REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the Review of the Regulation on the Governance of the Energy Union and Climate Action
Date: 2024-09-11
Institutions: Directorate-General for Energy, European Commission
Subjects: EU energy policy, adaptation to climate change, administrative formalities, energy cooperation, energy diversification, energy efficiency, green economy, reduction of gas emissions, renewable energy, security of supply

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 11.9.2024  COM(2024) 550 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the Review of the Regulation on the Governance of the Energy Union and Climate Action {SWD(2024) 200 final}  
 
 
1. EVALUATION OF THE GOVERNANCE OF THE ENERGY UNION AND CLIMATE ACTION: 
SETTING THE SCENE 

The  Regulation  on  the  Governance  of  the  Energy  Union  and  Climate  Action  (the 
‘Governance Regulation’, hereafter ‘the Regulation’) was adopted in December 20181. The 
aim  was  to  create  a  robust  governance  mechanism  to  enable  the  EU  to  achieve  its 
energy and climate objectives and meet the goals set by the 2015 Paris Agreement, 
while  integrating  and  simplifying  obligations  under  EU  energy  and  climate 
legislation.  The  Regulation  covers  the  five  dimensions  of  the  Energy  Union:  energy 
security,  the  internal  energy  market,  energy  efficiency,  decarbonisation,  as  well  as 
research, innovation, and competitiveness. 

The Regulation strengthens integrated national energy and climate policy planning 
by creating a coherent, efficient and transparent framework that streamlines, merges 
and simplifies a long list of scattered and partly overlapping monitoring obligations2. 
First, it supports strategic medium- and long-term energy and climate planning through 
integrated national  energy and  climate  plans (NECPs) and national  long-term strategies 
(LTSs). Second, it provides a framework for Member States to report on their progress in 
meeting the 2030 and the long-term energy and climate objectives and targets3, both to the 
Commission  and  to  the  United  Nations  Framework  Convention  on  Climate  Change 
(UNFCCC)  Secretariat.  Third,  it  enables  the  Commission  to  assess  and  monitor  the 
progress made by the EU and by Member States, and to take measures when the level of 
ambition and/or progress are insufficient. 

The Regulation aims to reduce administrative burden, provide clear investment signals 
to  investors,  and  improve  transparency  and  accountability  by  making  energy  and 
climate  policy  information  more  easily  accessible  to  the  public.  It  created  a  new 
cooperation  mechanism  between  Member  States  and  the  EU.  It  also  required  Member 
States to set up multi-level stakeholder dialogues involving local and regional authorities, 
civil  society  organisations,  business  community,  investors,  other  stakeholders,  and  the 
general public. 

This report evaluates how the Regulation has functioned and been implemented since 
it entered into force in 2018 and it is underpinned by an accompanying staff working 

2  

1    Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 on the 
Governance  of  the  Energy  Union  and  Climate  Action,  Regulation  -  2018/1999  -  EN  -  EUR-Lex 
(europa.eu). 
In  total,  the  Commission’s  proposal  for  the  Regulation  integrated,  streamlined  or  repealed  over  50 
individual  planning,  reporting  and  monitoring  obligations under  the  EU’s  energy  and  climate  acquis 
(integrating  31  and  deleting  23)  -  see  COM(2016)  759  final/2 2016/0375(COD),  see:  EUR-Lex  - 
52016PC0759R(01) - EN - EUR-Lex (europa.eu). 
Importantly, the Regulation does not contain reporting obligations for companies. 

3   

1 

 
 
 
document4.  The  evaluation  is  conducted  in  line  with  article 45  of  the  Regulation5.  The 
report assesses the contribution of the Regulation to the governance of the Energy Union, 
the long-term goals of the Paris Agreement, progress on the 2030 energy objectives, the 
EU’s 2050 climate-neutrality objective, as well as the other Energy Union objectives. The 
report also evaluates the extent to  which the Regulation integrates and is  coherent with  
relevant EU and international planning, reporting, and monitoring obligations. 

Assessing  the  EU’s  energy  and  climate  governance  framework  is  timely  and 
necessary.  It  is  politically  important  given  the  evolving  geopolitical  context  and  the 
pressing  climate,  economic,  competitiveness,  social  and  environmental  challenges.  An 
evaluation is a useful basis to help shape and implement the EU’s future energy and climate 
policies, particularly in view of our ambitions for 2040 and 20506. 

This report also identifies areas for improvement, including the potential to simplify 
and streamline reporting obligations, in line with the Commission’s overall commitment 
to reduce such obligations by 25%7. 

The evaluation draws on a wide range of sources and was underpinned by an external 
evaluation carried out by consultants8. The findings are partly based on consultations 
with national authorities, civil society organisations, industry, a stakeholder event9, views 
of  the  public  received  via  a  call  for  evidence10,  desk  research,  the  Commission’s 
assessments  of  NECPs11  and  of  NECP  progress  reporting12,  a  screening  of  planning, 

4   SWD(2024) 200 
5   The overall evaluation has been conducted in line with the Commission’s better regulation guidelines 
and is based on five standard evaluation criteria: effectiveness, efficiency, coherence, EU added value 
and relevance. 

6   Regulation (EU) 2021/1119 establishing the framework for achieving climate neutrality and amending 
Regulations  (EC)  No 401/2009  and  (EU)  2018/1999  (‘European  Climate  Law’)  sets  out  a  binding 
objective of climate neutrality in the EU by 2050 and, with a view to achieving this, requires setting an 
EU-wide climate target for 2040 (Regulation – 2021/1119 – EN – EUR-Lex (europa.eu)). To this effect, 
in February 2024 the Commission recommended reducing the EU’s net GHG emissions by 90% by 2040 
relative to 1990 (EUR-Lex – 52024DC0063 – EN – EUR-Lex (europa.eu)). 

7   Delivering 

today  and  preparing  for 

tomorrow: 

the  2024  Commission  work  programme,  

https://ec.europa.eu/commission/presscorner/detail/en/ip_23_4965. 

8     Support study for the evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union 

and Climate Action – final report (forthcoming) 

9   See:  https://energy.ec.europa.eu/events/workshop-evaluation-governance-energy-union-and-climate-

action-regulation-2024-01-11_en. 

10   See: 

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13799-Energy-Union-

and-climate-action-Review-report-on-the-Governance-Regulation_en. 

11   2019  Commission  EU-wide  assessment  of  2019  draft  NECPs  (COM/2019/285),  https://eur-
2020 
lex.europa.eu/legal-content/EN/TXT/?qid=1565713062913&uri=CELEX:52019DC0285; 
Commission  EU-wide  assessment  of 
the  2020  final  NECPs  https://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1600339518571&uri=COM%3A2020%3A564%3AFIN;  2020  Commission 
EU-wide assessment of the 2020 final NECPs (COM(2020) 564 final), https://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1600339518571&uri=COM%3A2020%3A564%3AFIN;  2023  Commission 
EU-wide  assessment  of  the  2023  draft  updated  NECPs  (COM/2023/796  final),  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2023%3A796%3AFIN. 

12    Assessment of progress towards the objectives of the Energy Union and Climate Action, SWD (2023) 

646 final, https://eur-lex.europa.eu/legal-content/RO/TXT/?uri=CELEX:52023SC0646. 

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reporting, and monitoring obligations under EU energy and climate law, and case studies 
in different Member States. 

2.  THE  EU’S  ENERGY  AND  CLIMATE  GOVERNANCE  IN  AN  EVOLVING  POLICY  AND 
GEOPOLITICAL CONTEXT 

The  European  and  international  energy  and  climate  landscape  has  evolved 
significantly since the Regulation was adopted. On the one hand, this is the result of 
increasing impacts from  climate change  that have triggered  major EU  and international 
policy responses, including the European Green Deal, the European Climate Law, the ‘Fit 
for 55’ package, the EU’s policy on climate risks and adaptation, as well as progress in 
implementing the Paris Agreement. The European Green Deal has also become the EU's 
new growth strategy, decoupling economic growth from resource use. On the other hand, 
EU  energy  and  climate  policies  have  evolved  in  response  to  the  unprecedented  crises 
triggered by the COVID-19 pandemic and Russia’s war of aggression against Ukraine.  

EU  legislative  developments  have  had  major  effects  on  the  Regulation.  Adopted  in 
2021,  the  European  Climate  Law  made  targeted  amendments  to  the  Regulation  to 
incorporate the EU’s climate-neutrality objective. The legislative changes by the Fit for 55 
package also brought in new planning and reporting obligations, some of which are yet to 
be  fully  incorporated  in  the  Regulation.  The  Commission’s  2022  guidance  on  updating 
NECPs13 encouraged Member States to increase the ambition of their plans in line with the 
Climate Law, the Fit for 55 package and the REPowerEU initiative14. 

Since  the  Regulation  entered  into  force,  major  policy  developments  have  also 
happened at international level. These include decisions on how to implement the Paris 
Agreement, such as through an ‘enhanced transparency framework’. At COP 28, parties to 
the Paris Agreement undertook the first ‘global stocktake’. They concluded that, while they 
are putting in place increasingly effective climate policies, urgent and additional action is 
needed. Parties also agreed to triple global renewable energy capacity and double the rate 
of energy efficiency improvements by 2030, as well as transition away from fossil fuels in 
energy systems. In addition, they created a Framework for Global Climate Resilience and 
launched the Belém work programme to establish climate adaptation indicators. They also 
committed  to  accelerate  action  to  phase  out  inefficient  fossil  fuel  subsidies  that  do  not 
tackle energy poverty or vulnerable groups15. 

13    Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy 
and  climate  plans  (2022/C  495/02),  Guidance  to  MS  for  updated  NECPs  2021-2030  -  European 
Commission (europa.eu). 

14    REPowerEU  is  the  EU’s  response  to  the  hardships  and  global  energy  market  disruption  caused  by 
Russia’s  invasion of Ukraine. It aims  to diversify the EU’s energy supplies, save  energy and further 
promote renewable energy and energy efficiency whilst reducing  emissions, see COM/2022/230 final 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2022%3A230%3AFIN&qid=1653033742483). 

15     Decision of the Conference of the Parties serving as the meeting of the Parties to the Paris Agreement -

1/CMA.5 

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The  COVID-19  pandemic  led  to  the  creation  of  a  ground-breaking  European 
economic  recovery  instrument  which  also  offered  an  opportunity  to accelerate  the 
EU’s green transition. The Recovery and Resilience Facility (RRF), which is at the heart 
of  the  NextGenerationEU  (NGEU)  instrument  and  accounts  for  up  to  EUR 800 billion, 
requires Member States to allocate at least 37% of their national recovery and resilience 
plan (RRP) funding to measures contributing to climate objectives.16 The RRF Regulation 
was amended in 2022 to enable Member States to add REPowerEU chapters to their RRPs 
and access additional funding to help end dependence on Russian fossil fuels before 2030. 
REPowerEU and emergency legislative initiatives mitigated the effects of the energy crisis 
for households and businesses in a coordinated manner. 

This  boost  in  funding  combined  with  raised  ambitions  has  accelerated  the 
implementation of the energy and climate policies and measures that Member States 
had presented in their original NECPs adopted in 2020. Relevant actions supported by 
the RRF must now be reflected in the final updated NECPs that were due by 30 June 2024. 
The reverse is also true: existing NECPs played an important role in identifying areas for 
reform as well as funding for investment under the RRF. 

The return of war to the EU’s borders and the ensuing biggest energy crisis since the 
1970s were an acute test of the EU’s resilience. These events shone a spotlight on the 
importance of energy security, the need for diversified access to energy supplies and the 
necessity to promote renewable energy and energy efficiency.  They also underscored the 
role of energy security in the broader context of  economic resilience, heightened global 
competition and the need to ensure competitive access to raw materials and components to 
achieve climate neutrality by 2050.  

The  Regulation’s  governance  mechanism  has  proven  to  be  an  agile  framework  to 
respond to these events. It has, for instance, enabled Member States to reflect the changing 
policy  and  geopolitical  circumstances  when  updating  their  NECPs  for  the  period  2021-
2030.  In  the  assessment  of  draft  updated  NECPs17  the  Commission  concluded  that, 
compared to the original NECPs, the draft updated plans substantially increased the level 
of ambition of energy and climate goals for 2030.  

However, in light of the updated regulatory framework the assessment also revealed 
an ambition gap in the actions planned to reduce greenhouse gas emissions and boost 
renewable  energy  and  energy  efficiency.  To  close  this  gap  –  and  tackle  other 
shortcomings  in  the  draft  plans  –  the  Commission  issued  recommendations  to  each 
Member State18 that were to be taken into account when finalising the updated NECPs. 
The Regulation thus continues to steer energy and climate planning at a crucial juncture. 

16   NGEU and the EU’s multiannual financial framework 2021-2027 together must spend at least 30% of 

their combined allocation on climate action (about EUR 600 billion). 

17    2023  Commission  EU-wide  assessment  of  the  2023  draft  updated  NECPs  (COM/2023/796  final), 

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2023%3A796%3AFIN. 

18    See: National energy and climate plans (europa.eu). 

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3. IMPACT OF THE GOVERNANCE REGULATION 

Effectiveness: delivering results on the ground. 

The Regulation has improved strategic planning, needed to achieve the EU’s energy 
and climate 2030 targets and to pave the way to achieve climate neutrality by 2050. It 
merged multiple national sectoral action plans into one single, coherent NECP covering 
key sectors of the economy and guided by clear medium-term targets. In doing so, it has 
contributed to improving planning both within Member States - requiring ministries to step 
up  cross-sectoral  policy  coordination  -  and  between  them  by  increasing  cross-border 
regional cooperation, including on infrastructure projects. 

Nonetheless,  there  are  still  considerable  differences  in  the  scope  and  quality  of 
Member  States’  plans  and  strategies.  There  is  also  uneven  political  buy-in  across 
Member States to the Regulation’s NECP cycle. This is partly related to the continued use 
of  different  national  planning  frameworks,  sometimes  resulting  in  parallel  planning 
procedures. Some stakeholders have argued that there is a misalignment in the sequencing 
for submitting LTSs and NECPs and have noted that the requirements to update LTSs after 
their adoption are less prescriptive than for NECPs.  

Better planning and a more coherent policy framework have helped create a more 
predictable  environment  for  investors,  but  issues  remain.  At  the  same  time,  the 
Commission’s  assessments  of  the  draft  (2019),  final  (2020)  and  draft  updated  NECPs 
(2023) all note the need for the NECPs to provide more detailed information and analysis 
on  investment  needs  and  funding  sources.  Likewise,  to  date  many  NECPs  lack  robust 
estimates  of  macro-economic  impacts  of  planned  policies  and  measures.  Moreover, 
considering certain long-term investment cycles (e.g. in industry) the 10-year timeframe 
of  NECPs  may  be  too  short;  this  underscores  the  importance  of  LTSs  taking  a  30-year 
perspective.  Investors  may  also  require  more  granular  information  (e.g.  at  regional  and 
local levels).  

The  Regulation  has  contributed  to  the  introduction  of  new  climate  and  energy 
policies. Since the adoption of the first NECPs in 2020, Member States have reported a 
significant number of new policies and measures. For instance, in the 2023 national energy 
and climate progress reports (NECPRs) 29% of all measures were new. This shows that 
Member  States  have  taken  continuous  action  to  achieve  the  2030  climate  and  energy 
objectives. While several policies and measures have been introduced in direct response to 
the Regulation, many others are more indirectly linked to it, reflecting the Regulation’s 
‘framework  nature’  which  integrates  obligations  from  other  pieces  of  EU  energy  and 
climate legislation (Figure 1). At the same time, and as noted above, the Commission’s 
December  2023  EU-wide  assessment  of  the  draft  updated  NECPs  found  that  the 
implementation of energy and climate policies needs to be stepped up to achieve the (now 
more  ambitious)  2030  targets.  The  NECPs  also  need  to  pay  more  attention  to  climate 
adaptation. 

5 

 
 
Figure  1.  Share  of  policies  and  measures  reported  by  Member  States  in  their  NECPR 
linked to EU policies and legislation 

Note: New policies and measures are those put in place since the original NECPs. Source: Assessment of 
progress towards the objectives of the Energy Union and Climate Action, SWD (2023) 646 final. 

The Regulation has improved the quality of information reported by Member States 
to  some  extent.  Importantly,  it  has  contributed  to  raising  the  quality  of  the  EU’s 
greenhouse  gas  inventory  data  and  projections.  The  NECPR  process  has  contributed  to 
improving  the  completeness  of  information.  However,  there  are  still  gaps  and 
inconsistencies in the information reported in the progress reports. This also applies to the 
scope  and  quality  of  reported  information  on  climate  change  adaptation  measures 
(Article 19(1)). 

Public access to data has also improved, for instance through requirements to collect and 
report data on new issues and to publish and consolidate information on an e-platform19 
established through the Regulation. However, although this data is publicly available, it is 
sometimes presented in a complex way that is not always readily understood. 

The Regulation is an important step towards more effective public consultation and 
multi-level governance of energy and climate policy as it has specific legal requirements 
covering both  aspects  (Articles 10 and 11). Most Member States have organised public 
consultations on their draft updated NECPs and reported several initiatives to engage in 
national multi-level climate and energy dialogues with sub-national authorities and other 
stakeholders.  However,  Member  States  did  not  set  up  sufficiently  early  and  inclusive 
public consultations, as required by the Regulation, or multi-level dialogues of sufficient 

19   The e-platform is an online platform (comprised of two systems: Reportnet managed by the European 
Environmental Agency and ReportENER managed by DG ENER) to facilitate communication between 
the Commission and Member States, promote cooperation among Member States and facilitate public 
access to information. The e-platform supports all Member States reporting under this Regulation. 

6 

 
 
 
quality.  Part  of  the  reason  may  be  that  the  Regulation’s  provisions  are  not  sufficiently 
precise or prescriptive. The links to the public involvement requirements under the Aarhus 
Convention or the Strategic Environmental Assessment (SEA) Directive20 may also not be 
sufficiently  clear.  In  some  cases,  a  lack  of  national  experience,  problems  linked  to 
administrative structures and capacity and/or a lack of political support could also play a 
role. 

The  Regulation  has  had  a  mixed  effect  on  improving  the  timeliness  of  reported 
information,  with  Member  States  frequently  submitting  the  required  plans  and 
information after the legal deadline.21 Delays appear to be partly caused by the need for 
more time to adjust to the process or by deadlines that are either too short or too close to 
one another (e.g. a reporting deadline in March 2023 followed by a June 2023 deadline for 
submitting  draft updated  NECPs).  Diverging national  or regional processes or  planning 
cycles, as well as changes in government, have in certain instances also resulted in delays. 
In some cases, human resource constraints may also play a role. Delays pose a risk to the 
Commission’s task of ensuring a comprehensive  and timely overview to steer  ambition 
and progress towards energy and climate objectives. Only four Member States submitted 
their final updated NECPs by 30 June 2024. In response, the Commission launched EU 
pilots to those Member States that did not submit final updated NECPs. 

The Regulation’s compliance mechanism is largely based on recommendations and 
other non-binding mechanisms. Although Member States must take recommendations 
into account, they are not binding. An external review of the Commission’s assessments 
of the final NECPs in 2020 concluded that the majority (66%, or 378) of recommendations 
to Member States were either only partially addressed (53%, or 304) or not at all (13%, or 
74)22. Some stakeholders expressed the criticism that, at best, infringement procedures are 
initiated  in  response  to  a  Member  State  breaching  procedural  obligations  (e.g.  late 
submission  of  NECPs),  not  for  a  failure  to  achieve  the  targets  set  in  sector-specific 
legislation. It should be recalled, however, that several pieces of EU energy and climate 
legislation include their own mechanisms to tackle insufficient implementation23. 

As  it  is  still  early  in  the  implementation  period,  the  Regulation’s  main  legal 
instruments to close any gaps in ambition or delivery (Articles 31 and 32) have seen 
little  use.  Some  stakeholders  questioned  the  Commission’s  capacity  to  act  if  Member 
States fall short on ambition or delivery. However, the Commission’s EU-wide assessment 
of the final NECPs during the 2019-2020 cycle did identify an ambition gap for energy 

20   Directive 2001/42/EC of the European Parliament and of the Council of 27 June 2001 on the assessment 
of  the  effects  of  certain  plans  and  programmes  on  the  environment  (https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=celex%3A32001L0042). 

21     For more details see the accompanying SWD. 
22   Support study for the evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union 

and Climate Action – final report (forthcoming) 

23   For instance, the Effort Sharing and LULUCF Regulations require the Commission to annually assess 
Member States’ progress towards the national targets set under these regulations and Member States to 
submit a corrective action plan in case of insufficient progress (even though such mechanisms may rely 
on reporting and data review processes established by the Governance Regulation). 

7 

 
 
efficiency.  To  bridge  this  gap,  the  Energy  Efficiency  Directive24  and  the  Energy 
Performance of Building Directive (EPBD)25 were revised as part of the Fit for 55 package. 
In the ongoing process to update the NECPs the Commission is closely following up on 
the risk of ambition gaps appearing. With regard to delivery, due to the time needed to 
consolidate energy and climate data, any substantial gaps will only become apparent in 
progress assessments further in the implementation period.   

The Regulation has stimulated regional cooperation between Member States to some 
extent. The Commission’s EU-wide assessments of the draft (2019), final (2020) and draft 
updated  NECPs  (2023)  generally  found  that  Member  States  had  properly  identified  the 
need for regional cooperation, with some making use of regional fora such as the high-
level  groups  set  up  by the  Commission26At  the  same  time,  the  assessments  revealed  an 
uneven use of regional consultation in preparing the NECPs and varying levels of detail 
on the measures that Member States plan to implement together with other Member States. 
One specific example of cooperation between Member States is the way in which Finland 
and Luxembourg have used the Renewable Energy Financing Mechanism (REFM) as  a 
delivery  mechanism  to  avoid  a  gap  in  Luxembourg's  share  of  renewable  energy.  The 
REFM is still at an early stage of implementation and there is untapped potential. Planned 
future tender(s) indicate that use of this mechanism could scale up. 

Efficiency: simplification and rationalisation 

By streamlining, merging, and simplifying energy and climate policy obligations, the 
Regulation  represents  an  important  step  towards  reducing  costs  and  improving 
policy  coherence.  Streamlining  took  the  form  of  integrated  plans  (NECPs),  strategies 
(LTSs)  and  progress  reports  (NECPRs),  the  merging  of  related  EU  and  international 
obligations  into  one  Regulation27  and  the  outright  deletion  of  others.  In  the  impact 
assessment  underpinning  the  Commission’s  initial  legislative  proposal,  this  policy 
streamlining  was  estimated  to  result  in  a  5%  annual  reduction  in  direct  reporting  costs 
under all pieces of EU energy legislation compared to the baseline28. 

At the same time, merging a wide range of planning and reporting obligations into 
one regulation also concentrates costs from across other pieces of legislation. Based 

24   Directive  (EU)  2023/1791  of the  European  Parliament  and of  the  Council  of  13 September  2023 on 
energy  efficiency  and  amending  Regulation  (EU)  2023/955  (recast),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=OJ%3AJOL_2023_231_R_0001. 

25   Directive (EU) 2024/1275 of the European Parliament and of the Council of 24 April 2024 on the energy 

performance of buildings (recast), Directive - EU - 2024/1275 - EN - EUR-Lex (europa.eu) 

26   The Commission has set up four high-level groups to provide strategic steering and policy guidance on 
regulatory and infrastructure development and to monitor progress on projects of common interest in 
priority regions: the North Seas Energy Cooperation (NSEC), Interconnections for South-West Europe, 
the Baltic Energy Market Interconnection Plan (BEMIP), and Central and Southeastern Europe Energy 
Connectivity (CESEC). 

27   This did not directly reduce the administrative burden of these (largely unchanged) reporting obligations 

but reduced the legislative complexity by bringing the obligations under one instrument. 

28   Commission staff working document, impact assessment accompanying the proposal for a regulation of 
the  European  Parliament  and  the  Council  on  the  Governance  of  the  Energy  Union.  See  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=SWD:2016:394:FIN. 

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on  information  collected  by  the  Commission  and  national  authorities  for  the  support 
study29,  the  one-off  costs  resulting  from  these  obligations  are  estimated  at  between 
EUR 7.8  million  and  10.5  million  for  the  27  Member  States  combined,  and  EUR 1.1 
million for the EU (Commission and European Environment Agency (EEA)). The annual 
recurring costs are estimated between EUR 13.9 million and EUR 19.5 million for the 27 
Member States combined and EUR 3.8 million for the EU. While it is not possible to give 
a quantitative estimate of the direct savings achieved by the Regulation, the streamlining 
has delivered some savings, as envisaged in the original impact assessment. 

The Regulation also produces efficiency benefits that cannot be quantified. Merging 
multiple strategic planning documents into a single NECP with a streamlined process and 
prescribed templates should, at least over time, help reduce the administrative burden. The 
integrated  approach  to  reporting  on  progress  in  the  NECPRs  also  enhances  both  the 
efficiency  and  quality  of  the  reporting  process.  These  advantages,  albeit  difficult  to 
quantify,  hold  substantial  value,  particularly  to  the  extent  that  better  data  and  more 
coherent planning improve policy making in the long run.  

By  further  streamlining  substantive  and  process  aspects  more  can  still  be  done  to 
reduce the administrative burden associated with energy and climate policy planning 
and  reporting.  Despite  the  Regulation’s  efficiency  benefits,  many  of  the  national 
authorities consulted considered that implementing the Regulation required an increase in 
financial and human resources. Besides the need for more cross-service coordination and 
data compilation, this may stem from national policy planning often not being fully aligned 
with the Regulation, thus resulting in parallel processes. However, stakeholders (especially 
national authorities) acknowledged that there is a learning curve and tended to expect that 
the administrative burden will ease over time as output expectations, tools and templates 
are fine-tuned. 

Certain factors may influence the Regulation’s perceived impacts on administrative 
costs. For instance, since the Regulation was adopted, energy and climate policies have 
increased in terms of scope, ambition, complexity, and political salience, with knock-on 
effects on planning and reporting requirements. The current NECP/R cycle reflects some 
of these policy changes, either by way of legal amendments or in the form of guidance30. 

The Regulation has  also made reporting more efficient  by  increased digitalisation, 
notably with the EU investing EUR 5 million in creating a dedicated e-platform. The 
use  of  digital  templates  and  quality  assurance  procedures  greatly  contributed  to  the 
comparability  of  reported  data  and  to  the  ease  of  data  reuse.  The  e-platform  is  also 
progressively being used to integrate obligations from outside the Regulation, generating 
substantial cost savings and synergies. The platform has significantly reduced the burden 

29   See Section 4.1.10 and Annexes II and IV to the staff working document. 
30   Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy 
and climate plans (2022/C 495/02), EUR-Lex - 52022XC1229(02) - EN - EUR-Lex (europa.eu). 

9 

 
 
on  the  Commission  to  manage  reporting  periods,  analyse  reported  data  and  make  data 
available for reuse. 

While this is a clear step forward, the platform could be made more user-friendly and 
less complex. Technical assistance and tutorials provided by the Commission and the EEA 
were  deemed  particularly  useful  by  those  national  authorities  involved  in  the  reporting 
process. However, the co-existence of two different reporting platforms (ReportNET3 and 
ReportENER) has attracted criticism from some national authorities and stakeholders.  

Stakeholders recognised that streamlining is a continuous process and recommended 
exploring  how  a  better  balance  can  be  found  between  the  volume  and  level  of  detail 
required in the planning, reporting, and monitoring obligations on the one hand, and the 
essential information needed for the EU to meet its targets on the other. 

The Commission is already taking action to tackle the administrative burden. It made 
a commitment to reduce the administrative burden of reporting obligations under EU law 
by 25% without undermining key policy objectives31. 

The Commission has conducted an AI-assisted in-depth screening of planning, reporting, 
and monitoring obligations under EU energy and climate law, also paying attention to links 
between those obligations and sustainability-related reporting obligations in other policy 
areas. In total, it screened over 700 obligations32, 41 of which fall under the Regulation 
(Figure 2). 

Figure 2. Planning, reporting, and monitoring obligations in EU energy and climate law 
and related policy areas – per legislative area and per responsible entity

Based  on  this  screening  process,  the  Commission  identified  several  key  actions  in  the 
rationalisation  plans  to  identify  new  measures  to  reduce  reporting  burdens,  including 

31   COM(2024) 163 final, The Clean Transition Dialogues - stocktaking a strong European industry for a 

sustainable Europe, edc7b551-6b25-42ab-b36c-d9af7d4654e9_en (europa.eu). 

32  A  ‘reporting  requirement’  is  a  requirement  stemming  from  EU  legislation  that  obliges  Member  States 
authorities, private organisations and/or public organisations to provide structured or unstructured data 
(qualitative or quantitative) to competent authorities at EU or national level. 

10 

 
 
 
 
repealing  reporting  obligations  on  oil  stocks33,  reviewing  the  security  of  gas  supply 
legislation34, and tertiary legislation under the gas and electricity internal market legislation 
and  the  Regulation  on  Wholesale  Energy  Market  Integrity  and  Transparency35.  This  is 
complemented by several support measures to ease compliance. The rationalisation plans 
also noted the possible revision of the Regulation as a means to further improve efficiency. 

Coherent and consistent energy and climate policies 

The  Regulation  is  an  internally  coherent,  unified  framework  bringing  together 
multiple  planning,  reporting,  and  monitoring  obligations  that  were  previously 
scattered  across  several  pieces  of  EU  legislation.  Nonetheless,  some  inconsistencies 
remain,  largely  due  to  the  complexity  of  merging  numerous  obligations  into  a  single 
framework. Areas where there is longstanding expertise in planning and reporting (such as 
greenhouse gas emissions, renewable energy, and energy efficiency) are commonly more 
developed than newer, more cross-cutting policy areas such as the energy efficiency first 
principle or energy poverty. It is expected that the Regulation and its iterative  design – 
supported by implementing regulations, Commission guidance for the NECP update cycle 
and  expert  meetings  –  will  promote  learning-by-doing.  Subsequent  plans  and  reports 
should achieve greater convergence and integration.  

The  Regulation  has  also  improved  coherence  between  EU  energy  and  climate 
legislation  and  other  related  pieces  of  EU  law,  as  well  as  with  international 
agreements.  The  Regulation  includes  common  rules  for  planning,  reporting,  and 
monitoring international agreements that, among other things, help Member States meet 
their obligations under the UNFCCC and the Paris Agreement. Nevertheless, some updates 
to the Regulation are needed to ensure full alignment with recently agreed international 
rules and processes. 

The Regulation is not yet fully coherent with new or updated EU energy and climate 
legislation.  Notably,  it  does  not  yet  fully  reflect  related  new  or  revised  reporting 
obligations resulting from the Fit-for-55 package. For instance, it has yet to integrate the 
process established under Article 4(5) of the EED recast to set the national contribution for 
energy efficiency or the related iterative gap-filling mechanism under Article 4(6). 

Coherence  between  NECPs  and  plans  under  EU  funding  programmes  also  merits 
attention. For instance, in the final updates of their NECPs Member States should provide 
more detail on synergies with their national common agricultural policy strategic plans and 
on  relevant  measures  and  reforms  in  their  national  recovery  and  resilience  plans  and 

33   Under Article 6(2) and 9(4) of Council Directive 2009/119/EC (Directive - 2009/119 - EN - EUR-Lex 
(europa.eu)) & Article 26(1)a) of Regulation (EU) 2018/1999 (Regulation - 2018/1999 - EN - EUR-Lex 
(europa.eu) 

34   Regulation  (EU)  2017/1938  of  the  European  Parliament  and  of  the  Council  of  25 October  2017 
concerning measures to safeguard the security of gas supply and repealing Regulation (EU) No 994/2010 
(Regulation - 2017/1938 - EN - EUR-Lex (europa.eu)). 

35   Regulation (EU) No 1227/2011 of the European Parliament and of the Council of 25 October 2011 on 
relevance 

transparency  Text  with  EEA 

and 

wholesale 
energy  market 
(http://data.europa.eu/eli/reg/2011/1227/oj). 

integrity 

11 

 
 
REPowerEU  chapters.  Inconsistencies  between  the  commitments  made  in  the  draft 
updated NECPs and interim regional commitments on fossil-fuel phase-outs made in the 
adopted territorial just transition plans should also be addressed.  

There  is  also  scope  to  enhance  coherence  and  synergies  with  other  policy  areas, 
including  on  environment  (e.g.  air  quality,  circular  economy,  water,  and  biodiversity), 
agriculture, transport, industry and macro-economic policy.  

Relevance and added value for an Energy and Climate Union 

The  Regulation  has  provided  EU  added  value  by  improving  consistency  and 
coordination  of  Member  States’  energy  and  climate  policies.  It  provides  EU  added 
value  by  setting  out  a  framework  and  mechanisms  to  support  more  consistent  and 
coordinated national energy and climate policies and provide clearer signals to investors, 
essential requisites to achieve the EU’s collective energy and climate objectives and targets 
for 2030 and beyond. 

By  requesting  the  publication  of  additional  data  and  reports,  the  Regulation  has 
provided information at EU or national level that would not otherwise be available. 
It has increased the predictability and transparency of Member States’ energy and 
climate policies by creating a comprehensive, integrated governance framework. This 
is  underpinned  by  standardised  planning,  reporting,  and  monitoring  processes  and 
deadlines, greater coordination, and public access to information. 

The Regulation has improved accountability to some extent by extending planning and 
reporting  obligations  to  additional  areas,  improving  public  accessibility  of  data,  and 
creating an iterative process that enables the Commission to assess the quality and ambition 
of Member States’ plans.  

Some stakeholders have criticised the Regulation for lacking clear, harmonised, and 
effective access to justice rights to challenge NECPs and LTSs in front of national courts 
if  they  fail  to  meet  participatory  requirements  or  contravene  environmental  legislation. 
They  argue  this  contributes  to  inconsistent  application  across  the  EU  and  undermines 
compliance with the Aarhus Convention, which allows for better public scrutiny of acts 
affecting the environment.  Although  the Regulation  clearly states that the consultations 
conducted on the plans should be, where applicable, in accordance with the provisions the 
SEA Directive, some stakeholders argued that further clarity is desirable to ensure access 
to justice rights in all Member States. 

More than 5 years after the Regulation’s adoption, its main objectives remain highly 
relevant and are likely to become even more so. The socio-economic, environmental, 
and geopolitical challenges of the past years, coupled with the increasing urgency to tackle 
climate change and boost our climate resilience, are reshaping policy priorities. They have 
illustrated the need to step up coordination between Member States and in the EU to meet 
increasingly  ambitious  and  challenging  climate  and  energy  objectives,  tackle  energy 
security, affordability and just transition concerns, foster research and innovation by means 

12 

 
of attracting investment and bring about a genuine Energy Union. A robust, simplified, and 
agile governance framework will continue to be a key tool to enable the EU to meet these 
objectives. 

4. CONCLUSIONS AND LESSONS LEARNED 

Since the Regulation entered into force in December 2018, it has made energy and 
climate planning and reporting more coherent, integrated, and simpler. It has proved 
its added value in a quickly evolving context including increasingly ambitious and cross-
cutting  energy  and  climate  policies  and  legislation,  the  COVID-19  pandemic  and  the 
energy crisis triggered by Russia’s war of aggression against Ukraine. The Regulation has 
played  an  important  role  in  putting  the  EU  on  track  to  meet  its  energy  and  climate 
objectives  and  targets  for  2030  and  beyond  in  a  more  efficient  way.  The  final  updated 
NECPs will be a key tool to deliver on these objectives. 

Although the overall policy framework created by the Regulation continued to deliver 
even under changing circumstances, this evaluation highlights that there are areas 
for  further  improvement.  It  provides  insights  that  will  feed  into  the  ongoing 
implementation and possible revision of the Regulation. 

The  Regulation  needs  to  help  the  EU  meet  a  set  of  widening  and  increasingly 
ambitious  energy  and  climate  objectives  beyond  achieving  its  2030  targets.  At  the 
same time as ensuring regulatory stability and maintaining our 2030 ambitions, which are 
fundamental for clean transition investments to materialise, the Regulation should provide 
a basis to shape and implement energy and climate policies in line with our ambitions for 
2040 and 2050. Its governance mechanism must help accelerate the transition to climate 
neutrality. It must also factor in competitiveness, energy security and energy resilience, 
tackle challenges across the supply chain for clean and net zero technologies, incentivise 
the  phase-out  of  fossil  fuels  and  fossil  fuel  subsidies,  tackle  energy  poverty  and  just 
transition concerns, factor in skills and jobs aspects, and put a greater emphasis on climate 
adaptation  considerations  taking  into  account  the  recent  European  Climate  Risk 
Assessment36.  This  calls  for  a  further  strengthening  of  the  EU’s  energy  and  climate 
governance  to  address  remaining  fragmentation,  gaps,  and  uncoordinated  national 
approaches. 

In line with the Commission’s commitment to reduce the administrative burden from 
reporting obligations by 25%, there are options to further simplify and rationalise 
the  Regulation,  including  through  digitalisation.  The  options  include  a  further 
streamlining of NECPs and NECPRs, continue aligning reporting to requirements under 
the Paris Agreement and its enhanced transparency framework, removing reporting on oil 
stocks37  as  well  as  expanding  and  improving  the  functionality  of  the  e-platform,  for 
instance to enable more effective data reuse. Additional options are also worth assessing, 
such as exploring the scope to improve synergies and coherence with, and the integration 

36   EEA  Report  01/2024,  European  Climate  Risk  Assessment  (European  Climate  Risk  Assessment  — 

European Environment Agency (europa.eu)). 
37    Article 26(1)c of the Governance Regulation. 

13 

 
 
of,  other  areas  of  EU  legislation  and  the  EU’s  international  obligations  to  achieve 
additional  efficiency  gains.  To  what  extent  broadening  the  Regulation’s  scope  to  cover 
policy areas beyond energy and climate would help achieve further efficiency gains merits 
careful consideration.  

Ensuring  that  future  NECPs  are  true  green  transition  investment  plans  requires 
greater  certainty  under  the  Regulation  for  public  and,  in  particular,  private 
investment at all levels. The main planning instruments under the Regulation must better 
identify  investment  needs  and  funding  sources  at  EU,  national  and  regional  level,  give 
stronger  signals  and  provide  better  data  to  investors,  and  highlight  the  economic 
opportunities and implications of the energy and climate transitions. Starting with the final 
updated plans that Member States were due to adopt by 30 June 2024, NECPs should be 
the  blueprint  to  ensure  that  the  EU  achieves  its  ambitions  and  objectives  for  2030  and 
beyond. 

Improving  compliance  would  help  meet  the  Regulation’s  objectives.  The  European 
Climate Law and sector-specific legislation have set the EU’s overall ambition, objectives, 
and targets. However, challenges remain in terms of the timely submission of plans, reports 
of  sufficient  quality,  and  effective  implementation.  How  compliance  can  be  enhanced 
concretely merits further reflection.  

There are several areas where consistency could be improved. They include the relation 
between LTSs and NECPs as well as, in  the context of the EU’s economic governance 
framework, between NECPs and  national  budgets. Also,  although the Regulation  is  the 
main  instrument  for  Member  State  reporting  on  climate  adaptation  action,  it  lacks 
indicators to track progress in this area. In addition, the Regulation may not sufficiently 
reflect  sector-specific  aspects  (e.g.  decarbonisation  needs  in  industry,  transport,  and 
buildings) to trigger the necessary action.  

Meeting  the  EU’s  mid  and  long-term  energy  and  climate  objectives  requires 
increasing  engagement  by,  and  cooperation  with  and  between,  Member  States, 
regional and local authorities, industry, the financial sector, social partners, and civil 
society. There is a need to take a genuinely collaborative approach based on consultation, 
information sharing, exchanges of good practices, technical assistance, and coordination. 
A  more  political  and  streamlined  approach  to  regional  cooperation  could  improve  joint 
work on cross-border projects, including projects to build the infrastructure needed for the 
energy  transition  to  net  zero38,  and  to  encourage  smart  specialisation  among  Member 
States. 

38   See Enrico Letta, Much More than a Market: Speed, Security, Solidarity. Available here: much-more-

than-a-market-report-by-enrico-letta.pdf (europa.eu). 

14