty.290 The Law on NBP should be adapted to 
make clear that such liquidity support is only temporary and it may not be extended to 
insolvent financial institutions. 
Article 42 of the Law on NBP in conjunction with Articles 270 and 306 of the Law on the 
Fund provides for Narodowy Bank Polski’s powers to grant, at its discretion, 
short-term credit to the Bank Guarantee Fund (hereinafter the “Fund”) related to the 
financing of its deposit guarantee function, if a threat to financial stability arises and in 
view of its urgent needs. Given the current features of the Fund, the provisions laid 
down in the Law on NBP and the Law on the Fund regarding the possibility of NBP 
granting loans to the Fund are not compatible with the monetary financing prohibition 
and should be amended accordingly. The Fund qualifies as a “body governed by 
public law” within the meaning of Article 123(1) of the Treaty. In particular, the Fund 
has all of the following characteristics: (a) it has been established for the purpose of 
meeting needs in the general interest – especially tasks related to financial stability, 
administering the deposit guarantee scheme and resolution; (b) it has legal 
personality; and (c) it is closely dependent on public sector entities referred to in Article 
123(1) of the Treaty, as the majority of the members of the Fund’s Council, which acts 
as the Fund’s administrative board, are appointed by the Minister competent for 
financial institutions and the Chairman of the Financial Supervisory Authority.291 
Additionally, the Fund is included in the catalogue of entities that are part of the public 
sector for the purposes of the Law of 27 August 2009 on public finance.292 
Article 220(2) of the Polish Constitution provides that “the budget shall not provide for
covering a budget deficit by way of contracting credit obligations to the State’s central 
bank”. While this provision prohibits the State from financing its budgetary deficit via 
Narodowy Bank Polski, the ECB understands that it does not constitute an 
implementation of Article 123 of the Treaty prohibiting monetary financing, and its aim 
and function are therefore not identical to those of the said Treaty prohibition. Article 
123 of the Treaty, supplemented by Council Regulation (EC) No 3603/93, is directly 
applicable, so in general, it is unnecessary to transpose it into national legislation. 
289  Under the Law on banking which applies to the provision of refinancing credit by Narodowy Bank Polski,
a commercial bank may extend credit to an uncreditworthy borrower, provided that: (i) qualified security is 
established; and (ii) a recovery programme is instituted, which the crediting bank considers will ensure 
the borrower’s creditworthiness during a specified period (Article 70(2) of the Law on banking). 
Furthermore, Narodowy Bank Polski may demand early repayment of any refinancing credit if the 
financial situation of the credited bank has worsened to the extent of putting the timely repayment at risk 
(Article 42(6) of the Law on NBP).
290  See Opinion CON/2013/5. 
291  See Opinion CON/2021/17. 
292  Ustawa o finansach publicznych. Consolidated version published in Dziennik Ustaw of 2021, item 305. 
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7.5.5 Legal integration of the NCB into the Eurosystem
With regard to Narodowy Bank Polski’s legal integration into the Eurosystem, the 
Polish Constitution and the Law on NBP need to be adapted in the respects set out 
below. 
Economic policy objectives
Article 3(1) of the Law on NBP provides that Narodowy Bank Polski’s primary objective 
is to maintain price stability, while supporting the economic policies of the 
Government, insofar as this does not constrain the pursuit of its primary objective. This 
provision is incompatible with Article 127(1) of the Treaty and Article 2 of the Statute, 
as it does not reflect the ESCB’s secondary objective of supporting the general 
economic policies in the Union. 
Tasks
Monetary policy 
Article 227(1) and (6) of the Constitution and Article 3(2)(5), Articles 12, 23 and 38 to 
50a and 53 of the Law on NBP, which provide for Narodowy Bank Polski’s powers with
regard to monetary policy, do not recognise the ECB’s powers in this field.
Collection of statistics 
Article 3(2)(7) and Article 23 of the Law on NBP, which provides for Narodowy Bank 
Polski’s powers relating to the collection of statistics, do not recognise the ECB’s 
powers in this field. 
Official foreign reserve management 
Article 3(2)(2) and Article 52 of the Law on NBP, which provide for Narodowy Bank 
Polski’s powers in the field of foreign exchange management, do not recognise the 
ECB’s powers in this field.
Payment systems 
Article 3(2)(1) of the Law on NBP, which provides for Narodowy Bank Polski’s powers 
in organising monetary settlements, does not recognise the ECB’s powers in this field.
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Issue of banknotes 
Article 227(1) of the Constitution and Article 4 and Articles 31 to 37 of the Law on NBP, 
which provide for Narodowy Bank Polski’s exclusive powers to issue and withdraw 
banknotes and coins having the status of legal tender, do not recognise the Council’s 
and the ECB’s powers in this field. 
Financial provisions 
Appointment of independent auditors 
Article 69(1) of the Law on NBP, which provides for the auditing of Narodowy Bank 
Polski, does not recognise the Council’s and the ECB’s powers under Article 27.1 of 
the Statute. The powers of the NIK to control the activities of Narodowy Bank Polski 
should be clearly defined by legislation and should be without prejudice to the 
activities of Narodowy Bank Polski’s independent external auditors, as laid down in 
Article 27.1 of the Statute. 
Exchange rate policy 
Articles 3(2)(3) and 17(4)(2) and Article 24 of the Law on NBP, which provide for 
Narodowy Bank Polski’s power to implement the exchange rate policy set in 
agreement with the Council of Ministers, do not recognise the Council’s and the ECB’s 
powers in this field. 
International cooperation 
Articles 5(1) and 11(3) of the Law on NBP, which provide for Narodowy Bank Polski’s 
right to participate in international financial and banking institutions, do not recognise 
the ECB’s powers in this field. 
Miscellaneous 
Article 9(3) of the Law on NBP, which specifies the wording of the oath sworn by 
Narodowy Bank Polski’s President, needs to be adapted to comply with Article 14.3 of 
the Statute. 
With regard to Article 21(4) of the Law on NBP, which provides for Narodowy Bank 
Polski’s rights to present its opinion on draft legislation concerning the activity of banks 
and having significance to the banking system, it is noted that consulting Narodowy 
Bank Polski does not obviate the need to consult the ECB under Articles 127(4) and 
282(5) of the Treaty. 
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7.5.6 Conclusions 
The Polish Constitution, the Law on NBP and the Law on the State Tribunal do not 
comply with all the requirements of central bank independence, confidentiality, the 
monetary financing prohibition and legal integration into the Eurosystem. Poland is a 
Member State with a derogation and must therefore comply with all adaptation 
requirements under Article 131 of the Treaty.293 
7.6 Romania 
7.6.1 Compatibility of national legislation 
The following legislation forms the legal basis for Banca Naţională a României and its 
operations: 
• Law No 312/2004 on the Statute of Banca Naţională a României (hereinafter the 
“Law on BNR”).294 
There have been no changes in relation to the points identified in the ECB’s 
Convergence Report of June 2020 concerning the Law on BNR, and therefore those 
comments are repeated in this year’s assessment. 
7.6.2 Independence of the NCB 
With regard to Banca Naţională a României’s independence, the Law on BNR and 
other legislation needs to be adapted in the respects set out below. 
Institutional independence 
Article 3(1) of the Law on BNR provides that, when carrying out their tasks, Banca 
Naţională a României and the members of its decision-making bodies may not seek or 
take instructions from public authorities or from any other institution or authority. The 
ECB understands that the provision encompasses both national and foreign 
institutions in line with Article 130 of the Treaty and Article 7 of the Statute. For legal 
certainty reasons, the next amendment to the Law on BNR should bring this provision 
fully in line with Article 130 of the Treaty and Article 7 of the Statute. 
Further, Article 3 of the Law on BNR does not expressly prohibit the Government from 
seeking to influence the members of Banca Naţională a României’s decision-making 
bodies in situations where this may have an impact on Banca Naţională a României’s 
 
293  For a detailed review of necessary adaptations of the Constitution, the Law on NBP and other laws, see 
Opinion CON/2011/9. 
294  Published in Monitorul Oficial al României, Part One, No 582, 30.6.2004. 
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fulfilment of its ESCB-related tasks. In this respect the Law on BNR needs to be 
adapted to be fully consistent with Article 130 of the Treaty and Article 7 of the Statute. 
Personal independence
Article 33(9) of the Law on BNR provides that an appeal may be brought to the High 
Court of Cassation and Justice against a decision to recall from office a member of the 
Board of Banca Naţională a României within 15 days of its publication in Monitorul 
Oficial al României. The Law on BNR is silent on the jurisdiction of the Court of Justice 
of the European Union to hear cases with regard to the dismissal of the Governor. The 
ECB understands that in spite of this silence, Article 14.2 of the Statute applies. 
Article 33(7) of the Law on BNR provides that no member of the Board of Banca 
Naţională a României may be recalled from office for reasons other than or following a 
procedure other than those provided for in Article 33(6) of the Law on BNR. Article 
33(6) of the Law on BNR contains grounds for dismissal which are compatible with 
those laid down in Article 14.2 of the Statute. Law 161/2003 on certain measures for 
transparency in the exercise of public dignities, public functions and business 
relationships and for the prevention and sanctioning of corruption,295 and Law 
176/2010 on the integrity in the exercise of public functions and dignities,296 define the 
conflicts of interest and incompatibilities applicable to the Governor and the other 
members of the Board of Banca Naţională a României and require them to report on 
their interests and wealth. The ECB understands that the sanctions provided for in 
these Laws for the breach of such obligations as well as the automatic resignation 
mechanism in cases of incompatibility297 do not constitute new grounds for dismissal 
of the Governor or other members of the Board of Banca Naţională a României in 
addition to those contained in Article 33 of the Law on BNR. For legal certainty 
reasons and in line with Article 33 of the Law on BNR, a clarification to this end in the 
above-mentioned Laws would be welcome. 
Financial independence
Article 43 of the Law on BNR provides that each month, Banca Naţională a României
must transfer to the State budget an 80% share of the net revenues left after deducting 
expenses relating to the financial year, including provisions for credit risk, and any 
losses relating to previous financial years that remain uncovered. As noted in Chapter 
7.6.4, this arrangement may in certain circumstances amount to an intra-year credit, 
which in turn may undermine the financial independence of Banca Naţională a 
României. 
295  Published in Monitorul Oficial al României, Part One, No 279, 21.4.2003. 
296  Published in Monitorul Oficial al României, Part One, No 621, 2.9.2010. 
297  According to the relevant provisions of Article 99 of Law 161/2003, if a member of the Board of Banca
Naţională a României or an employee occupying a leading position with Banca Naţională a României 
does not choose within a given period of time between their function and the one which they have 
declared to be incompatible with their function, they are considered to have resigned from their function 
and the Parliament takes note of the resignation.
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214 
A Member State may not put its NCB in a position where it has insufficient financial 
resources to carry out its ESCB or Eurosystem-related tasks, and also its own national 
tasks, such as financing its administration and own operations. 
Article 43(3) of the Law on BNR also provides that Banca Naţională a României sets 
up provisions for credit risk in accordance with its rules, after having consulted the 
Ministry of Public Finance. The ECB notes that NCBs must be free to independently 
create financial provisions to safeguard the real value of their capital and assets. 
Article 43 of the Law on BNR should therefore be adapted, in addition to taking into 
account the issues highlighted in Chapter 7.6.4, to ensure that such arrangement does 
not undermine the ability of Banca Naţională a României to carry out its tasks in an 
independent manner. 
Pursuant to Articles 21 and 23 of Law 94/1992 on the organisation and functioning of 
the Court of Auditors,298 the Court of Auditors is empowered to control the 
establishment, management and use of the public sector’s financial resources, 
including Banca Naţională a României’s financial resources, and to audit the 
management of the funds of Banca Naţională a României. The scope of audit by the 
Court of Auditors is further defined in Article 47(2) of the Law on BNR, which provides 
that commercial operations performed by Banca Naţională a României, as shown in 
the revenue and expenditure budget and in the annual financial statements, shall be 
subject to auditing by the Court of Auditors. As the provisions of Law 94/1992 on the 
organisation and functioning of the Court of Auditors expressly apply to Banca 
Naţională a României, in the interests of legal certainty it should be clarified in 
Romanian legislation that the scope of audit by the Court of Auditors is provided by 
Article 47(2) of the Law on BNR and is therefore limited to commercial operations 
performed by Banca Naţională a României.299 
7.6.3 Confidentiality 
Pursuant to Article 52(2) of the Law on BNR, the Governor may release confidential 
information on the four grounds listed. Under Article 37 of the Statute, professional 
secrecy is an ESCB-wide matter. Therefore, the ECB assumes that such release is 
without prejudice to the confidentiality obligations towards the ECB and the ESCB. 
7.6.4 Monetary financing and privileged access 
Articles 6(1) and 29(1) of the Law on BNR expressly prohibit direct purchase on the 
primary market by Banca Naţională a României of debt instruments issued by the 
State, central and local public authorities, autonomous public service undertakings, 
national societies, national companies and other majority State-owned companies. 
Such prohibition has been extended by Article 6(2) to other bodies governed by public 
law and public undertakings in Member States. Furthermore, under Article 7(2) of the 
 
298  Published in Monitorul Oficial al României, Part One, No 238, 3.4.2014. 
299  For the activities of the NCB’s independent external auditors see, for example, Article 27.1 of the Statute. 
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215 
Law on BNR, Banca Naţională a României is prohibited from granting overdraft 
facilities or any other type of credit facility to the State, central and local public 
authorities, autonomous public service undertakings, national societies, national 
companies and other majority State-owned companies. Article 7(4) extends this 
prohibition to other bodies governed by public law and public undertakings in Member 
States. The range of public sector entities referred to in these provisions needs to be 
extended to be consistent with and fully mirror Article 123 of the Treaty and aligned 
with the definitions contained in Regulation (EC) No 3603/93. 
Pursuant to Article 7(3) of the Law on BNR, majority State-owned credit institutions are 
exempted from the prohibition on granting overdraft facilities and any other type of 
credit facility in Article 7(2) and benefit from loans granted by Banca Naţională a 
României in the same way as any other credit institution eligible under Banca 
Naţională a României’s regulations. The wording of Article 7(3) of the Law on BNR 
should be aligned with the wording of Article 123(2) of the Treaty, which only exempts 
publicly owned credit institutions “in the context of the supply of reserves by central 
banks”. 
Article 26 of the Law on BNR provides that, to carry out its task of ensuring financial 
stability, in exceptional cases and only on a case-by-case basis, Banca Naţională a 
României may grant to credit institutions loans which are unsecured or secured by 
assets other than assets eligible to collateralise the monetary or foreign exchange 
policy operations of Banca Naţională a României. Article 26 does not contain sufficient 
safeguards to prevent such lending from potentially breaching the monetary financing 
prohibition contained in Article 123 of the Treaty, especially given the risk that such 
lending could result in the provision of solvency support to a credit institution 
experiencing financial difficulties, and should be adapted accordingly. 
Article 43 of the Law on BNR provides that Banca Naţională a României must transfer 
to the State budget an 80% share of the net revenues left after deducting expenses 
relating to the financial year, including provisions for credit risk, and losses related to 
the previous financial years that remained uncovered. The 80% of the net revenues is 
transferred monthly before the 25th day of the following month, based on a special 
statement. The adjustments relating to the financial year are performed by the 
deadline for submission of the annual balance sheet, based on a rectifying special 
statement. This provision is constructed in a way which does not rule out the possibility 
of an intra-year anticipated profit distribution in circumstances where Banca Naţională 
a României accumulates profits during the first half of the year but suffers consecutive 
losses during the second half of the year. Although the State is under an obligation to 
make adjustments after the closure of the financial year and would therefore have to 
return any excessive distributions to Banca Naţională a României, this would only 
happen after the deadline for submission of the annual balance sheet and may 
therefore be viewed as amounting to an intra-year credit to the State. Article 43 should 
be adapted to ensure that such an intra-year credit is not possible to rule out the 
possibility of breaching the monetary financing prohibition in Article 123 of the Treaty. 
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7.6.5 Legal integration of the NCB into the Eurosystem
With regard to Banca Naţională a României’s legal integration into the Eurosystem, 
the Law on BNR needs to be adapted in the respects set out below. 
Economic policy objectives
Article 2(3) of the Law on BNR provides that, without prejudice to the primary objective 
of price stability, Banca Naţională a României must support the State’s general 
economic policy. This provision is incompatible with Article 127(1) of the Treaty, as it 
does not reflect the ESCB’s secondary objective of supporting the general economic 
policies in the Union. 
Tasks
Monetary policy 
Article 2(2)(a), Article 5, Articles 6(3) and 7(1), Articles 8, 19 and 20 and Article 
33(1)(a) of the Law on BNR, which provide for the powers of Banca Naţională a 
României in the field of monetary policy and instruments for the implementation 
thereof, do not recognise the ECB’s powers in this field.
Collection of statistics 
Article 49 of the Law on BNR, which provides for the powers of Banca Naţională a 
României relating to the collection of statistics, does not recognise the ECB’s powers
in this field. 
Official foreign reserve management 
Articles 2(2)(e) and 9(2)(c) and Articles 30 and 31 of the Law on BNR, which provide 
for the powers of Banca Naţională a României relating to foreign reserve 
management, do not recognise the ECB’s powers in this field. 
Payment systems 
Article 2(2)(b), Article 22 and Article 33(1)(b) of the Law on BNR, which provide for the 
role of Banca Naţională a României in relation to the smooth operation of payment 
systems, do not recognise the ECB’s powers in this field.
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217 
Issue of banknotes 
Article 2(2)(c) and Articles 12 to 18 of the Law on BNR, which provide for Banca 
Naţională a României’s role in issuing banknotes and coins, do not recognise the 
Council’s and the ECB’s powers in this field. 
Financial provisions 
Appointment of independent auditors 
Article 36(1) of the Law on BNR, which provides that the annual financial statements of 
Banca Naţională a României are audited by financial auditors that are legal entities 
authorised by the Financial Auditors Chamber in Romania and selected by the Board 
of Banca Naţională a României through a tender procedure, does not recognise the 
ECB’s and the Council’s powers under Article 27.1 of the Statute. 
Financial reporting 
Article 37(3) of the Law on BNR, which provides that Banca Naţională a României 
establishes the templates for the annual financial statements after having consulted 
the Ministry of Public Finance, and Article 40 of the Law on BNR, which provides that 
Banca Naţională a României adopts its own regulations on organising and conducting 
its accounting, in compliance with the legislation in force and having regard to the 
advisory opinion of the Ministry of Public Finance, and that Banca Naţională a 
României registers its economic and financial operations in compliance with its own 
chart of accounts, also having regard to the advisory opinion of the Ministry of Public 
Finance, do not reflect Banca Naţională a României’s obligation to comply with the 
Eurosystem’s regime for financial reporting of NCB operations, pursuant to Article 26 
of the Statute. 
Exchange rate policy 
Article 2(2)(a) and (d), Article 9 and Article 33(1)(a) of the Law on BNR, which 
empower Banca Naţională a României to conduct exchange rate policy, do not 
recognise the Council’s and the ECB’s powers in this field. 
Articles 10 and 11 of the Law on BNR, which allow Banca Naţională a României to 
draw up regulations on monitoring and controlling foreign currency transactions in 
Romania and to authorise foreign currency capital operations, transactions on foreign 
currency markets and other specific operations, do not recognise the Council’s and 
the ECB’s powers in this field. 
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7.6.6 Miscellaneous
With regard to Article 3(2) of the Law on BNR, which entitles Banca Naţională a
României to be consulted on draft national legislation, consulting Banca Naţională a 
României does not obviate the need to consult the ECB under Articles 127(4) and 
282(5) of the Treaty. 
Article 57 of the Law on BNR does not recognise the ECB’s powers to impose 
sanctions. 
Article 4(5) of the Law on BNR entitles Banca Naţională a României to conclude 
short-term credit arrangements and to perform other financial and banking operations 
with other entities, including central banks, and provides that such arrangements are 
possible only if the credit is repaid within one year. The ECB notes that such a 
limitation is not foreseen in Article 23 of the Statute. 
7.6.7 Conclusions
The Law on BNR does not comply with all the requirements for central bank 
independence, the monetary financing prohibition and legal integration into the 
Eurosystem. Romania is a Member State with a derogation and must therefore comply 
with all adaptation requirements under Article 131 of the Treaty. 
7.7 Sweden
7.7.1 Compatibility of national legislation
The following legislation forms the legal basis for Sveriges Riksbank and its 
operations: 
• the Instrument of Government,300 which forms part of the Swedish Constitution,
• the Law on Sveriges Riksbank,301
• the Law on exchange rate policy.302
The ECB notes that a proposal for a new Law on Sveriges Riksbank, together with 
proposed amendments to the Instrument of Government, the Law on exchange rate 
policy and other legislation have been included in the Swedish Government’s Official
Report published on 29 November 2019.303 
300  SFS 1974:152. 
301  SFS 1988:1385. 
302  SFS 1998:1404.
303  SOU 2019:46 – En ny riksbankslag (A new Law on Sveriges Riksbank). 
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On 20 April 2020, the ECB delivered an opinion on the proposed reform of Sveriges 
Riksbank.304 It states that any legislative reform in Sweden should aim to gradually 
achieve legal convergence with, rather than divergence from, ESCB standards, in 
accordance with the convergence process obligations enshrined in the Treaty. 
In particular, the Parliament’s (Sveriges Riksdag) right to approve or reject Sveriges
Riksbank’s decisions on the design of the price stability objective would be 
inconsistent with Article 130 of the Treaty. Furthermore, a narrow conceptualisation of 
monetary policy and broad conceptualisation of financial stability under the draft law, 
combined with the prohibition on Sveriges Riksbank seeking and taking instructions 
applying only within the narrowly defined area of monetary policy, does not provide the 
legally required compatibility with the Treaties and the Statute. The ECB has 
expressed particular concern that, under the draft law, Sveriges Riksbank may only 
build up its foreign reserves for financial stability purposes. The constraints on 
Sveriges Riksbank’s ability to increase its foreign reserves whenever necessary, 
through appropriate means, in pursuance of its independently formulated monetary, 
foreign exchange and liquidity policies encroach on Sveriges Riksbank’s
independence under the Treaty and Statute in the performance of its basic monetary, 
foreign exchange and liquidity policies. 
The Swedish Government submitted a revised legislative proposal to Sveriges 
Riksdag on 28 October 2021,305 where it is now being processed. However, no 
changes have yet been made to Swedish legislation in relation to the points identified 
in the ECB’s Convergence Report of June 2020, and the proposed new Law on 
Sveriges Riksbank and the proposed amendments to the Instrument of Government 
and the Law on exchange rate policy are only intended to enter into force in 2023, 
according to the current legislative proposal. Therefore, the comments made in the 
ECB’s Convergence Report of June 2020 are largely repeated in this year’s
assessment. 
7.7.2 Independence of the NCB
With regard to Sveriges Riksbank’s independence, the Law on Sveriges Riksbank 
needs to be adapted in the respects set out below. 
Institutional independence
Article 13 of Chapter 9 of the Instrument of Government states that Sveriges Riksbank 
is an authority under the Riksdag. Article 2 of Chapter 3 of the Law on Sveriges 
Riksbank, which prohibits the members of the Executive Board from seeking or taking 
of instructions, and Article 13 of Chapter 9 of the Instrument of Government, which 
prohibits any authority from giving instructions to Sveriges Riksbank, do not cover all 
304  Opinion CON/2020/13. 
305  Regeringens proposition 2021/22:41 – En ny riksbankslag (A new Law on Sveriges Riksbank). 
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ESCB-related tasks, as required by Article 130 of the Treaty and Article 7 of the 
Statute. 
Although the explanatory memorandum to the Law on Sveriges Riksbank extends the 
coverage to all ESCB-related tasks, it would be beneficial if this issue and the relation 
with Article 13 of Chapter 9 of the Instrument of Government were addressed in the 
next amendments to the relevant provisions of Swedish legislation. 
In addition, pursuant to Article 13(1) of Chapter 8 of the Instrument of Government, the 
Parliament may direct Sveriges Riksbank in an act of law within its sphere of 
responsibility under Chapter 9 (Financial power) to adopt provisions concerning its 
duty to promote a secure and efficient payments system. The ECB understands that 
this provision only enables the Parliament to assign the adoption of regulations to 
Sveriges Riksbank within the Sveriges Riksbank’s areas of responsibility for
promoting secure and efficient payment systems. 
Article 3 of Chapter 6 of the Law on Sveriges Riksbank, which establishes the right of 
the minister appointed by the Swedish Government to be informed prior to Sveriges 
Riksbank making a monetary policy decision of major importance, could potentially 
breach the prohibition on giving instructions to the NCBs pursuant to Article 130 of the 
Treaty and Article 7 of the Statute. Article 3 of Chapter 6 of the Law on Sveriges 
Riksbank should therefore be adapted accordingly. The Swedish Government has 
referred the issue to the Parliamentary Committee on Sveriges Riksbank, which has 
investigated how the Swedish Government may continue to be kept informed of 
monetary policy decisions of major importance without restricting the independence of 
Sveriges Riksbank. The conclusions of that investigation, including the relevant 
proposals, were presented in the Swedish Government’s Official Report referred to in 
Section 7.7.1. 
Financial independence
In accordance with Article 3 of Chapter 10 of the Law on Sveriges Riksbank, the 
General Council of Sveriges Riksbank submits proposals to the Swedish Parliament 
and the Swedish National Audit Office on the allocation of Sveriges Riksbank’s profit. 
Pursuant to Article 4 of Chapter 10 of the Law on Sveriges Riksbank, the Swedish 
Parliament then determines the allocation of Sveriges Riksbank’s profit. These 
provisions are supplemented by non-statutory guidelines on profit distribution, which 
state that Sveriges Riksbank should pay 80% of its profit to the Swedish State, after 
adjustment for exchange rate and gold valuation effects and based on a five-year 
average, with the remaining 20% used to increase its own capital. However, these 
guidelines are not legally binding and there is no statutory provision limiting the 
amount of profit that may be paid out. 
The present arrangements on profit distribution have been reviewed. The Swedish 
Government submitted a draft legislative proposal to strengthen the Sveriges 
Riksbank’s financial independence and balance sheet, which the ECB has reviewed 
Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 419 –
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and commented on.306 After receiving extensive comments on the proposal from a 
number of consultation bodies, the Swedish Government appointed the Parliamentary 
Committee on Sveriges Riksbank to further investigate the matters addressed in the 
draft legislative proposal as well as to propose appropriate amendments to the Law on 
Sveriges Riksbank in order to enhance the financial independence and balance sheet 
of Sveriges Riksbank. The conclusions of that investigation, including the relevant 
proposals, were presented in the Swedish Government’s Official Report referred to in 
Section 7.7.1. However, as the legislation currently stands, it is incompatible with the 
requirement of central bank independence in Article 130 of the Treaty and Article 7 of 
the Statute. To safeguard Sveriges Riksbank’s financial independence, statutory 
provisions should be adopted containing clear provisions concerning the limitations 
applicable to the Swedish Parliament’s decisions on Sveriges Riksbank’s profit
allocation. 
7.7.3 Monetary financing prohibition
Article 1(3) of Chapter 8 of the Law on Sveriges Riksbank provides that Sveriges 
Riksbank may not extend credit or purchase debt instruments directly from the State, 
another public body or a Union institution. Although the explanatory memorandum to 
the Law on Sveriges Riksbank, which according to Swedish legal tradition will be 
closely followed by Swedish courts when interpreting national legislation, states that 
the coverage is extended to Union bodies and the public sector including public 
undertakings of other Member States, it would be beneficial if this issue could be 
addressed when the Law on Sveriges Riksbank is next amended, to bring it fully in line 
with Article 123 of the Treaty. 
In addition, Article 1(4) of Chapter 8 of the Law on Sveriges Riksbank provides that 
“subject to other provisions in this Law, the Riksbank may also grant credit to and 
purchase debt instruments from financial institutions owned by the State or another 
public body”. The wording of Article 1(4) of Chapter 8 of the Law on Sveriges Riksbank 
should be aligned with the wording of Article 123(2) of the Treaty, which only exempts 
publicly owned credit institutions from the prohibition on monetary financing in respect 
of the supply of reserves by central banks; the central bank may not supply reserves to 
other public financial institutions. In the same vein, the range of public sector entities 
would need to be made consistent with Article 123(2) of the Treaty, and the ECB 
suggests, for reasons of legal certainty, inserting a reference to Article 123 of the 
Treaty in Article 1 of Chapter 8 of the Law on Sveriges Riksbank. 
As noted above, the provisions of the Law on the allocation of Sveriges Riksbank’s
profit are supplemented by non-statutory guidelines on profit distribution, that are not 
legally binding, and state that Sveriges Riksbank should pay 80% of its profit to the 
Swedish State, after adjustment for exchange rate and gold valuation effects and 
based on a five-year average, with the remaining 20% used to increase its own capital. 
It is essential for the five-year average rule to be applied in a way which remains 
consistent with the prohibition on monetary financing under Article 123 of the Treaty, 
306  See Opinion CON/2017/17. 
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i.e. only as a calculation method and a cap for the NCB’s profit distribution to the State
budget. Statutory provisions providing for necessary limitations and ensuring that a 
breach of the monetary financing prohibition may not occur in this respect should also 
be adopted. To comply with the monetary financing prohibition, the amount distributed 
to the State budget pursuant to the applicable profit distribution rules cannot be paid, 
even partially, from the NCB’s reserve capital. Therefore, profit distribution rules 
should leave unaffected the NCB’s reserve capital. 
7.7.4 Legal integration of the NCB into the Eurosystem
With regard to Sveriges Riksbank’s legal integration into the Eurosystem, the Law on 
Sveriges Riksbank, the Constitution and the Law on exchange rate policy need to be 
adapted in the respects set out below. 
Economic policy objectives
Article 2 of Chapter 1 of the Law on Sveriges Riksbank provides that Sveriges 
Riksbank’s objective is to maintain price stability. The ECB notes that Article 2 should 
reflect the ESCB’s secondary objective of supporting the general economic policies of 
the Union in line with Article 127(1) of the Treaty and Article 2 of the Statute. 
Article 2 of Chapter 1 of the Law on Sveriges Riksbank provides that Sveriges 
Riksbank shall promote a safe and efficient payments system. The ECB notes that 
insofar as this is a task and not an objective of the Sveriges Riksbank, there is no need 
to subordinate it to the ESCB’s primary and secondary objectives.
Tasks
Article 1 of Chapter 1 of the Law on Sveriges Riksbank, which provides that Sveriges 
Riksbank may only conduct, or participate in, such activities for which it has been 
authorised by Swedish law, is incompatible with the provisions of the Treaty and the 
Statute as it does not provide for Sveriges Riksbank’s legal integration into the 
Eurosystem. 
Monetary policy 
Article 13 of Chapter 9 of the Instrument of Government and Article 2 of Chapter 1 of 
the Law on Sveriges Riksbank, which establish Sveriges Riksbank’s powers in the
field of monetary policy, do not recognise the ECB’s powers in this field.
Articles 2, 5 and 6 of Chapter 6 of the Law on Sveriges Riksbank, which provide for 
Sveriges Riksbank’s powers in the field of monetary policy, do not recognise the 
ECB’s powers in this field.
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Article 6 of Chapter 6 and Articles 1 and 2a of Chapter 11 of the Law on Sveriges 
Riksbank, concerning the imposition of minimum reserves on financial institutions and 
the payment of a special fee to the Swedish State in the event of a breach of this 
requirement, do not recognise the ECB’s powers in this field.
Collection of statistics 
Article 4(2) and Articles 9, 10 and 11307 of Chapter 6 of the Law on Sveriges Riksbank, 
which establish Sveriges Riksbank’s powers relating to the collection of statistics, do 
not recognise the ECB’s powers in this field.
Official foreign reserve management 
Chapter 7 of the Law on Sveriges Riksbank, and Article 12 of Chapter 9 of the 
Instrument of Government, which provide for Sveriges Riksbank’s powers in the field
of foreign reserve management, do not recognise the ECB’s powers in this field.
Payment systems 
The second sentence of Article 14 of Chapter 9 of the Instrument of Government and 
Article 2 of Chapter 1 and Article 7 of Chapter 6 of the Law on Sveriges Riksbank, 
which establish Sveriges Riksbank’s powers with regard to the smooth operation of 
payment systems, do not recognise the ECB’s powers in this field.
Issue of banknotes 
Article 14 of Chapter 9 of the Instrument of Government and Chapter 5 of the Law on 
Sveriges Riksbank, which lay down Sveriges Riksbank’s exclusive right to issue 
banknotes and coins, do not recognise the Council’s and the ECB’s powers in this 
field. 
Financial provisions
Appointment of independent auditors 
The Law on Sveriges Riksbank does not recognise the Council’s and the ECB’s
powers under Article 27.1 of the Statute. 
307  These articles have been introduced in Chapter 6 of the Law on Sveriges Riksbank by amendments
which entered into force in June 2014 (SFS 2014:485).
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Exchange rate policy
Article 12 of Chapter 9 of the Instrument of Government and Chapter 7 of the Law on 
Sveriges Riksbank, together with the Law on exchange rate policy, lay down the 
powers of the Swedish Government and Sveriges Riksbank in the area of exchange 
rate policy. These provisions do not recognise the Council’s and the ECB’s powers in 
this field. 
International cooperation
Pursuant to Article 6 of Chapter 7 in the Law on Sveriges Riksbank, Sveriges 
Riksbank may serve as a liaison body in relation to international financial institutions of 
which Sweden is a member. This provision does not recognise the ECB’s powers in 
this field. 
Miscellaneous
With regard to Article 4 of Chapter 2 of the Law on Sveriges Riksbank, which provides 
for the General Council’s right to submit consultation opinions on behalf of Sveriges 
Riksbank within its area of competence, it is noted that consulting Sveriges Riksbank 
does not obviate the need to consult the ECB under Articles 127(4) and 282(5) of the 
Treaty. 
As specified in Chapter 2.2.4, the primacy of Union law and rules adopted thereunder 
also means that national laws on access by third parties to documents may not lead to 
infringements of the ESCB’s confidentiality regime. The ECB understands that the 
Public Access to Information and Secrecy Act 308 and any other relevant Swedish 
legislation will permit Sveriges Riksbank to apply it in a manner that ensures 
compliance with the ESCB’s confidentiality regime.
7.7.5 Conclusions
The Law on Sveriges Riksbank, the Swedish Instrument of Government and the Law 
on exchange rate policy do not comply with all the requirements for central bank 
independence, the monetary financing prohibition and legal integration into the 
Eurosystem. Sweden is a Member State with a derogation and must therefore comply 
with all adaptation requirements under Article 131 of the Treaty. The ECB notes that 
the Treaty has obliged Sweden to adopt national legislation for integration into the 
Eurosystem since 1 June 1998. Over the years no legislative action has been taken by 
the Swedish authorities to remedy the incompatibilities described in this and previous 
reports. At present it is not clear to what extent the legislative proposal referred to in 
Section 7.7.1 may result in such legislative action. Although the proposals contained in 
308  SFS 2009:400. 
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that legislative proposal should aim to achieve the required legal convergence, they 
would not do so as they stand.309 
309  Opinion CON/2020/13. 
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Convergence Report, June 2022 226 
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Deutscher Bundestag – 20. Wahlperiode Drucksache 20/2296– 425 –

EN EN
Anlage 4 
EUROPEAN 
COMMISSION 
Brussels, 1.6.2022 
COM(2022) 282 final 
2022/0179 (NLE) 
Proposal for a 
COUNCIL DECISION 
on the adoption by Croatia of the euro on 1 January 2023 
EN EN
EXPLANATORY MEMORANDUM 
1. CONTEXT OF THE PROPOSAL
On 3 May 1998, the Council decided that Belgium, Germany, Spain, France, Ireland, Italy, 
Luxembourg, the Netherlands, Portugal, Austria and Finland fulfilled the necessary conditions 
for the adoption of the euro on 1 January 1999. Denmark and the United Kingdom made use 
of their opt-out clauses and were therefore not assessed by the Council. Greece and Sweden 
were considered by the Council as Member States with a derogation. 
On 19 June 2000, the Council decided that Greece fulfilled the necessary conditions to adopt 
the euro on 1 January 2001. The countries that joined the European Union on 1 May 2004 (the 
Czech Republic, Estonia, Cyprus, Latvia, Lithuania, Hungary, Malta, Poland, Slovenia and 
Slovakia) became Member States with a derogation in accordance with Article 4 of the 
respective Act of Accession. 
On 11 July 2006, the Council decided that Slovenia fulfilled the necessary conditions to adopt 
the euro on 1 January 2007. 
Bulgaria and Romania, who joined the European Union on 1 January 2007, became Member 
States with a derogation in accordance with Article 5 of the respective Act of Accession. 
On 10 July 2007, the Council decided that Cyprus and Malta fulfilled the necessary conditions 
to adopt the euro on 1 January 2008. 
On 8 July 2008, the Council decided that Slovakia fulfilled the necessary conditions for 
adopting the euro as of 1 January 2009. 
On 13 July 2010, the Council decided that Estonia fulfilled the necessary conditions for 
adopting the euro as of 1 January 2011. 
Croatia joined the European Union on 1 July 2013 and became a Member State with a 
derogation in accordance with Article 5 of the Act of Accession. 
On 9 July 2013, the Council decided that Latvia fulfilled the necessary conditions for adopting 
the euro as of 1 January 2014. 
On 23 July 2014, the Council decided that Lithuania fulfilled the necessary conditions for 
adopting the euro as of 1 January 2015. 
Article 140(1) of the Treaty on the Functioning of the European Union ('the Treaty') states that 
at least once every two years or at the request of a Member State with a derogation, the 
Commission and the European Central Bank have to report to the Council on the progress made 
by Member States with a derogation in fulfilling their obligations regarding the achievement of 
economic and monetary union. 
Based on its own report and that of the ECB, the Commission should submit to the Council a 
proposal for a Council decision, in accordance to the procedure laid down in Article 140(2) of 
the Treaty, to abrogate the derogation of the Member States fulfilling the necessary conditions. 
Both the Commission and the ECB convergence reports were released on 1 June 2022. The 
reports include an examination of the compatibility between Croatia's national legislation, 
including the statutes of its national central bank, with Articles 130 and 131 of the Treaty and 
the Statute of the ESCB and of the ECB. 
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The reports also examine whether a high degree of sustainable convergence has been achieved, 
by reference to the fulfilment of the convergence criteria, and take account of several other 
factors required under the final sub-paragraph of Article 140(1) of the Treaty. 
In its convergence report, the Commission concludes that Croatia fulfils the conditions for the 
adoption of the euro. 
On the basis of its report and that of the ECB, the Commission has adopted the attached proposal 
for a Council decision to abrogate the derogation of Croatia, with effect from 1 January 
2023. 
2. RESULTS OF CONSULTATIONS WITH THE INTERESTED PARTIES AND
IMPACT ASSESSMENT
Discussions with Member States on economic policy challenges in Member States are held 
under various headings on a regular basis in the Economic and Financial Committee (EFC) and 
the ECOFIN/Eurogroup. These include informal discussions on issues specifically relevant to 
the preparation of eventual euro-area entry (including exchange rate policies). Dialogue with 
academics and other interested groups takes place in conferences/seminars and on an ad-hoc 
basis. 
Economic developments in the euro area and the Member States are assessed through the 
various procedures of economic policy coordination and surveillance (notably under Art. 121 
of the Treaty), as well as in the context of the Commission’s regular monitoring and analysis of 
country-specific and area-wide developments (including forecasts, regular publication series, 
and input to the EFC and ECOFIN/Eurogroup). In accordance with the proportionality principle 
and in line with past practice, no formal impact assessment has been carried out. 
3. LEGAL ELEMENTS OF THE PROPOSAL
3.1. Legal basis
The legal basis for this proposal is Article 140(2) of the Treaty, which lays down the procedure 
for a Council decision on euro adoption and for abrogating the derogation in the concerned 
Member States. 
The Council shall act on a proposal from the Commission, after consulting the European 
Parliament, after discussion in the European Council and after having received a 
recommendation of a qualified majority of those among its members representing Member 
States whose currency is the euro. 
3.2. Subsidiarity and proportionality 
The proposal falls under the exclusive competence of the Union. The subsidiarity principle 
therefore does not apply. 
This initiative does not go beyond what is necessary to achieve its objective and, therefore, 
complies with the proportionality principle. 
3.3. Choice of legal instrument 
A Decision is the only appropriate legal instrument according to Article 140(2) of the Treaty. 
4. BUDGETARY IMPLICATION
The proposal has no implications for the budget of the Union.
2
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2022/0179 (NLE) 
Proposal for a 
COUNCIL DECISION 
on the adoption by Croatia of the euro on 1 January 2023 
THE COUNCIL OF THE EUROPEAN UNION, 
Having regard to the Treaty on the Functioning of the European Union, and in particular 
Article 140(2) thereof, 
Having regard to the proposal from the European Commission, 
Having regard to the report from the European Commission (1) 
Having regard to the report from the European Central Bank (2) 
Having regard to the opinion of the European Parliament, 
Having regard to the discussion in the European Council, 
Having regard to the recommendation of the members of the Council representing Member 
States whose currency is the euro, 
Whereas: 
(1) The third stage of economic and monetary union (‘EMU’) started on 1 January 1999.
The Council, meeting in Brussels on 3 May 1998 in the composition of Heads of State
or Government, decided that Belgium, Germany, Spain, France, Ireland, Italy,
Luxembourg, the Netherlands, Austria, Portugal and Finland fulfilled the necessary
conditions for adopting the euro on 1 January 1999 (3).
(2) By Decision 2000/427/EC (4) the Council decided that Greece fulfilled the necessary
conditions for adopting the euro on 1 January 2001. By Decision 2006/495/EC (5) the
Council decided that Slovenia fulfilled the necessary conditions for adopting the euro
on 1 January 2007. By Decisions 2007/503/EC (6) and 2007/504/EC (7) the Council
decided that Cyprus and Malta fulfilled the necessary conditions for adopting the euro
on 1 January 2008. By decision 2008/608/EC (8) the Council decided that Slovakia
(1) Report of 1 June 2022 (not yet published in the Official Journal).
(2) Report of 1 June 2022 (not yet published in the Official Journal).
(3) Council Decision 98/317/EC of 3 May 1998 in accordance with Article 109j(4) of the Treaty (OJ L 139,
11.5.1998, p. 30).
(4) Council Decision 2000/427/EC of 19 June 2000 in accordance with Article 122(2) of the Treaty on the
adoption by Greece of the single currency on 1 January 2001 (OJ L 167, 7.7.2000, p. 19).
(5) Council Decision 2006/495/EC of 11 July 2006 in accordance with Article 122(2) of the Treaty on the
adoption by Slovenia of the single currency on 1 January 2007 (OJ L 195, 15.7.2006, p. 25).
(6) Council Decision 2007/503/EC of 10 July 2007 in accordance with Article 122(2) of the Treaty on the
adoption by Cyprus of the single currency on 1 January 2008 (OJ L 186, 18.7.2007, p. 29).
(7) Council Decision 2007/504/EC of 10 July 2007 in accordance with Article 122(2) of the Treaty on the
adoption by Malta of the single currency on 1 January 2008 (OJ L 186, 18.7.2007, p. 32).
(8) Council Decision 2008/608/EC of 8 July 2008 in accordance with Article 122(2) of the Treaty on the
adoption by Slovakia of the single currency on 1 January 2009 (OJ L 195, 24.7.2008, p. 24).
3
EN EN
fulfilled the necessary conditions for adopting the euro. By decision 2010/416/EU (9) 
the Council decided that Estonia fulfilled the necessary conditions for adopting the euro. 
By decision 2013/387/EU (10) the Council decided that Latvia fulfilled the necessary 
conditions for adopting the euro. By decision 2014/509/EU (11) the Council decided that 
Lithuania fulfilled the necessary conditions for adopting the euro. 
(3) In accordance with paragraph 1 of the Protocol on certain provisions relating to Denmark
annexed to the Treaty establishing the European Community and the Decision taken by
the Heads of State or Government in Edinburgh in December 1992, Denmark has
notified the Council that it will not participate in the third stage of EMU. Denmark has
not requested that the procedure referred to in Article 140(2) of the Treaty on the
Functioning of the European Union (TFEU) be initiated.
(4) By virtue of Decision 98/317/EC Sweden has a derogation as defined in Article 139(1)
TFEU. In accordance with Article 4 of the 2003 Act of Accession (12), the Czech
Republic, Hungary and Poland have derogations as defined in Article 139(1) TFEU. In
accordance with Article 5 of the 2005 Act of Accession (13), Bulgaria and Romania have
derogations as defined in Article 139(1) TFEU. In accordance with Article 5 of the 2012
Act of Accession (14), Croatia has a derogation as defined in Article 139(1) TFEU.
(5) The European Central Bank (‘ECB’) was established on 1 July 1998. The European
Monetary System has been replaced by an exchange rate mechanism, the setting-up of
which was agreed by a resolution of the European Council on the establishment of an
exchange-rate mechanism in the third stage of economic and monetary union of 16 June
1997 (15). The procedures for an exchange-rate mechanism in stage three of economic
and monetary union (ERM II) were laid down in the Agreement of 16 March 2006
between the European Central Bank and the national central banks of the Member States
outside the euro area laying down the operating procedures for an exchange rate
mechanism in stage three of economic and monetary union.(16)
(6) Article 140(2) TFEU lays down the procedures for abrogation of the derogation of the
Member States concerned. At least  once every two years, or at the request  of a
Member State with a derogation, the Commission and the ECB shall report to the
Council in accordance with the procedure laid down in Article 140(1) TFEU.
(7) National legislation in the Member States, including the statutes of national central
banks, is to be adapted as necessary with a view to ensuring compatibility with Articles
130 and 131 TFEU and with the Statute of the European System of Central Banks and
of the European Central Bank (‘Statute of the ESCB and of the ECB’). The reports of
the Commission and the ECB provide a detailed assessment of the compatibility of the
legislation of Croatia with Articles 130 and 131 of the Treaty and with the Statute of the
ESCB and of the ECB.
(9) Council Decision 2010/416/EU of 13 July 2010 in accordance with Article 140(2) of the Treaty on the
adoption by Estonia of the euro on 1 January 2011 (OJ L 196, 28.7.2010, p. 24).
(10) Council Decision 2013/387/EU of 9 July 2013 on the adoption by Latvia of the euro on 1 January 2014
(OJ L 195, 18.7.2013, p. 24).
(11) Council Decision 2014/509/EU of 23 July 2014 on the adoption by Lithuania of the euro on 1 January
2014 (OJ L 228, 31.7.2014, p. 29).
(12) OJ L 236, 23.9.2003, p. 33.
(13) OJ L 157, 21.6.2005, p. 203.
(14) OJ L 112, 24.4.2012, p. 21.
(15) OJ C 236, 2.8.1997, p. 5.
(16) OJ C 73, 25.3.2006, p. 21.
4
EN EN
(8) In accordance with Article 1 of Protocol No 13 on the convergence criteria referred to
in Article 140 TFEU, the criterion on price stability referred to in the first indent of
Article 140(1) TFEU means that a Member State has a price performance that is
sustainable and an average rate of inflation, observed over a period of one year before
the examination, that does not exceed by more than one and a half percentage points that
of, at most, the three best performing Member States in terms of price stability. For the
purpose of the criterion on price stability, inflation is measured by the harmonised
indices of consumer prices (HICPs) defined in Regulation (EU) 2016/792 of the
European Parliament and of the Council (17). To assess the price stability criterion,
a Member State's inflation is measured by the percentage change in the arithmetic
average of 12 monthly indices, relative to the arithmetic average of 12 monthly indices
from the previous period. A reference value calculated as the simple arithmetic average
of the inflation rates of the three best-performing Member States in terms of price
stability, plus 1,5 percentage points, was used in the reports of the Commission and the
ECB. In the one-year period ending in April 2022, the inflation reference value was
calculated to be 4,9 per cent, with France, Finland and Greece as the three
bestperforming Member States in terms of price stability, with inflation rates of 3,2 per cent,
3,3 per cent and 3,6 per cent, respectively. It is warranted to exclude from the best
performers countries whose inflation rates cannot be seen as a meaningful benchmark
for other Member States. Such outliers were in the past identified in 2004, 2010, 2013,
2014 and 2016. Currently, it is warranted to exclude Malta and Portugal from the best
performers (18). For the calculation of the reference value, they are replaced by Finland
and Greece, the Member States with the next- lowest average inflation rates.
(9) In accordance with Article 2 of Protocol No 13, the criterion on the government
budgetary position referred to in the second indent of Article 140(1) TFEU requires that,
at the time of the examination, the Member State not be the subject of a Council decision
under Article 126(6) TFEU that an excessive deficit exists.
(10) In accordance with Article 3 of Protocol No 13, the criterion on participation in the
exchange-rate mechanism of the European Monetary System referred to in the third
indent of Article 140(1) TFEU requires a Member State to have complied with the
normal fluctuation margins provided for by the exchange-rate mechanism (ERM) of
the European Monetary System, without severe tensions, for at least the last two years
before the examination. In particular, the Member State must not have devalued its
currency's bilateral central rate against the euro on its own initiative for the same period.
Since 1 January 1999, the ERM II provides the framework for assessing the fulfilment
of the exchange rate criterion. In assessing the fulfilment of this criterion in their reports,
the Commission and the ECB have examined the two-year period ending on 18 May
2022.
(11) In accordance with Article 4 of Protocol No 13, the criterion on the convergence of
interest rates referred to in the fourth indent of Article 140(1) TFEU requires that,
observed over a period of one year before the examination, a Member State have had an
average nominal long-term interest rate that does not exceed by more than two
percentage points that of, at most, the three best performing Member States in terms of
(17) Regulation (EU) 2016/792 of the European Parliament and of the Council of 11 May 2016 on harmonised
indices of consumer prices and the house price index, and repealing Council Regulation (EC) No 2494/95 
(OJ L 135, 24.05.2016, p.11). 
(18) In April 2022, the 12-month average inflation rates of Malta and Portugal were respectively 2,1% and 2,6%
and that of the euro area 4,4%. 
5
EN EN
price stability. The criterion used to assess the convergence of interest rates was 
comparable interest rates on ten-year benchmark government bonds. To assess the 
fulfilment of the interest-rate criterion, a reference value calculated as the simple 
arithmetic average of the nominal long-term interest rates of the three best performing 
Member States in terms of price stability, plus two percentage points, was considered in 
the reports of the Commission and the ECB. The reference value is based on the
longterm interest rates in France (0,3 per cent), Finland (0,2 per cent) and Greece (1,4 per 
cent) and in the one-year period ending in April 2022 it was 2,6 per cent. 
(12) In accordance with Article 5 of Protocol No 13, the data used in assessing the fulfilment
of the convergence criteria is to be provided by the Commission. The Commission
provided that data. Budgetary data were provided by the Commission after reporting by
the Member States before 1 April 2022, in accordance with Council Regulation (EC)
No 479/2009. (19)
(13) On the basis of reports presented by the Commission and the ECB on the progress made
by Croatia in fulfiling its obligations regarding the achievement of economic and
monetary union, it is concluded that:
(a) in Croatia, national legislation, including the Statute of the national central bank,
is compatible with Articles 130 and 131 of the Treaty and with the Statute of
the ESCB and of the ECB;
(b) regarding the fulfilment by Croatia of the convergence criteria mentioned in the
four indents of Article 140(1) TFEU:
– the average inflation rate in Croatia in the year ending in April 2022 stood at 4,7
per cent, which is below the reference value, and it is likely to remain below the
reference value in the months ahead,
– Croatia is not the subject of a Council decision on the existence of an excessive
deficit,
– Croatia has been a member of ERM II since 10 July 2020. During the two years
preceding the assessment, the kuna exchange rate (HRK) has not been subject to
severe tensions and Croatia has not devalued the HRK bilateral central rate
against the euro on its own initiative,
– in the year ending April 2022, the long-term interest rate in Croatia was, on
average, 0,8 per cent, which is well below the reference value.
(c) in the light of the assessment on legal compatibility and on the fulfilment of the
convergence criteria as well as the additional factors, Croatia fulfils the
necessary conditions for the adoption of the euro,
HAS ADOPTED THIS DECISION: 
Article 1 
Croatia fulfils the necessary conditions for the adoption of the euro. The derogation in favour 
of Croatia referred to in Article 5 of the 2012 Act of Accession is abrogated with effect from 
1 January 2023. 
(19) Council Regulation (EC) No 479/2009 of 25 May 2009 on the application of the Protocol on the excessive
deficit procedure annexed to the Treaty establishing the European Community (OJ L 145, 10.6.2009, p.
1). 
6
EN EN
Article 2 
This Decision is addressed to the Member States. 
Done at Brussels, 
For the Council 
The President 
7
EN EN
Anlage 5 
EUROPEAN 
COMMISSION 
Brussels, 1.6.2022 
COM(2022) 281 final 
2022/0178 (NLE) 
Proposal for a 
COUNCIL REGULATION 
amending Regulation (EC) No 974/98 as regards the introduction of the euro in Croatia 
EN EN
EXPLANATORY MEMORANDUM 
1. CONTEXT OF THE PROPOSAL
On 1 June 2022, the Commission released a proposal for a Council Decision in
accordance with Article 140(2) of the Treaty on the Functioning of the European
Union (‘the Treaty’), indicating that Croatia fulfils the necessary conditions for the
adoption of the euro and that the derogation of Croatia is abrogated with effect from
1 January 2023.
In the event of a positive decision, the Council will subsequently have to take the
other measures necessary for the introduction of the euro in Croatia.
Council Regulation (EC) No 974/98 on the introduction of the euro1 governs the
initial introduction of the euro in the first-wave euro-area Member States and
Greece2. That Regulation was amended by:
- Regulation (EC) No 2169/2005, in order to prepare for future enlargements of the
euro area
- Regulation (EC) No 1647/2006, to cover Slovenia (which adopted the euro on 1
January 2007)
- Regulation (EC) No 835/2007, to cover Cyprus (which adopted the euro on 1
January 2008)
- Regulation (EC) No 836/2007, to cover Malta (which adopted the euro on 1
January 2008)
- Regulation (EC) No 693/2008, to cover Slovakia (which adopted the euro in
January 2009)
- Regulation (EU) No 670/2010, to cover Estonia (which adopted the euro in January
2011)
- Regulation (EU) No 678/2013, to cover Latvia (which adopted the euro in January
2014)
- Regulation (EU) No 827/2014, to cover Lithuania (which adopted the euro in
January 2015).
For Croatia to also be covered by Regulation (EC) No 974/98, a reference to this 
Member State needs to be added to that Regulation. This proposal contains the 
necessary amendments to that Regulation. 
Croatia's National Euro Changeover Plan specifies that the ‘big bang’ scenario 
should be applicable, i.e. that the adoption of the euro as the currency of Croatia and 
the introduction of euro banknotes and coins in Croatia should coincide. 
2. RESULTS OF CONSULTATIONS WITH THE INTERESTED PARTIES
AND IMPACT ASSESSMENT
Discussions with Member States on economic policy challenges in Member States
are held under various headings on a regular basis in the Economic and Financial
1 OJ L 139, 11.5.1998, p. 1. 
2 Cf. Council Regulation (EC) No 2596/2000 of 27 November 2000 amending Council Regulation 
(EC) No 974/98 on the introduction of the euro (OJ L 300, 29.11.2000, p, 2). 
1
EN EN
Committee (EFC) and the ECOFIN/Eurogroup. These include informal discussions 
on issues specifically relevant to the preparation of eventual euro area entry 
(including exchange rate policies). Dialogue with academics and other interested 
groups takes place conferences/seminars and on an ad-hoc basis. 
Economic developments in the euro area and the Member States are assessed through 
the various procedures of economic policy coordination and surveillance (notably 
under Art. 121 of the Treaty), as well as in the context of the Commission’s regular 
monitoring and analysis of country-specific and area-wide developments (including 
forecasts, regular publication series, and input to the EFC and ECOFIN/Eurogroup). 
In accordance with the proportionality principle and in line with past practice, no 
formal impact assessment is necessary. 
3. LEGAL ELEMENTS OF THE PROPOSAL
3.1. Legal basis 
The legal basis for this proposal is Article 140(3) of the Treaty, which allows for the 
adoption of the other measures necessary for the introduction of the euro in the 
Member State the derogation of which has been abrogated under Article 140(2) of 
the Treaty. 
The Council shall act with the unanimity of the Member States whose currency is the 
euro and the Member State concerned, on a proposal from the Commission and after 
consulting the ECB. 
3.2. Subsidiarity and proportionality 
The proposal falls under the exclusive competence of the Union. The subsidiarity 
principle therefore does not apply. 
This initiative does not go beyond what is necessary to achieve its objective and, 
therefore, complies with the proportionality principle. 
3.3. Choice of legal instrument 
A Regulation is the only appropriate legal instrument for amending Council 
Regulation (EC) No 974/98 on the introduction of the euro. 
4. BUDGETARY IMPLICATION
The proposal has no implications for the budget of the Union.
5. COMMENTARY ON INDIVIDUAL ARTICLES
5.1. Article 1 
In accordance with Article 1 lit. (a) and with Article 1a of Regulation (EC) No 
974/98, the table in the Annex to that Regulation lists the participating Member 
States and defines the euro adoption date, the cash changeover date, and the ‘
phasingout’ period, if applicable, for all these Member States. 
According to Article 1 lit. (i) of Regulation (EC) No 974/98, a ‘phasing-out’ period 
can only apply to Member States where the euro adoption date and the cash 
changeover date fall on the same day. This was not the case for the eleven Member 
States that adopted the euro on 1 January 1999, nor for Greece, which adopted the 
euro on 1 January 2001. 
2
EN EN
Slovenia, Cyprus, Malta, Slovakia, Estonia, Latvia and Lithuania’s euro adoption 
date and cash changeover date coincided (1 January 2007 for Slovenia, 1 January 2008 
for Cyprus and Malta, 1 January 2009 for Slovakia, 1 January 2011 for Estonia, 1 
January 2014 for Latvia, 1 January 2015 for Lithuania), but the countries chose not to 
have a ‘phasing-out’ period. 
Also Croatia's National Euro Changeover Plan sets the same date for the euro adoption 
date and for the cash changeover date (1 January 2023), and Croatia has chosen not to 
have a ‘phasing-out’ period. 
This Article adds Croatia and the following relevant data for this Member State to the 
table in the Annex to Regulation (EC) No 974/98 in protocol order. 
Member State Euro adoption date Cash changeover date Member State with a 
‘phasing-out’ period 
‘Croatia 1 January 2023 1 January 2023 No’ 
5.2. Article 2 
This Article sets the date of entry into force of the Regulation as 1 January 2023, ensuring that 
it will be applicable in conformity with the timing of the other Council acts relating to the 
adoption of the euro by Croatia, i.e. the date of on which the derogation is abrogated and the 
date on which the conversion rate for the Croatian kuna enters into force. 
3
EN EN
2022/0178 (NLE) 
Proposal for a 
COUNCIL REGULATION 
amending Regulation (EC) No 974/98 as regards the introduction of the euro in 
Croatia 
THE COUNCIL OF THE EUROPEAN UNION, 
Having regard to the Treaty on the Functioning of the European Union, and in particular 
Article 140(3) thereof, 
Having regard to the proposal from the European 
Commission, Having regard to the opinion of the European 
Central Bank, Whereas: 
(1) Council Regulation (EC) No 974/98 (3) provides for the substitution of the euro for the
currencies of the Member States which fulfiled the necessary conditions for the
adoption of the euro at the time when the Community entered the third stage of
economic and monetary union.
(2) According to Article 5 of the 2012 Act of Accession, Croatia is a Member State with a
derogation, as defined in Article 139(1) of the Treaty on the Functioning of the
European Union (the ‘Treaty’).
(3) Pursuant to Council Decision 2022/…/EU of … … 2022 on the adoption by Croatia of
the euro on 1 January 2023 (4), Croatia fulfils the necessary conditions for the
adoption of the euro and the derogation in favour of Croatia is to be abrogated with
effect from 1 January 2023.
(4) The introduction of the euro in Croatia requires the extension to Croatia of the existing
provisions on the introduction of the euro that are set out in Regulation (EC) No
974/98.
(5) Croatia's National Euro Changeover Plan specifies that euro banknotes and coins
should become legal tender in that Member State on the day of the introduction of the
euro as its currency. Consequently, the euro adoption date and the cash changeover
date shall be 1 January 2023. No ‘phasing-out’ period should apply.
(6) Regulation (EC) No 974/98 should therefore be amended accordingly,
HAS ADOPTED THIS REGULATION:
Article 1 
The Annex to Regulation (EC) No 974/98 is amended by inserting the following row in the 
table between the entries for France and Ireland: 
3 Council Regulation (EC) No 974/98 of 3 May 1998 on the introduction of the euro (OJ L 139, 
11.5.1998, p. 1). 
4 OJ L […], […], p. […]. 
4
EN EN
‘Croatia 1 January 2023 1 January 2023 No’ 
Article 2 
This Regulation shall enter into force on 1 January 2023. 
This Regulation shall be binding in its entirety and directly applicable in all Member States. 
Done at Brussels, 
For the Council 
The President 
5
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ISSN 0722-8333]</text>
  <titel>gemäß § 9a des Gesetzes über die Zusammenarbeit von Bundesregierung und Deutschem Bundestag in Angelegenheiten der Europäischen Union&#xd;
Beitritt Kroatien zum Euroraum</titel>
  <datum>2022-06-17</datum>
</document>
