EU climate and energy targets : 2020 targets achieved, but little indication that actions to reach the 2030 targets will be sufficient. Special report 18, 2023.
Date: 2023-07-07
Institutions: European Court of Auditors
Subjects: EU Member State, EU budget, EU energy policy, climate change policy, cost-effectiveness analysis, financing, greenhouse gas, investment, investment cost, performance audit, reduction of gas emissions, report

EN 

2023 

18 

Special report  EU climate and energy targets 

2020 targets achieved, but little indication that 
actions to reach the 2030 targets will be sufficient 

 
 
 
Contents 

Executive summary 

Introduction 

The EU climate and energy targets 

Main policies aimed at achieving the climate and energy targets 

Main responsibilities 

Budget to reach the climate and energy targets 

Audit scope and approach 

Observations 

The EU reached its 2020 targets, but not only due to its own 
climate action 

Commission did not assess the extent of the COVID-19 pandemic’s 
contribution to achieving the EU’s 2020 targets 

2 

Paragraph 

I-X 

01-14 

01-02 

03-07 

08-10 

11-14 

15-18 

19-85 

19-46 

21-26 

The Commission did not assess the extent of unexpected GDP fluctuations on 
member states’ achievement of the EU’s 2020 targets 

27-35 

There is a lack of transparency on how flexibilities allowed member states to 
achieve their targets in a cost-effective manner 

36-46 

The EU compares well internationally in terms of greenhouse gas 
emissions reduction, but not all emissions are accounted for 

The EU compares well internationally in terms of reducing greenhouse gas 
emissions 

Net emissions from imported goods not accounted for in greenhouse gas 
emissions 

Emissions from international aviation and shipping not accounted for in 
greenhouse gas emissions 

Commission has a good overview of sectoral contribution to 
targets, but lacks key information on cost-effectiveness of reaching 
the targets 

The Commission has identified which sectors successfully contribute to the 
targets 

47-60 

49-53 

54-57 

58-60 

61-85 

62-65 

 
 
3 

The Commission and member states have sparse information on the cost and 
effects of actions to reach the targets 

66-80 

81-85 

86-95 

Little indication so far that more ambitious EU targets will translate into 
sufficient action 

Conclusions and recommendations 

Annexes 

Annex I – National achievements of 2020 greenhouse gas emission 
target per member state 

Annex II – National achievements of 2020 renewable energy share 
target per member state 

Annex III – National achievements of 2020 energy efficiency target 
per member state (in primary and final energy consumption) 

Annex IV – Extract of the Commission’s assessment of reporting of 
investment needs and their funding sources in five National Energy 
and Climate Plans we reviewed 

Annex V – Reporting template on member states’ policies and 
measures 

Acronyms and abbreviations 

Replies of the Commission 

Timeline 

Audit team 

 
 
 
 
4 

Executive summary 

I Climate change is a global challenge, one which has a significant effect on EU citizens’ 
lives. Over time, the EU has set itself increasingly ambitious climate and energy targets 
to respond to it. These include 2020 and 2030 targets for reducing greenhouse gas 
emissions, increasing the use of renewable energy, and promoting energy efficiency. 

II We decided to carry out this audit now given the high level of public interest. 
By drawing lessons from successful practice related to the achievement of the 2020 
targets, we expect our report to help the Commission assess the draft National Energy 
and Climate Plans and the member states to finalise them. 

III The EU has a legal framework in place governing climate and energy targets. 
Member states were required to submit National Energy and Climate Plans for the 2021-
2030 period. In these plans, they outlined policies aimed at achieving these targets. 
The Commission and member states monitor and report on progress made towards 
achieving the targets. 

IV The EU committed to spending at least 20 % of its 2014-2020 EU budget on climate 
action. For the 2021-2027 EU budget, this figure has increased to 30 %, about €87 billion 
per year. This amount is less than 10 % of the total investment needed to reach the 
2030 targets, estimated at around €1 trillion per year. It is envisaged that the rest of 
the investment will come from national and private funds. 

V For this audit, we assessed whether the EU has built on successful actions to reach 
its 2030 energy and climate targets. We examined whether the EU had learned lessons 
from the achievement of 2020 targets which would help it to reach the more ambitious 
2030 targets. 

VI We found that the EU had indeed achieved its 2020 targets. However, this 
achievement was also due to the contribution of external factors. The Commission has 
not assessed the extent to which this progress was a result of the policies rather than 
external factors, such as the financial crisis in 2009 and the exact contribution of the 
COVID-19 pandemic in 2020. 

 
 
5 

VII We found that the EU’s greenhouse gas emissions reduction compared well to 
those of other industrialised countries. However, accounting for the EU’s 2020 
greenhouse gas emissions does not include emissions occurring as a result of trade, 
caused by carbon leakage (which, if included, are estimated to increase by about 8 %) 
and from international aviation and shipping (respectively 3.4 % and 3.6 %). 

VIII The Commission has only a partial overview of the actions that proved successful 
for achieving the 2020 targets. It has identified the sectors which have been successful, 
i.e. those covered by the EU Emissions Trading System but lacks information on the cost 
and effects of actions. It lacks data on the cost to the EU budget, national budgets and 
private sector of achieving the EU targets. 

IX The National Energy and Climate Plans also lack data on investment needs and 
funding sources to assess whether such plans are a sound basis to reach the 2030 
targets. Overall we found little indication so far that the ambitious 2030 EU targets will 
be translated into sufficient action. There is no information that sufficient financing will 
be made available to reach the 2030 targets, in particular from the private sector. 

X We recommend that the Commission should: 

o 

o 

provide more transparency on the performance of the EU and its member states on 
climate and energy action; 

account for all greenhouse gas emissions caused by the EU, including emissions 
embodied in trade and from international aviation and navigation; 

o 

support member states’ commitment to achieving the 2030 targets. 

 
 
 
6 

Introduction 

The EU climate and energy targets 

01 Climate change is a global challenge, with significant impact on EU citizens’ lives. 
Over time, the EU has set itself increasingly ambitious climate and energy targets to 
respond to it. These include 2020 and 2030 targets for: 

o 

o 

o 

reducing greenhouse gas emissions, compared to 1990 levels (see Figure 1); 

increasing the share of renewable energy (see Figure 2); and 

promoting energy efficiency, i.e. reducing energy consumption (see Figure 3). 

Figure 1 – Evolution of the EU greenhouse gas emissions target 

In million tonnes of CO2 equivalent
6 000

4 847

5 000

4 000

3 000

2 000

1 000

0

2020 Target│ - 20 %

1

2030 Target│ - 40 % 

2

3

2030 Target│ - 55 %

① 2020 target (as set in 2009)

② 2030 target (as set in 2018)

③ 2030 target - Fit for 55 (COM proposal 2021)

GHG emissions

Rebound effect after 
COVID-19

Source: ECA based on data from European Environment Agency. [Data for 2021 are provisional]. 

 
 
 
Figure 2 – Evolution of the EU renewable energy share target 

7 

2030 Target│ 45 % 
4

2030 Target│ 40 % 

3

2030 Target│ 32 % 

2

2020 Target│ 20 % 

1

50 %

45 %

40 %

35 %

30 %

25 %

20 %

15 %

10 %

5 %

0 %

① 2020 target (as set in 2009)

② 2030 target (as set in 2018)

③ 2030 target - Fit for 55 (COM proposal 2021)  

④ 2030 target – REPowerEU (COM proposal 2022)

Source: ECA based on data from Eurostat. 

Total share of renewable energy

 
 
 
8 

Figure 3 – Evolution of the EU energy efficiency target, expressed in terms 
of energy consumption 

In million tonnes of oil equivalent

2007 EU reference scenario projections

2020 Target│ -20 % 

1

2030 Target│ -32.5 %

2

2030 Target│ -39 % 

3

4

2030 Target│ -42 % 

1 800

1 600

1 367

1 400

1 200

1 000

800

600

400

200

0

Energy consumption

20 % target

① 2020 target (as set in 2009)

② 2030 target (as set in 2018)

③ 2030 target – Fit for 55 (COM proposal 2021) 

④ 2030 target – REPowerEU (COM proposal 2022)

Source: ECA based on data from Eurostat. 

02 All three 2020 headline targets were broken down into targets for each individual 
member state. The aim was to ensure that the targets for the EU are achieved 
collectively, as a whole. 

Main policies aimed at achieving the climate and energy targets 

03 In 2009, the EU introduced a set of policies (the “Climate and Energy Package”), 
aimed at achieving the 2020 targets. This package included a reviewed Directive on 
Emissions Trading (the ETS Directive) and the Effort-Sharing Decision. 

 
 
 
9 

Under the package, the EU’s overall greenhouse gas emissions target was further broken 
down into: 

o 

o 

an EU emissions trading system target (a 21 % reduction in emissions by 2020 
compared to 2005 values) – setting a maximum emissions cap for the sectors 
covered by the ETS (energy supply and heavy industry); 

an EU non-ETS target (a 10 % reduction in emissions by 2020 compared to 2005 
values), broken down into national binding targets for emissions not currently 
covered by the ETS (transport, buildings, agriculture, non-ETS industry and waste). 

 
 
10 

04 Figure 4 provides an overview of the progress towards meeting these two sub-
targets: 

Figure 4 – Evolution of greenhouse gas emissions from EU ETS and non-
ETS sectors 

In million tonnes of CO2 equivalent

ETS sectors
(energy supply, 
industry, aviation)

GHG
emissions
(ETS)

Non-ETS sectors
(transport, buildings, 
agriculture, non-ETS 
industry and waste)

GHG
emissions
(non-ETS)

2 500

2 000

1 500

1 000

500

0

3 000

2 500

2 000

1 500

1 000

500

0

1

2020 Target│ -21 %

2030 Target│ -43 %

2

3

2030 Target│ -61 %

1

2020 Target│ - 10 %

2030 Target│ -30 %

2

3

2030 Target│ -40 %

① 2020 target (as set in 2009)

② 2030 target (as set in 2018)

③ 2030 target - Fit for 55 (COM proposal 2021)

Source: ECA based on data from European Environment Agency for ETS and for non-ETS. 

 
 
 
11 

05 In 2019, the EU adopted the “Clean Energy for All Europeans Package”, which 
consisted of eight laws and three non-legislative initiatives. These were aimed at further 
decarbonising the EU’s energy system, and putting in place measures to allow the EU to 
reach its 2030 targets. One of the main novelties related to climate and energy targets 
was a new Regulation on the Governance of the Energy Union and Climate Action. 
This introduced the requirement for member states to establish integrated 10-year 
national energy and climate plans (NECPs), outlining policies for 2021-2030 to achieve 
climate and energy targets. The Commission monitors progress based on member 
states’ reporting . 

06 In 2021, the EU adopted its European Climate Law, establishing a binding EU target 
of zero net greenhouse gas emissions by 2050. It also set an intermediate target of 
reducing net emissions by 55 % by 2030, compared to 1990 levels. To support this 
ambition, the Commission proposed a series of legislative proposals in July 2021 under 
the “Fit for 55” package, including more ambitious EU renewable energy and energy 
efficiency targets. Figure 5 provides an overview of the Commission’s main initiatives to 
achieve the proposed updated 2030 climate and energy targets. The current status of 
the 20 legislative proposals included in this package is available on the European 
Parliament’s website. 

 
 
Figure 5 – Commission proposals to support the delivery of the 2030 
targets 

12 

Source: European Commission. 

07 In May 2022, the Commission adopted the REPowerEU Plan to reduce dependence 
on Russian fossil fuels. This plan proposed to further increase the 2030 energy efficiency 
target from 39 % to 42 %, and the 2030 target for the share of energy from renewables 
from 40 % to 45 %. On 30 March 2023, the Council and the Parliament negotiators 
reached a provisional political agreement to raise the share of energy from renewables 
to 42.5 % by 2030 with an additional 2.5% indicative top up that would allow to reach 
45 %. By April 2023, negotiations between the Council and the European Parliament on 
the proposal to increase the 2030 energy efficiency target are still ongoing. The current 
status of the four legislative proposals included in the REPowerEU plan is available on 
the European Parliament’s website. 

 
 
 
13 

Main responsibilities 

08 The Commission and co-legislators (the European Parliament and the Council) have 
established an EU legal framework on climate and energy targets. 

09 In their National Energy and Climate Plans (NECPs) submitted to the Commission in 
2019 and 2020, member states outlined the policies that they intended to put in place 
for the 2021-2030 period to achieve the EU targets, set in 2018 (see paragraph 01). 
They will have to report by 15 March 2023, and every two years thereafter, on the 
action they have taken. By 30 June 2023, member states must submit to the 
Commission draft updated NECPs, reflecting the increased ambition of the EU targets 
(see paragraphs 06 and 07). Otherwise, they must provide to the Commission reasons 
justifying why the plan does not require updating. The Commission assesses draft NECPs 
and issues recommendations, which member states must take into account when 
submitting final NECPs. These are due by 30 June 2024. 

10 The Commission tracks progress towards the targets with the assistance of 
the European Environment Agency (EEA), which verifies the quality of the data and 
projections submitted by member states. The Commission monitors and reports 
annually on the achievement of the targets, for example through the Commission’s 
State of the Energy Union report and the Climate Action Progress Report. Member 
states also report directly to the United Nations on their greenhouse gas emissions. 

Budget to reach the climate and energy targets 

11 In 2021, the Commission estimated that achieving the 55 % greenhouse gas 
emissions reduction target by 2030 would require additional investment of €392 billion 
per year1 compared to the 2011-2020 average in the energy system alone. Experts have 
estimated that reaching net-zero emissions by 2050 in the EU-27 would require total 
(i.e. ongoing plus additional) investment of around €1 trillion per year2 in the 2021-2050 
period. 

12 The EU committed to spending at least 20 % of its 2014-2020 EU budget for climate 
action. In June 2021, the Commission reported that the EU had spent 20.1 % of its 2014-
2020 budget, or €216 billion, on combating climate change, delivering on its 20 % 

1  Commission Staff Working Document Impact Assessment Report, SWD(2021) 621 final. 

2  McKinsey & Company, How the European Union could achieve net-zero emissions at net-zero 

cost, 2020. 

 
 
 
14 

greenhouse gas emission reduction target3. In our special report 09/2022 on climate 
spending we found that the Commission had overstated climate spending by at least 
€72 billion, which meant that around 13 % of the 2014-2020 EU budget had been spent 
on climate action. 

13 For 2021-2027, the EU has set an overall goal of spending 30 % of its budget to 
climate action, a total of €610 billion throughout the period, or €87 billion per year. 
Figure 6 provides an overview of the EU’s spending on achieving its climate and energy 
targets. 

Figure 6 – Climate-spending targets for the EU budget  

Multiannual financial 
framework (MFF)

Climate 
spending

NGEU is the temporary instrument 
designed to boost post-COVID 
recovery. The Recovery and 
Resilience Facility (RRF) represents 
the core spending of the NGEU 
instrument.

20 %

NextGenerationEU
(NGEU)

30 %

RRF has a 37 % 
climate-spending 
target

current prices

2014-2020 
EU budget
(€1 075 bn)

2021-2027 
EU budget
(€2 033 bn)

Source: ECA special report 09/2022, based on: Commission, A Modern Budget for a Union that Protects, 
Empowers and Defends; The Multiannual Financial Framework for 2021-2027, COM(2018) 321; European 
Council, Conclusions - Special meeting of the European Council, EUCO 10/20, 2020, p. 7; Commission, 
Guidance to Member States, Recovery and Resilience Plans, SWD(2020) 205, p 5. 

14 This spending under the EU budget is less than 10 % of the total estimated 
investment needed to reach the 2030 targets (i.e. €87 billion compared to €1 trillion, 
see paragraphs 11-13): a major proportion of the investment will need to come from 
national and private funds. 

3  Commission, 2020 Annual Management and Performance Report for the EU budget, 

Volume I. 

 
 
 
 
 
15 

Audit scope and approach 

15 Our main audit question was aimed at determining whether the EU is building on 
successful actions in order to reach its 2030 energy and climate targets. 

16 We analysed whether the achievement of the 2020 targets was based on the EU’s 
own climate actions and compared well to other industrialised countries in the world. 
We then examined whether the EU had drawn lessons, by assessing whether the 
Commission and member states had identified actions which had proved successful 
(and unsuccessful) in achieving the 2020 targets, and whether these lessons had fed into 
the framework for achieving the more ambitious 2030 targets. 

17 We decided to carry out this work now given the high level of public interest. 
By drawing lessons from successful practice related to the achievement of 2020 targets, 
we expect our report to help the Commission assess the draft NECPs and the member 
states to finalise them. We expect our recommendations to be useful in the context of 
the EU’s objective of achieving climate neutrality by 2050. 

18 We reviewed the work of the Commission and analysed data for the 1990-2021 
period mainly from Eurostat and the European Environment Agency. We also 
interviewed authorities from five member states (Germany, Ireland, Italy, Poland and 
Sweden), representing 48 % of EU greenhouse gas emissions. We reviewed evaluations 
and studies from the Joint Research Centre, the European Parliament Research Service, 
and built upon previous ECA work. 

 
 
 
16 

Observations 

The EU reached its 2020 targets, but not only due to its own 
climate action 

19 On 18 October 2022, the Commission reported that the EU had reached its three 
2020 climate and energy targets4. For the EU to be able to learn from this achievement, 
it is important to assess and report in a transparent manner whether the EU’s 
performance was due to its own climate actions. 

20 The following sections describe the impact of COVID-19, the impact of unexpected 
GDP fluctuations, and the extent to which the flexibilities allowed member states to 
achieve their 2020 targets. 

Commission did not assess the extent of the COVID-19 pandemic’s 
contribution to achieving the EU’s 2020 targets 

21 By March of the year n+2, member states must send their emissions data to 
the Commission. The Commission sends the EU’s consolidated data to the United 
Nations Framework Convention on Climate Change secretariat by April of the same 
year5. In our special report 18/2019 on greenhouse gas emissions, we concluded that 
EU’s emission data is appropriately reported. 

22 As shown in Figure 1, the EU reduced its greenhouse gas emissions by 31.9 % 
by 2020, thereby achieving its 2020 greenhouse gas target (a reduction of 20 %). 
Greenhouse gas emissions dropped by 8.4 % from 2019 to 2020 (a reduction of 
303 million tonnes CO2e), the year marked by the economic downturn caused by 
the COVID-19 pandemic (-5.7 % in EU GDP). This drop in greenhouse gas emissions was 
the largest in the 1990-2020 period. 

4  State of the Energy Union Report 2022. 

5  See Regulation (EU) No 525/2013 and the United Nations Framework Convention on Climate 

Change (UNFCCC). 

 
 
 
17 

23 The Commission considered the impact of COVID-19 on the achievement of 
the EU’s 2020 targets in its reports6. It however did not assess the exact contribution of 
the COVID-19 pandemic to achieving these targets. We noted that Germany reported on 
the extent of the impact of COVID-19 on greenhouse gas emissions (see Box 1). 
We estimated the likely value of the 2020 EU greenhouse gas emissions in the absence 
of COVID-19, by extrapolating it from the 2009-2019 trend, assuming a linear annual 
average reduction continuing for the year 2020. Following this approach, EU greenhouse 
gas emissions would in 2020 have been around -27 % compared to 1990 levels instead 
of -31.9 %. This still exceeds the reductions called for by the 2020 target. Provisional EEA 
data on 2021 greenhouse gas emissions indicates a major rebound effect, with 
emissions rising up by 5 % to 3 460 million tonnes CO2e. 

6  2021 EU Climate Action progress report; 

2022 Report on the Achievement of the 2020 renewable energy targets; 
2022 Report on the achievement of the 2020 energy efficiency targets. 

 
 
 
18 

Box 1: Reporting on the impact of COVID-19 on greenhouse gas 
emissions in Germany 

In Germany, greenhouse gas emissions decreased by 8.9 % from 2019 to 2020: from 
800 to 729 million tonnes CO2e. In its report on the 2020 greenhouse gas emissions, 
the German Expert Council for Climate Matters carried out an estimation of the 
impact of COVID-19 by sector: 

Million tonnes of CO2 equivalent

Other combustion

Waste

Agriculture

Change
(2020 compared 
to 2019)

+0.1

-0.4

-0.8

Domestic Transport

-18.1

Buildings

Industry

-1.9

-11.4

Energy supply

-38.4

GHG emissions 
in 2020

7

9

56

147

119

172

219

Total

-70.9

729

-80

-60

-40

-20

0

20

Change without the COVID-19 pandemic

Change due to the COVID-19 pandemic

Source: European Environment Agency and Bericht zur Vorjahresschätzung der deutschen 
Treibhausgasemissionen für das Jahr 2020. 

According to this estimation, 63 % of the total reduction (45 out of 71 
million tonnes) can be attributed to the one-off factor of COVID-19. Without this 
factor, emissions would only have decreased by 3.3 % or around 26 million tonnes, 
compared to 2019. The method used to estimate this impact is based on an 
extrapolation of the trends observed for the 1995-2019 period to 2020. 

24 Member states submit yearly data on their energy consumption to Eurostat7. 
Based on this data, verified by Eurostat, the Commission monitors progress towards 

7  See Regulation (EC) No 1099/2008 on energy statistics. 

 
 
 
 
19 

the 2020 energy efficiency target. The Commission also uses energy consumption data 
to monitor progress towards the 2020 renewable energy share target, whereby energy 
consumption is the denominator. The numerator of this share derives from data that 
member states report yearly to Eurostat: 

𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟 𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑒𝑒𝑒𝑒 𝑠𝑠ℎ𝑟𝑟𝑟𝑟𝑟𝑟  =  

𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑒𝑒𝑒𝑒 𝑐𝑐𝑐𝑐𝑟𝑟𝑠𝑠𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑟𝑟 𝑓𝑓𝑟𝑟𝑐𝑐𝑐𝑐 𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟 𝑠𝑠𝑐𝑐𝑐𝑐𝑟𝑟𝑐𝑐𝑟𝑟𝑠𝑠
𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑒𝑒𝑒𝑒 𝑐𝑐𝑐𝑐𝑟𝑟𝑠𝑠𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑟𝑟

25 As shown in Figure 2, the EU achieved its 2020 renewable energy share target 
(20 %), by increasing this share to 22.1 % in 2020. This share increased sharply from 
2019 to 2020, partly as a result of the exceptional reduction (of 7.4 %) in the gross final 
energy consumption caused by the COVID-19 pandemic. Without such a drop, we 
estimate that the renewable energy share would have been around 20.5 % in 2020, just 
above the 20 % target, based on extrapolation of 2009-2019 data. Provisional data on 
2021 EU renewable energy share indicates it remained stable, close to the 2020 value, 
mainly because of the rebound effect on the denominator (the gross final energy 
consumption). 

26 As shown in Figure 3, the EU achieved its 2020 energy efficiency target, expressed 
in terms of energy consumption (-20 %). It did so by decreasing its energy consumption 
by 24.6 % against a scenario where no additional action was taken, i.e. compared to 
the 2007 forecast of 2020 consumption level. Energy consumption fell by 8.7 % between 
2019 and 2020, mainly because of the economic downturn caused by the COVID-19 
pandemic. We estimate that without this sharp drop, energy consumption would have 
declined by 17.8 % compared to the baseline scenario (rather than 24.6 %), assuming 
that the annual average decline over the period 2009-2019 continued into 2020. 
Thus, without the COVID-19 pandemic, the EU-27 would most likely not have reached its 
2020 energy efficiency target. Despite the economic slowdown caused by the COVID-19 
pandemic, seven member states (Austria, Belgium, Bulgaria, Germany, Lithuania, Poland 
and Sweden) did not achieve their 2020 national targets. Provisional data indicate 
a major rebound effect, as EU energy consumption rose by 5.6 % from 2020 to 2021. 
Therefore, the EU energy consumption, which was -24.6 % in 2020 (compared to 
consumption growth projected in 2007), was only -20.3 % in 2021, a little below 
the - 20 % target. 

 
 
 
 
 
 
20 

The Commission did not assess the extent of unexpected GDP fluctuations 
on member states’ achievement of the EU’s 2020 targets  

27 National targets for greenhouse gas emissions covered by the Effort-Sharing 
Decision were set using 2005 emission levels as baseline8. The EU agreed that all targets 
should remain within a margin of 20 % above or below this baseline. The main criterion 
for setting the target for each member state was the relative GDP per capita in 2005. 

28 The higher a member state’s per capita GDP in 2005, the more it was required to 
reduce its greenhouse gas emissions by 2020. Denmark, Luxembourg and Ireland, for 
example, were required to reduce their emissions by 20 %, and Sweden by 17 %. 
The lower the GDP per capita, the smaller the reduction target was. Some member 
states with the lowest per capita GDP were even allowed to increase their emissions 
compared to 2005 levels. Bulgaria and Romania, for example, were allowed to increase 
their emissions by 20 % and 19 % respectively. The reasoning behind this is that member 
states with a lower GDP per capita were expected to have higher growth rates up to 
2020, which would generate higher emissions. They would also have less funds available 
to invest in modern technologies that boost energy efficiency and the uptake of 
renewable energy9. Annex I provides an overview of these targets and achievements for 
each member state. 

29 The renewable energy directive established national targets10 based on the same 
main principle of relative GDP per capita11. Annex II provides an overview of these 
targets and achievements for each member state. 

30 For energy efficiency, the energy efficiency directive required member states to set 
their own indicative targets as their national contribution to the EU’s collective 2020 
target. When doing so, member states had to consider factors such as cost-effectiveness 
and GDP forecasts. They also had to ensure that their collective ambition was sufficient 
to reach the EU 2020 target12. Annex III provides an overview of these targets and 
achievements for each member state. 

8  Article 3 of Decision No 406/2009/EC. 

9  European Council conclusions of March 2007, paragraph 33. 

10  Article 3 of Directive 2009/28/EC. 

11  Impact assessment SEC(2008) 85, paragraph 12. 

12  Article 3 of Directive 2012/27/EU. 

 
 
 
21 

31 Forecast GDP growth thus played a major role in setting the 2020 national targets. 
However, the GDP of several member states did not grow as expected, mainly because 
of the 2009 financial crisis, which reduced the EU’s GDP by 4.5 %13. This led to an overall 
reduction in energy consumption and contributed to the fact that nine member states 
achieved their 2020 renewable targets as early as 2014, five years after the targets were 
set (see Box 2). The COVID-19 pandemic, which caused a drop of 5.7 % in EU GDP in 
2020, also influenced the overall achievement of EU targets. For example, the 2020 
energy efficiency target, which several reports from the Commission and European 
Environment Agency14 considered unlikely to reach, became reachable because of 
the impact of the COVID-19 pandemic. 

Box 2 

Examples of member states which reached their 2020 renewable 
energy targets early 

By 2014, nine member states (Bulgaria, Czechia, Estonia, Croatia, Italy, Lithuania, 
Romania, Finland and Sweden) had already reached their 2020 targets, set in 
2009. 

13  Eurostat. 

14  2020 report on the State of the Energy Union, COM(2020) 950. 

Trends and projections in Europe 2020, EEA Report No 13/2020. 

 
 
 
Member states’ progress towards achieving their national renewable 
energy targets 

22 

Share of renewable 
energy (2009)

0 %

50 %

100 %

Croatia

Estonia

Sweden

Bulgaria

Czechia

Italy

Lithuania

Romania

Finland

Denmark

Greece

Cyprus

Latvia

Poland

Slovakia

Belgium

47 %

24 %

23 %

12 %

10 %

13 %

20 %

22 %

31 %

20 %

34 %

9 %

6 %

9 %

9 %

5 %

Germany

11 %

Ireland

5 %

Spain

13 %

Luxembourg

3 %

Hungary

12 %

Malta

22 %

Netherlands

4 %

Austria

Portugal

Slovenia

France

31 %

24 %

21 %

12 %

Year national target 
was reached

National targets for 
the share of 
renewable energy

Share of renewable 
energy (2020)

0 %

50 %

100 %

31 %

30 %

60 %

23 %

17 %

20 %

27 %

24 %

44 %

32 %

22 %

17 %

42 %

16 %

17 %

13 %

19 %

16 %

21 %

12 %

14 %

11 %

14 %

37 %

34 %

25 %

19 %

Source: ECA based on Eurostat. 
Croatia had already met in 2009 its renewable energy share target of 20 % by 2020, before Croatia 
joined the EU, in 2013. 

32 In addition to the reporting on greenhouse gas emissions and energy efficiency, 
the Commission also reports on greenhouse gas emissions intensity indicators such as 
emissions per GDP or per capita. 

33 These intensity indicators could be useful for assessing the drivers of progress 
towards the climate and energy targets, especially when GDP does not grow as forecast. 
This was the case in the 2005-2020 period because of the financial crisis and the 
COVID-19 pandemic.  

 
 
 
23 

34 Using intensity indicators would make it possible to isolate the member states’ 
performance towards achieving the targets through their policies and technological 
progress, from the impact of other factors, such as the economic cycle or changes in 
population. Figure 7 shows, for each member state, the evolution of total greenhouse 
gas emissions, the emissions per unit of GDP and the emissions per capita. It shows that 
some member states which performed the best in terms of reducing greenhouse gas 
emissions (first column of Figure 7) over the 2005-2020 period, such as Greece and Italy, 
would have performed less well than most member states when considering emission 
per GDP (second column of Figure 7). If considering emissions per capita (third column 
of Figure 7), member states such as Romania or Bulgaria would have performed less 
well. On the other hand, member states such as Ireland or Malta would have performed 
better if using emission intensity indicators. 

 
 
24 

Figure 7 – Evolution of total greenhouse gas emissions, emissions per unit 
of GDP and emissions per capita in 2005-2020 period 

/

/

Greenhouse gas 
emissions
(Change since 2005)

Emissions per unit 
of GDP
(Change since 2005)

Emissions per capita
(Change since 2005)

Greece

Estonia

Spain

Denmark

Italy

Portugal

Finland

Sweden

Luxembourg

Malta

France

EU-27

Belgium

Slovakia

Germany

Romania

Czechia

Netherlands

Slovenia

Bulgaria

Austria

Croatia

Hungary

Ireland

Lithuania

Poland

Latvia

Cyprus

-45 %

-40 %

-38 %

-38 %

-35 %

-33 %

-32 %

-31 %

-30 %

-29 %

-29 %

-27 %

-27 %

-27 %

-26 %

-25 %

-24 %

-23 %

-23 %

-21 %

-20 %

-20 %

-18 %

-18 %

-11 %

-7 %

-4 %

-4 %

-28 %

-55 %

-40 %

-47 %

-29 %

-33 %

-39 %

-46 %

-50 %

-60 %

-34 %

-36 %

-37 %

-53 %

-37 %

-52 %

-43 %

-34 %

-38 %

-42 %

-30 %

-25 %

-34 %

-57 %

-40 %

-46 %

-24 %

-23 %

-44 %

-39 %

-43 %

-42 %

-37 %

-32 %

-35 %

-39 %

-49 %

-44 %

-34 %

-29 %

-34 %

-28 %

-27 %

-17 %

-27 %

-28 %

-26 %

-12 %

-26 %

-15 %

-15 %

-31 %

6 %

13 %

-7 %

-20 %

Source: ECA based on European Environment Agency. 

35 However, we found that, when assessing member states’ performance, 
the Commission did not use the existing reporting on intensity indicators to analyse 
the drivers of progress and recommend improvements in climate and energy action. 

 
 
 
25 

There is a lack of transparency on how flexibilities allowed member states 
to achieve their targets in a cost-effective manner 

36 Some national targets were binding, and some were not: 

o 

o 

o 

The greenhouse gas sub-target covered by the Effort-Sharing Decision 
(see paragraph 03) was broken down into binding national targets. The other 
greenhouse gas sub-target (for ETS sectors) was not broken down into national 
targets, as the ETS provides an EU wide market for economic operators. 

The renewable energy share target was translated into binding national targets. 

The energy efficiency target was translated into indicative (i.e. non-binding) 
national targets. 

37 If binding targets are not achieved, the Commission can start corrective actions 
followed by infringement procedures, if necessary. These procedures can lead to 
the European Court of Justice sanctioning a member state for failing to reach its targets. 
Binding national targets also tend to increase member states´ commitment, provide 
certainty for investors, and encourage the continuous development of technologies15. 
Indicative targets, by contrast, cannot be enforced. But they can encourage progress, 
serve as a benchmark between member states and make it easier to agree on more 
ambitious targets. Experience from the 2020 targets shows that the energy efficiency 
target, which was not broken down into binding national targets, was the hardest one 
to achieve (see paragraph 26). 

38 Under the legislative framework for achieving the 2030 targets (see paragraph 05) 
binding national targets exist only for the greenhouse gas emissions covered by 
the Effort-Sharing Regulation. Both the 2030 national targets for energy efficiency and 
renewable energy share are indicative for member states. The Fit-for-55 proposal 
confirms this approach. 

39 The legislation also establishes that member states can use certain ‘flexibilities’ to 
reach their national targets when these are binding. This was to “enhance the overall 
cost-effectiveness of the total commitment of the Community”16 and “create 
opportunities for reducing the cost of achieving the targets”17. The sections below 

15  Recital 13 of Directive 2009/28/EC. 

16  Recital 10 of Decision No 406/2009/EC. 

17  Recital 36 of Directive 2009/28/EC. 

 
 
 
26 

explain how the use of binding targets and related flexibilities influenced their 
achievement. 

Use of flexibilities for greenhouse gas emissions targets 

40 Member states were able to use the following flexibilities to achieve the 2020 sub-
target related to greenhouse gas emissions covered by the Effort-Sharing Decision18: 

o 

o 

o 

o 

carry over overachievement in a given year to subsequent years, up to 2020; 

using in advance up to 5 % of the emissions allocation for the following year; 

buy emissions allocations from other member states; and 

use international credits, which represent investments in projects that have 
reduced emissions in developing countries or other industrialised countries. 

41 Three member states (Germany, Ireland and Malta) did not reach their 
2020 greenhouse gas target on their own. They bought over the 2013-2020 period 
a total of 17 million tonnes CO2e of greenhouse gas emissions allocations from other 
member states that over-achieved their targets (see third bullet of paragraph 40). 
Ireland also used international credits for a total of 8.2 million tonnes CO2e (see fourth 
bullet of paragraph 40). This altogether represented 8.4 % of the emissions that these 
three member states had managed to cut based on their own actions 
(299 million tonnes CO2e). One of the five member states we interviewed, Sweden, 
explained that they did not sell their over-achievement to other member states, to 
improve the environmental integrity of the EU system. 

42 Member states determine the price of transferred emission allocations based on 
a bilateral agreement, which is kept confidential. As a term of comparison, if applying 
the ETS average price of €39.9 per tonne CO2e in 2021, the value of such purchases 
would be €790 million. 

43 The Effort-Sharing Decision requires the Commission to adopt measures to 
increase the transparency of such transfers. The Commission receives information from 
member states on the quantity of emissions transferred and the price of the individual 
transactions between member states. The Commission publishes information on 
the quantities transferred but not on their price, in line with the Commission’s 
Implementing Regulation (EU) No 749/2014. The lack of transparency on the price paid 
by member states makes it difficult for citizens and stakeholders to determine whether 

18  Decision No 406/2009/EC, Articles 3 and 5. 

 
 
 
27 

flexibilities achieve their intended goal of improving the overall cost-effectiveness of 
achieving the targets (see paragraph 39). Under the regulation 2018/1999, the 
Commission will have to publish the price range of transfers as from 202319, but not of 
individual transfers. 

Use of flexibilities for the renewable energy share target 

44 Member states were able to use the following flexibilities to achieve the renewable 
energy share target20: 

o 

o 

o 

o 

buy renewable energy shares between member states; 

joint projects between member states; 

joint projects between member states and non-EU countries; and 

joint support schemes to spur renewable energy production in one or several 
member states’ territories. 

45 Six member states (Belgium, Ireland, France, Luxembourg, the Netherlands and 
Slovenia) did not reach their renewable energy share target solely based on their own 
climate action. They had to buy shares from other member states that over-achieved 
their targets (see first bullet of paragraph 44). By April 2023, France had not bought 
the missing shares to reach its target. Figure 8 shows how close these six member states 
were to achieving their national target before using flexibilities. 

19  Regulation 2018/1999, Article 26(3) and Annex V(f). 

20  Directive 2009/28/EC, Articles 6, 7, 9 and 11. 

 
 
 
28 

Figure 8 – Progress towards the national renewable energy share target 
for the six member states before buying shares 

25 %

0.9 %

23 %

0.0 %

24.1 %

19.1 %

30 %

25 %

20 %

15 %

10 %

5 %

0 %

16 %

2.6 %

14 %

2.5 %

13 %

1.0 %

13.6 %

11.5 %

12.0 %

11 %

1.6 %

10.1 %

Member states actions 
and targets compared:

Member 
state target

Flexibilities 
used

Member state 
achievement

Source: ECA based on data from European Commission. 

46 These six member states bought in total 22 137 million GWh of renewable energy 
from other member states. The Commission does not make public the price of 
the individual transactions between member states. The renewable energy directive 
required the Commission to do so in aggregated form21. Under the renewable energy 
directive revised in 201822, there is no such requirement for the Commission. The lack of 
transparency about the way member states reach their national binding targets through 
the use of flexibilities makes it difficult for citizens and stakeholders to determine 
whether flexibilities achieve their intended goal of improving the overall cost-
effectiveness of achieving the targets (see paragraph 39). 

21  Articles 6(2) and 24(2) of Directive 2009/28/EC. 

22  Directive (EU) 2018/2001. 

 
 
 
 
29 

The EU compares well internationally in terms of greenhouse gas 
emissions reduction, but not all emissions are accounted for 

47 The EU has committed itself to being a global leader in the transition towards 
climate neutrality23. This implies that it should compare well to other industrialised 
countries in terms of reducing greenhouse gas emissions and include all greenhouse gas 
emissions in its reporting, including those from imported goods and the ones from 
international aviation and shipping. 

48 We compared progress in the EU towards achieving the EU greenhouse gas 
emissions target to that in other countries in the world. This target is the only of the 
three EU headline targets for which there is comparable data with other countries. 

The EU compares well internationally in terms of reducing greenhouse gas 
emissions 

49 To reach climate neutrality, the EU aims to decouple its greenhouse gas emissions 
from economic growth24 i.e. reducing emissions while preserving economic growth. 
In this section, we put the EU’s achievement in terms of greenhouse gas emissions 
reductions into a global context by comparing it with other industrialised countries. 

50 Figure 9 shows the evolution of greenhouse gas emissions in the largest 
industrialised economies in the world, altogether representing more than 60 % of global 
emissions. While global emissions increased by 57 % from 1990 to 2019, EU-27 
emissions decreased by 26 %. As a result, the EU’s share of global emissions dropped 
from 15.3 % to 7.9 % in the same period. 

23  COM(2018) 773, “A Clean Planet for all: A European strategic long-term vision for 

a prosperous, modern, competitive and climate neutral economy”, page 3. 
Regulation (EU) 2021/1119 establishing the framework for achieving climate neutrality 
(‘European Climate Law’), recitals 16-17. 

24  The European Green Deal, page 1, COM(2019) 640. 

 
 
 
30 

Figure 9 – Greenhouse gas emission evolution across the world in the 
1990-2019 period 

Billion tonnes of CO2 equivalent

35

30

25

20

15

10

5

0

Total emissions
(Change since 1990)

+259 % China

+166 % India

-5 % Japan

-33 % Russia

-26 % EU-27

+2 % USA

Source: For USA, EU, Japan and Russia: ECA based on UNFCCC: for India and China: PBL Netherlands 
Environmental Assessment Agency, 2021 report. 

51 This is also due to the fact that the EU managed to decouple emissions from 
economic growth as shown in Figure 10. 

 
 
 
Figure 10 – Decoupling of greenhouse gas emissions from economic 
growth 

31 

130 %

120 %

110 %

100 %

90 %

80 %

70 %

Decoupling of 
emissions from 
economic growth
(Change since 2005)

+14 % in GDP

-21 % in GHG emissions

/

Emission intensity
(ratio of GHG emissions 
produced to GDP)

410

359

312

263

Source: ECA based on European Environment Agency. 

52 The EU also compares well to other major economies in terms of emissions 
intensity over GDP (i.e. greenhouse gas emissions/GDP), in particular compared to the 
USA and Japan, which started from similar emissions intensity levels in 1990 
(see Figure 11). 

Figure 11 – Evolution of emissions intensity over GDP across the world  

Kilograms of CO2e/GDP

4.0

3.5

3.0

2.5

2.0

1.5

1.0

0.5

0.0

Source: ECA based on UNFCCC. 

/

Emissions intensity
(Change since 1990)

-47 % Russia

-54 % India

-74 % China

-50 % USA

-54 % EU-27

-27 % Japan

 
 
 
 
32 

53 The EU also performs well in terms of emission intensity per capita (i.e. greenhouse 
gas emissions per capita) - see Figure 12 - in particular compared to Japan, which 
started from a similar emission intensity level in 1990. 

Figure 12 – Evolution of emission intensity per capita across the world 

Tonnes of CO2e/capita

30

25

20

15

10

5

0

Source: ECA based on UNFCCC. 

/

Emissions per capita
(Change since 1990)

-22 % USA

-31 % Russia

-8 % Japan
+197 % China

-30 % EU-27

+59 % India

Net emissions from imported goods not accounted for in greenhouse gas 
emissions 

54 The EU decarbonised its economy faster than other large economies between 1990 
and 2019. However, worldwide reporting is currently based on a “production-based” 
approach, whereby emissions are accounted for where products are manufactured and 
emissions are generated25. This approach does not take into account “carbon leakage”, 
which refers to a situation where businesses transfer production to other countries, 
for instance with laxer emissions constraints26. 

55 If the EU used a “consumption-based” approach, whereby emissions 
include “carbon leakage” and are calculated on the basis of where products are 
consumed rather than where they are produced, EU emissions are estimated to be 

25  Based on the United Nations Framework Convention on Climate Change (UNFCCC). 

26  European Commission – Carbon Leakage. 

 
 
 
 
33 

around 8 % higher than the levels currently reported27: an additional 300 million tonnes 
of CO2. This is because the EU is a net importer of goods from the rest of the world. 

56 There is so far no methodology that is applied internationally to measure and 
report on “carbon leakage”. One of the five member states’ authorities we interviewed, 
in Sweden, has proposed a national law to include, in its national greenhouse gas 
emissions, also those generated in non-EU countries manufacturing goods imported into 
Sweden (see Box 3). 

Box 3 

Sweden proposed a law to take account of carbon leakage when 
reporting on its national greenhouse gas emission target 

In April 2022, the Swedish government proposed to include emissions generated 
abroad for imported goods in Sweden’s national target for greenhouse gas 
emissions. According to the Swedish Environmental Protection Agency, about 
60 % of Sweden’s total greenhouse gas emissions originate from abroad. 

If the Parliament adopts the proposal, Sweden will become the first country in the 
world to take responsibility for the carbon footprint of imported goods. 

57 In 2021, as part of its Fit-for-55 package, the Commission proposed to introduce 
the Carbon Border Adjustment Mechanism28 for a number of sectors (e.g. iron and steel 
and cement). This mechanism will attach the same price to the carbon content of 
imported goods as to those produced within the EU, requiring importers of goods 
manufactured outside the EU to buy Carbon Border Adjustment Mechanism certificates. 
Through this mechanism, the EU will start compiling data on “carbon leakage”, which 
could contribute to measuring emissions under a “consumption-based” approach. 

Emissions from international aviation and shipping not accounted for in 
greenhouse gas emissions 

58 Current worldwide reporting also fails to include emissions from international 
aviation and shipping, pending a world-wide solution being agreed under the umbrella 

27  Commission’s Joint Research Centre and Eurostat estimation in page 342 of the “Sustainable 

development in the European Union”, May 2022. 

28  Proposal for a regulation establishing a carbon border adjustment mechanism. 

COM(2021) 564. 

 
 
 
34 

of the International Civil Aviation Organization29. In the EU, in 2019, these sectors 
generated 3.4 % and 3.6 % of total greenhouse gas emissions respectively. They are 
the two sectors where greenhouse gas emissions grew the most in the 1990-2019 
period (see Figure 13). As an example, greenhouse gas emissions from international 
aviation grew by 146 %, whereas total EU greenhouse gas emissions dropped by 26 % 
(see Figure 15). 

Figure 13 – Breakdown of EU greenhouse gas emissions by sector in 1990 
and 2019 

Greenhouse gas emissions in 1990
5 003 million tonnes of CO2e (100 %)

Greenhouse gas emissions in 2019 
3 874 million tonnes of CO2e (100 %)

International shipping (2.1 %)

International aviation (1.1 %)

Transport (13.5 %)

Other combustion (2.1 %)

Waste (3.5 %)

Agriculture (9.7 %)

Buildings (12.4 %)

Industry (23.8 %)

Energy supply (31.9 %)

3.6 %

3.4 %

21.6 %

2.2 %

2.9 %

9.9 %

11.5 %

19.9 %

25.1 %

1990

2019

Source: ECA based on the 2022 greenhouse gas emissions inventory published by the European 
Environment Agency. 

59 While greenhouse gas emissions from domestic aviation (flights within a member 
state) were included in the 2020 EU greenhouse gas emissions target, emissions from 
international aviation (both intra-EU and extra-EU flights) were excluded. 
These represent almost 90 % of greenhouse gas emissions from the aviation sector 
(see Figure 14). 

29  European Commission – Reducing emissions from aviation. 

 
 
 
 
Figure 14 – Breakdown of greenhouse gas emissions in the aviation sector 

35 

Domestic 
aviation

16
(11 %)

Intra-EU 
aviation

50
(33 %)

149
million tonnes 
CO2e 

83
(56 %)

Extra-EU 
aviation

Source: ECA based on European Environment Agency. 

60 In 2021 the EU made a first step in accounting for the emissions from international 
aviation and shipping, by including greenhouse gas emissions from intra-EU aviation and 
shipping in the 2030 EU target (-55 %). Extra-EU emissions in both sectors are still not 
captured by this target. In the aviation sector, extra-EU emissions represent 56 % of 
emissions (see Figure 14). 

Commission has a good overview of sectoral contribution to 
targets, but lacks key information on cost-effectiveness of 
reaching the targets 

61 For the EU to be able to draw lessons from the achievement of the 2020 climate 
and energy targets, the Commission should – based on the input of member states - 
identify the sectors and policies that proved successful in achieving these targets, 
building on information reported under the applicable legislation30. Particular focus 
should be put on identifying policies allowing the EU to achieve its targets in a cost-

30  European Climate Law (Regulation (EU) No 2021/1119), recital 36 and Article 6. 

Governance Regulation (Regulation (EU) No 2018/1999), Articles 18-21 and 29-32. 
Regulation (EU) No 525/2013 on monitoring and reporting of greenhouse gas emissions and 
other information relevant to climate change. 

 
 
 
 
36 

effective manner31. On the basis of this assessment, the Commission should take 
initiatives to facilitate the achievement of the more ambitious 2030 targets. 

The Commission has identified which sectors successfully contribute to 
the targets 

62 The Commission has a good overview of how the different sectors contribute to 
the three headline targets, through a reporting system managed by Eurostat and the 
European Environment Agency (EEA) based on member states’ data. Figure 15 shows 
the evolution of greenhouse gas emissions per sector in the EU from 1990 to 2019, 
the year before the COVID-19 pandemic. 

31  European Climate Law (Regulation (EU) No 2021/1119), recital 4. 

Commission communication on Fit for 55: delivering the EU's 2030 Climate Target on the way 
to climate neutrality (COM(2021) 550 final), page 2. 
Impact assessment accompanying the Package of Implementation measures for the EU's 
objectives on climate change and renewable energy for 2020, (SEC(2008) 85 C6-0041/080, 
page 3. 

 
 
 
37 

Figure 15 – Greenhouse gas emission evolution in the EU by sector  
(1990-2019) 

Growth rate 
(2019 compared 
to 1990)

Greenhouse gas 
emissions in 2019
(million tonnes of CO2e)

Energy supply

-39 %

Industry

-35 %

Waste

-34 %

Buildings

-29 %

Agriculture

-21 %

Other combustion

-18 %

Transport

International shipping

International aviation

24 %

34 %

146 %

972

772

114

444

382

84

835

138

133

Total GHG emissions

-22 %

3 874

Source: ECA based on European Environment Agency. 

63 The overall reduction in EU greenhouse gas emissions was mostly driven by 
the sectors covered by the ETS, i.e. energy supply and industry. Not all greenhouse gas 
emissions from the industry sector are covered by the EU ETS, which addresses mainly 
heavy industries (e.g. iron and steel, cement, chemicals). Box 4 explains how the EU ETS 
works and successfully contributes to cutting emissions. 

 
 
 
38 

Box 4 – The EU Emissions Trading System (ETS) 

The EU ETS works as a “cap-and-trade” system, in which operators (around 10 000 
power stations and manufacturing plants) must forfeit one emissions allowance per 
tonne of greenhouse gas they emit. These operators may receive allowances for 
free or obtain them through auctions. Each year the total number of available 
allowances is reduced, providing a “cap”. 

Emission allowance

Shortage

Surplus

Free allocation

Emissions

Auction

Emission allowance

Source: ECA adapted from the European Commission’s EU ETS Handbook, 2015. 

In our previous special report 18/2020, we found that, when requiring operators to 
pay for their allowances through auctions, the ETS respects the “polluter pays” 
principle and provides an incentive for operators to cut emissions. 

64 The other sectors not covered by the ETS contributed less to the overall reduction 
in greenhouse gas emissions, or even increased their emissions. In particular, from 1990 
until 2019, greenhouse gas emissions rose significantly in transport (by 24 %), 
international shipping (by 34 %) and international aviation (by 146 %). These three 
sectors, which accounted for 16.6 % of EU greenhouse gas emissions in 1990, accounted 
for 28.5 % in 2019 (see Figure 13). 

65 Building on the successful ETS, the Commission has proposed to reinforce it in 
the “Fit for 55 package”. Under the proposal, the ETS will be extended to include 
shipping, and a parallel ETS will be created for road transport and buildings. 

 
 
 
 
 
39 

The Commission and member states have sparse information on the cost 
and effects of actions to reach the targets 

66 Ensuring that the EU’s policies allow it to achieve its targets in a cost-effective 
manner requires an overview of the cost and effects (in terms of greenhouse gas 
emissions reductions) of the policies put in place. The sub-sections below report on 
the information available on the EU, national and private funding for the 2020 and 2030 
targets. 

2020 targets 

67 As regards the EU funding, in a previous special report32, we reported that 
the Commission overstated the amount of funds from the EU budget spent on climate 
action. It estimated it at 20 %, while our audit established the figure to be around 13 %. 
Furthermore, in previous special reports we noted that the Commission generally has no 
information on the contribution of individual EU spending programmes to the EU’s 
climate and energy targets33. 

68 As regards national funding, we found that the Commission has sparse information 
on the member states’ policies aimed at achieving their climate targets. The Commission 
obtains this information through the “EEA database on greenhouse gas policies and 
measures in Europe” reporting. Since 2015, every two years member states must report 
on their national greenhouse gas policies and measures, following a detailed template 
set by the Commission34 (see Annex V). This includes key data on projected and realised 
cost and greenhouse gas emissions reductions, when information is available. 

32  ECA special report 09/2022. 

33  ECA special report 21/2012, Recommendation 2. 

ECA special report 06/2014, paragraph 54 and Recommendation 1. 
ECA special report 05/2018, paragraph 91 and Recommendation 4. 
ECA special report 08/2019, paragraph 89 and Recommendation 6. 
ECA special report 18/2019, paragraphs 59-65 and Recommendation 2. 
ECA special report 11/2020, Recommendation 1b, paragraph 93 and Recommendation 3. 
ECA special report 16/2021, Recommendation 1, paragraph 95 and Recommendation 3. 
ECA special report 02/2022, paragraphs 107-120 and 137-139. 

34  Commission implementing Regulation (EU) No 749/2014 on information reported by 

Member States, Article 22 and Annex XI. 

 
 
 
40 

69 We analysed this database in October 2022 and found the following: 

o  member states reported 2 053 policies and measures, of which 1 391 (68 %) had 

been implemented. 

o 

data on costs only existed for six policies and measures. Data on effects in terms of 
greenhouse gas emission reductions only existed for 474 policies and measures 
(i.e. 34 % of the 1 391 that had been implemented). 

70 According to the 2021 EEA report, the level of quantitative information reported is 
low because member states do not use common evaluation approaches and 
methodologies, find it difficult to separate the effects of individual policies from others, 
and are only rarely interested in communicating the actual effects of past actions. 
The five member states we interviewed explained they did not manage to provide all 
the data requested, as they considered it too detailed. It also sometimes overlapped 
with other requests, such as reporting under individual directives, and statistical 
reporting to Eurostat and to the UNFCCC. According to this report, the fact that the EEA 
guidelines for reporting on greenhouse gas policies and measures did not include 
methods for assessing the costs and effects of the policies and measures reported is 
an additional explanatory factor for the low level of information.  

71 Since 2018, the Commission has produced guidance to address this problem35. 
However, the Commission informed us that in practice member states consider 
reporting information on cost and effect to be voluntary and are not in favour of making 
it a mandatory requirement. 

72 At our request, four (Germany, Italy, Poland and Sweden) of the five member 
states’ authorities we interviewed provided data on the actual cost and effects of 
the policies in place to reach the 2020 targets, which shows that some data on costs and 
effects exists at member states’ level. However, member states were only able to 
provide data covering one third of the greenhouse gas emissions reductions that 
they had achieved by 2020. Ireland had no data on the cost and effects of its policies put 
in place to reach the 2020 targets. 

35  Overview of policy evaluation guidelines. 

 
 
 
41 

73 As regards private funding, neither the Commission nor the authorities 
interviewed in the five member states could provide data on the amount of private 
funds mobilised to reach the 2020 targets, or estimate the reduction in greenhouse gas 
emissions achieved as a result of private action. 

2030 targets 

74 The need to better estimate and track the costs and effects of the policies to 
achieve more ambitious 2030 targets was reflected in the National Energy and Climate 
Plans (NECPs), which member states were required to submit in 2019/2020 
(see paragraph 09). When outlining the policies to put in place for the 2021-2030 period 
to achieve the targets, member states were required to include much more detailed 
information than in the previous period on the expected costs and effects of policies36: 

o 

o 

o 

o 

the expected national targets; 

the investment gap which needs to be filled, in order to achieve their national 
targets; 

the source and amount of budget required to fill the investment gaps, to provide 
guidance to market players and mobilise private investments; and 

the main policies and measures to fill the investment gaps not covered by private 
sectors, specifying their indicative timeline and expected contribution to reducing 
greenhouse gas emissions. 

75 As regards the expected national targets as quantified by member states in their 
NECPs, the Commission concluded that the cumulative ambition of the 27 member 
states was sufficient to reach the EU greenhouse gas emissions and renewable energy 
share targets. At the same time, the Commission concluded that the collective ambition 
of the 27 member states towards the 2030 energy efficiency target was insufficient: 

36  Articles 9 and 17 of Regulation (EU) 2018/1999 on the Governance of the Energy Union and 

Climate Action. 
Commission communication “United in delivering the Energy Union and Climate Action – 
Setting the foundations for a successful clean energy transition”, COM(2019) 285 final, 
pages 7-12. 

 
 
 
42 

it amounts to a reduction of 29.7 % for primary energy consumption, 2.8 percentage 
points below the EU’s target of 32.5 % for 203037. 

76 As regards investment gaps, in our previous report on sustainable finance38 
we highlighted that information on investment needs was incomplete, inconsistent and 
showed large disparities. For the five NECPs we reviewed, we found that there was only 
a general estimate of the amount of investment needed to reach the 2030 targets and, 
at best, a breakdown of the investment needed in each sector of the economy. 
The NECPs did not specify how such estimates were calculated, which makes it 
impossible to assess their reliability. 

77 The five NECPs we reviewed did not indicate the source or the amount of budget 
required to fill the investment gaps. It is thus not clear to what extent existing policies 
could meet these needs, or how much private investments should be mobilised. 

78 As regards the main policies and measures put in place to reach the 2030 targets, 
we found that the five NECPs we reviewed provided different degrees of details. In most 
cases, they did not specify their indicative timeline and expected greenhouse gas 
emissions reductions. 

79 On 15 December 2022, the Commission issued guidance to member states for 
updating their NECPs39, which addresses these shortcomings. This guidance encourages 
member states to provide structured information on expected investments and on their 
financing, both from public and private sources. However, the guidance is not 
mandatory for member states, which entails the risk that member states will continue 
to provide sparse information in their plans. 

37  Commission Communication on “An EU-wide assessment of National Energy and Climate 

Plans”, COM(2020) 564. 

38  ECA special report 22/2021, “Sustainable Finance: More consistent EU action needed to 

redirect finance towards sustainable investment”, paragraph 73. 

39  Commission Notice C(2022) 9264 on the Guidance to Member States for the update of the 

2021-2030 national energy and climate plans. 

 
 
 
43 

80 By 15 March 2023 member states had to report on the implementation of 
the NECPs for the first time, based on a Commission implementing regulation40, 
published on 25 November 2022. The Commission publishes the status of member 
states’ reporting on its website. This regulation requires member states to report on 
realised cost and effects of the policies put in place. However, parts of this reporting 
remain voluntary. This may result in member states providing sparse information, as it is 
the case for the EEA database (see paragraph 69).  

Little indication so far that more ambitious EU targets will translate into 
sufficient action 

81 The Commission noted that the NECPs are not sufficiently ambitious to reach 
the 2030 energy efficiency target (paragraph 75) and do not provide sufficient details 
to make it possible to assess whether they represent a sound basis for reaching the 
2030 targets (see Annex IV). Furthermore, we found that the NECPs only provide vague 
information on investment gaps and sources of financing to fill them 
(see paragraphs 74-75). In our special report 22/2021 on sustainable finance, 
we conclude that more EU action is needed to redirect private and public finance 
towards sustainable investments. 

82 The Commission proposes to further increase the level of the 2030 targets in 
the context of the 2021 Fit-for-55 package and the 2022 REPowerEU Plan proposal 
(see paragraphs 06 and 07). In our Opinion 04/2022 on the REPowerEU Plan proposal, 
the issue of a possible lack of financing emerged again; we noted that it was unclear 
whether the funds available would be in proportion to REPowerEU’s ambitious 
objectives and corresponding investment needs. 

40  Commission Implementing Regulation (EU) 2022/2299 laying down rules as regards the 
structure, format, technical details and process for the integrated national energy and 
climate progress reports, Article 7 and Annex IX. 

 
 
 
44 

83 We also found that the impact assessment underlying the Fit-for-55 package 
involved several assumptions concerning member states, such as the full 
implementation of existing policies and the full achievement of the expected effects of 
existing policies. It also pointed to the need of further technological advances in energy 
and transport, including rapid electrification, carbon capture and storage. Evidence from 
our previous reports show that such assumptions often do not fully materialize as 
planned41. 

84 The scenario analyses underlying the impact assessment furthermore did not 
sufficiently consider known issues such as the energy dependency from Russia42, or 
the projected decrease in the availability of critical raw materials43, essential to 
the technological development of renewables, batteries and electrification modelled in 
the scenarios. 

85 Finally, the latest data on 2021 greenhouse gas emissions, renewable energy share 
and energy efficiency (see paragraphs 23-26) indicate a major rebound effect after the 
COVID-19 pandemic, which represents a further challenge in reaching the revised 2030 
targets. 

41  ECA special report 06/2014, paragraph 53. 

ECA special report 24/2018, paragraphs 108 and 112. 
ECA special report 08/2019, paragraph 80. 
ECA special report 18/2019, paragraph 75. 
ECA special report 11/2020, paragraph 93. 
ECA special report 05/2021, paragraphs 71-74. 
ECA special report 16/2021, paragraph 95. 
ECA special report 02/2022, paragraphs 137-139. 

42  Commission Communication on “European Energy Security Strategy”, COM(2014) 330. 

43  JRC’s Raw Materials Information System analyses. 

 
 
 
 
45 

Conclusions and recommendations 

86 We found that the EU had achieved the three headline climate and energy targets 
(greenhouse gas emissions, renewable energy share and energy efficiency) for 2020. 
However, this was also due to the contribution of external factors, such as the COVID-19 
pandemic and unexpected GDP fluctuations. The Commission has only a partial 
overview of the actions that proved successful in achieving the targets. The targets 
for 2030 are more ambitious than those for 2020, and we found little indication so far 
that this ambition will translate into sufficient action. 

87 The Commission monitored the progress of the EU towards achieving its headline 
targets. It did not, however, assess the extent to which this progress was a result of 
the policies rather than external factors, such as the financial crisis in 2009 and the exact 
contribution of the COVID-19 pandemic in 2020. We found that, while the greenhouse 
gas emissions and renewable energy share targets would most likely have been 
achieved without the economic decline caused by COVID-19, the pandemic played 
a significant role in the achievement of the energy efficiency target (paragraphs 19-26). 

88 The EU broke down the 2020 EU targets into national targets. While the majority 
of member states made their expected contributions, some did not: 

o 

o 

o 

Seven member states did not achieve their indicative targets on energy efficiency 
(paragraph 26); 

Three member states did not reach their binding greenhouse gas emissions targets 
solely based on their climate action, and had to buy emissions allocations from 
other member states that over-achieved their targets or to use international credits 
(paragraphs 41-44); 

Six member states did not reach their binding renewable energy share targets 
solely based on their climate action, but did so by buying shares from other 
member states that over-achieved their targets, except France, which by April 2023 
had not bought the missing shares to reach its target (paragraphs 45-47). 

89 The Commission publishes information on the quantities of greenhouse gas 
emissions or renewable energy shares transferred between member states, but not on 
their price. This lack of transparency on the way member states reach their national 
binding targets through flexibilities makes it difficult for citizens and stakeholders 
to determine whether the EU achieves its overall targets in a cost-effective way 
(paragraphs 40-47). 

 
 
46 

90 Another important factor which, beyond the member states’ actions, influenced 
the achievement of the national targets was the fact that the GDP of several member 
states did not grow as expected, mainly because of the financial crisis in 2009. 
Some member states reached their targets just a few years after they were set. Intensity 
indicators could be useful in assessing the drivers of progress towards the climate and 
energy targets, especially when GDP does not grow as forecast. However, we found that 
the Commission did not use the existing reporting on intensity indicators to analyse 
the drivers of progress and recommend improvements in climate and energy action, 
when assessing member states’ performance (paragraphs 27-35). 

Recommendation 1 – Provide more transparency on the 
performance of the EU and its member states on climate and 
energy action 

To provide more transparency on the performance of the EU and its member states on 
climate and energy action, the Commission should: 

(a)  use available reporting on greenhouse gas emissions per unit of GDP and per capita 
to assess the drivers of member states’ progress and to engage with member states 
with the aim at improving the performance of their climate and energy action, 
when needed; 

Target implementation date: December 2024 

(b)  assess and report on the EU and member states’ progress towards the targets, 

by distinguishing the impact of policies in place from the impact of external factors;  

Target implementation date: March 2026 

(c) 

implement measures to allow for greater transparency regarding the price of 
greenhouse gas emissions and individual renewable energy share transfers. 

Target implementation date: December 2024 

91 The EU has committed itself to being a global leader in the transition towards 
climate neutrality. We found that the EU compares well to other industrialised 
countries, in terms of greenhouse gas emissions reduction. However, accounting for 
emissions does not include those produced as a result of trade. Including these would 
increase the EU greenhouse gas emissions by about 8 %. Furthermore, the Commission 
also fails to include all emissions from international aviation and shipping in 

 
 
47 

its greenhouse gas target (respectively 3.4 % and 3.6 %), as it currently only includes 
those from intra-EU aviation and shipping (paragraphs 49-60). 

Recommendation 2 – Account for all greenhouse gas emissions 
caused by the EU 

To account for all greenhouse gas emissions caused by the EU, the Commission should: 

(a)  Assess the possibility of using the data it will collect through the Carbon Border 

Adjustment Mechanism to complement its reporting on EU progress towards 
the EU’s 2030 greenhouse gas emission reduction target with reporting on 
emissions associated with imported goods to the EU; and 

(b)  assess the feasibility of including in its 2050 target for climate neutrality the EU’s 

share of emissions from international aviation and shipping. 

Target implementation date: December 2026 

92 The Commission has only a partial overview of the actions that proved successful 
in achieving the 2020 and 2030 targets. It has identified which of the sectors are 
successful - i.e. those sectors covered by the emissions trading scheme - and 
consistently made proposals to reinforce the emissions trading scheme in the “Fit for 55 
package” (paragraphs 61-65). 

93 Since 2015, member states have provided the Commission with more information 
on the policies they have in place to achieve the targets, first through the European 
Environment Agency database (2020 targets), then also through the member states’ 
National Energy and Climate Plans (2030 targets). Despite this, the Commission still lacks 
information on the costs and effects of actions (paragraphs 66-80). 

94 Looking ahead to the 2030 targets, a particular concern is that the 2016 EU wide 
estimates on financing needs have not been followed up by similar assessments at 
the national level in the National Energy and Climate Plans, together with an analysis of 
the financing sources to fill the gaps. There is thus no information that sufficient 
financing will be made available to reach the 2030 targets, in particular from the private 
sector. The Commission also reported that member states have a lack of collective 
ambition towards achieving the 2030 energy efficiency target, which had already proven 
to be the hardest to achieve by 2020 (see paragraphs 66-80). 

 
 
48 

95 The Commission made proposals to further raise the 2030 targets in its 2021  
Fit-for-55 proposal and in the 2022 REPowerEU proposal. This will put further pressure 
on the level of financing needed, as well as the collective ambition of the member 
states. The latter may prove particularly challenging to achieve (see paragraphs 81-85), 
in a context where: 

o 

o 

the impact assessment of the Fit-for-55 package involved several assumptions 
concerning progress by member states (e.g. full implementation of existing 
policies). Evidence from our previous reports show that such assumptions often 
do not fully materialize as planned; 

its underlying analyses prior to 2021 did not take into account sufficiently known 
issues, such as energy dependency on Russia, or the estimated decrease in 
the availability of critical raw materials, essential to the technological development 
of renewables; 

o 

the latest data on 2021 greenhouse gas emissions, renewable energy share and 
energy efficiency indicates a major rebound effect after the COVID-19 pandemic. 

Recommendation 3 – Support member states’ commitment to 
achieving the 2030 targets  

To support member states’ commitment to achieving the 2030 targets, the Commission 
should: 

(a)  work together with member states to include in the updated National Energy and 
Climate Plans consistent information on the expected cost and effects of policies 
for achieving the targets, as well as on investment needs and funding sources to fill 
those needs. 

Target implementation date: December 2024 

(b)  assess the feasibility of enhancing the current system of transfers of greenhouse 

gas emissions and renewable energy shares between member states, including 
the option of closer aligning the price of transfers with market prices. 

Target implementation date: December 2025 

 
 
This Report was adopted by Chamber I, headed by Mrs Joëlle Elvinger, Member of 
the Court of Auditors, in Luxembourg at its meeting of 10 May 2023. 

For the Court of Auditors 

49 

Tony Murphy 
President 

 
 
 
 
 
 
 
 
 
 
50 

Annexes 

Annex I – National achievements of 2020 greenhouse gas 
emission target per member state 

Million tonnes of CO2 equivalent

level 2005

achievement 2020

target 2020

600

500

400

300

200

100

0

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Source: ECA based on data from European Environment Agency. 

 
 
 
 
51 

Annex II – National achievements of 2020 renewable energy 
share target per member state 

Renewable energies share
(total)

level 2005

achievement 2020

target 2020

70 %

60 %

50 %

40 %

30 %

20 %

10 %

0 %

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Source: ECA based on data from Eurostat. 

 
 
 
 
52 

Annex III – National achievements of 2020 energy efficiency 
target per member state (in primary and final energy 
consumption) 

Primary energy consumption
(million tonnes of oil equivalent)

level 2007

achievement 2020

target 2020

350

300

250

200

150

100

50

0

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Final energy consumption
(million tonnes of oil equivalent)

level 2007

achievement 2020

target 2020

53 

250

200

150

100

50

0

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Source: ECA based on data from Eurostat. 

 
 
 
 
 
54 

Annex IV – Extract of the Commission’s assessment of reporting 
of investment needs and their funding sources in five National 
Energy and Climate Plans we reviewed  

Member 
State 

Reporting of investment 
needs 

Reporting of funding sources 

Germany 

The plan largely addresses and 
quantifies the energy-related 
investment needs stemming 
from additional measures, 
though it does not indicate the 
estimated overall amount of 
private and public funding up to 
2030.  

Overall, the plan lacks a 
comprehensive overview of the 
source of additional investment 
needs reported up to 2030.  

Ireland 

The plan does not assess the 
overall investment needs, 
which could be fulfilled by 
either the public or private 
sector, to achieve the objectives 
and ambition defined under the 
Without Additional Measures 
scenario, though it stresses the 
need to mobilise private 
investment.  

The role of public finance is mentioned 
in a dedicated section. However, the 
information provided is not quantitative, 
as it does not specify the proportion of 
each level in the overall funding.  

By 2030, the energy and climate fund 
will allocate some three-digit billion 
euros to climate action and the energy 
transition.  

Other support measures are mentioned, 
but without being described. The 
relationship between the different 
sources of investment is unclear. 

The role of EU funds such as the 
Connecting European Facility or the 
cohesion policy funds is mentioned. The 
Just Transition Fund is mentioned for 
regions particularly affected by 
structural change. 

The plan does not quantify the 
proportion of public-sector funding in 
this investment. Nor does it indicate the 
different levels of financing (national, 
European).  

No indication is provided on the scale of 
the private investment that will need to 
be mobilised.  

It is clear that EU funding such as the 
Connecting Europe Facility will remain 
an important source of funding for 
Ireland. 

Some details are provided on specific 
programmes, funds or projects and their 
budgets, but this is done in a rather ad 
hoc manner and it does not cover all 
policies, measures or ambitions. 

 
 
Member 
State 

Reporting of investment 
needs 

Reporting of funding sources 

55 

The plan estimates that between 2017 
and 2030, € 183 billion in cumulative 
additional investment will be needed 
compared to the current policies 
scenario (equivalent to an 18 % 
increase) to address the objectives set 
out by the plan. The assessment of 
expenditure and funding sources 
presented for the national, regional or 
EU levels remains partial. 

However, the plan does not provide 
clear details on the methodology 
applied to calculate investment needs, 
nor does it identify risk factors, or 
develop a strategy to close the 
investment gap. 

Due to the lack of information at policy 
level it is difficult to see whether the 
targets might be achieved, as the 
policies which are evaluated are not 
achieving the targets. The number and 
type of policies might not be enough to 
achieve targets, particularly after 2022, 
when measures have yet to be budgeted 
and approved. 

The plan identifies priority investment 
areas and the funding sources, but 
provides limited information on market 
barriers and risks. 

Some national and other EU funding 
sources are mentioned e.g. the 
Modernisation Fund, the EU’s 
Framework Programme for Research 
and Innovation and free allowances 
from the EU ETS.  

The identified investment needs are 
generally not matched with a funding 
analysis. In particular, the funding 
analysis for additional public financial 
support is not sufficiently detailed. 

Italy 

The plan provides substantial 
information on investment 
needs, including the 
incremental annual investments 
needs for 2017-2030 across 
different sectors and their 
expected macroeconomic 
impacts. 

Poland 

The plan considers investment 
needs extensively in the WAM 
scenario, broken down by 
sector, with priority investment 
objectives listed, and there is a 
sophisticated macroeconomic 
analysis.  

The investment needs are 
further broken down by sector.  

 
 
56 

Member 
State 

Reporting of investment 
needs 

Reporting of funding sources 

Sweden 

The plan does not specify an 
overall estimated amount of 
investment needs. Other than 
for electricity production 
capacity and distribution 
infrastructure, it lacks a 
quantitative assessment of 
Sweden’s investment needs to 
achieve its climate and energy 
objectives. 

The plan lacks a comprehensive 
summary and an assessment of the 
multiple sources of funding at EU, 
national or regional level. 

In the section on decarbonisation, the 
plan describes several measures based 
on government funding such as the 
‘Climate Leap’ and the ‘Industrial Leap’. 

Source: Commission assessment of final NECPs.

 
 
Annex V – Reporting template on member states’ policies and measures 

57 

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Ex-ante assessment 

Ex-post assessment 

58 

Policy impacting EU ETS or 
ESD emissions (both can be 
selected) 

GHG emissions reductions 
in t (kt CO2-equivalent per 
year) 

GHG emissions reductions 
in t+5 (kt CO2-equivalent 
per year) 

GHG emissions reductions 
in t+10 (kt CO2-equivalent 
per year) 

GHG emissions reductions 
in t+15 (kt CO2-equivalent 
per year) 

EU ETS 

ESD 

LULUCF 

Total 

EU ETS 

ESD 

Total 

EU ETS 

ESD 

Total 

EU ETS 

ESD 

Total 

EU ETS 

ESD 

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Projected costs and benefits 

Realised costs and benefits 

Policy or 
measure or 
groups of 
policies and 
measures 

Costs in EUR 
per tonne 
CO2eq 
reduced/ 
sequestered 

Absolute costs 
per year in EUR 
(specify year 
cost has been 
calculated for) 

Description of 
cost estimates 
(Basis for cost 
estimate, what 
type of costs are 
included in the 
estimate, 
methodology) 

Price 
year 

Year for 
which 
calculated 

Documenta
tion/Source 
of cost 
estimation 

Costs in EUR 
per tonne 
CO2eq 
reduced/ 
sequestered 

Price 
year 

Year for 
which 
calculated 

Description of 
cost estimates 
(Basis for cost 
estimate, what 
type of costs are 
included) 

Documentation/
Source of cost 
estimation 

Source: Commission implementing Regulation (EU) No 749/2014 on structure, format, submission processes and review of information reported by Member States 
pursuant to Regulation (EU) No 525/2013 - Annex XI. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
59 

Acronyms and abbreviations 

EEA: European Environment Agency 

ETS: Emissions Trading System 

GDP: Gross Domestic Product 

NECPs: National Energy and Climate Plans 

UNFCCC: United Nations Framework Convention on Climate Change 

 
 
 
 
60 

Replies of the Commission 

https://www.eca.europa.eu/en/publications/sr-2023-18 

Timeline 

https://www.eca.europa.eu/en/publications/sr-2023-18 

 
 
 
 
 
 
 
 
 
 
 
 
61 

Audit team 

The ECA’s special reports set out the results of its audits of EU policies and programmes, 
or of management-related topics from specific budgetary areas. The ECA selects and 
designs these audit tasks to be of maximum impact by considering the risks to 
performance or compliance, the level of income or spending involved, forthcoming 
developments and political and public interest. 

This performance audit was carried out by Audit Chamber I Sustainable use of natural 
resources, headed by ECA Member Joëlle Elvinger. The audit was led by ECA Member 
Joëlle Elvinger, supported by Ildiko Preiss, Head of Private Office and Paolo Pesce, 
Private Office Attaché; Florence Fornaroli, Principal Manager; Lorenzo Pirelli, Head of 
Task, Josef Edelmann, Deputy Head of Task, and Timo Lethinen, Auditor. 
Marika Meisenzahl provided graphical support. Judita Frangez provided secretarial 
support. 

From left to right: Judita Frangez, Florence Fornaroli, Josef Edelman, Lorenzo Pirelli, 
Joëlle Elvinger, Paolo Pesce, Ildiko Preiss, Marika Meisenzahl. 

 
 
 
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HTML 

ISBN 978-92-849-0419-8 

ISSN 1977-5679  doi:10.2865/105673  QJ-AB-23-016-EN-Q 

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The EU achieved its 2020 climate and energy targets, but some 
member states did not contribute as expected to the targets. The 
Commission did not assess whether the EU had reached its 
targets as a result of its policies rather than as a result of external 
factors, such as the 2009 financial crisis and the COVID-19 
pandemic. The EU’s 2020 and 2030 greenhouse gas emissions 
targets do not include emissions embodied in imported goods or 
emissions from international aviation and shipping. Little data is 
available on the cost to the EU budget, national budgets and 
private sector at which the EU achieved its targets. The National 
Energy and Climate Plans lack data on investment needs and 
funding sources to assess whether such plans are a sound basis to 
reach the 2030 targets. 

ECA special report pursuant to Article 287(4), second 
subparagraph, TFEU.