COMMISSION STAFF WORKING DOCUMENT EVALUATION Accompanying the document 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  SWD(2024) 200 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION     Accompanying the document 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 {COM(2024) 550 final}  
 
 
Table of contents 

1. 

INTRODUCTION .................................................................................................................. 1 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ......................... 3 

2.1  Background and intervention logic ................................................................................. 3 

2.2   Point(s) of comparison and expected outcome ................................................................. 9 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ........... 9 

3.1 

 Implementation by Member States and the Commission ............................................... 9 

3.2   Policy and other developments ...................................................................................... 12 

4. 

EVALUATION FINDINGS ................................................................................................. 18 

4.1  To what extent was the Governance Regulation successful and why? ......................... 18 

Effectiveness ........................................................................................................................... 18 

4.1.1 Contribution to better energy and climate policy planning ........................................... 18 

4.1.2 Contribution to the implementation of climate and energy policies .............................. 19 

4.1.3 Contribution to raising the quality of reported information .......................................... 25 

4.1.4 Contribution to increased public accessibility of reported information ........................ 27 

4.1.5 Timeliness of plans and reported information. .............................................................. 28 

4.1.6 Compliance mechanisms ................................................................................................ 32 

4.1.7 Impact on stimulating energy and climate spending and investment ............................. 33 

4.1.8 Ensuring regional cooperation. ..................................................................................... 34 

4.1.9 Public consultation and multi-level and multi-stakeholder dialogue ............................ 35 

Efficiency ................................................................................................................................ 38 

4.1.10 Streamlining of planning, reporting and monitoring obligations and cost savings in 
terms of policy coherence and administrative burden ............................................................ 38 

4.1.11 Contribution to efficiency gains through increased digitalisation ............................... 40 

Coherence ................................................................................................................................ 41 

4.1.12 Internal coherence ....................................................................................................... 41 

4.1.13 External coherence ....................................................................................................... 43 

4.2 EU added value: how did the EU intervention make a difference and to whom? ............. 45 

4.2.1. Coordination and consistency of Member States’ energy and climate policies ............ 45 

4.3 Is the Governance Regulation still relevant as it stands? .................................................. 48 

4.3.1 Relevance in view of legislative and policy developments at EU and international level

48 

4.3.2 Relevance in view of socio-economic, environmental, and geopolitical changes and 
risks  49 

 
 
 
 
 
5. 

CONCLUSIONS AND LESSONS LEARNED ................................................................... 52 

ANNEX I:  PROCEDURAL INFORMATION.............................................................................. 54 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ..................................... 55 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS 
TO THE EVALUATION QUESTIONS (BY CRITERION) ............................................... 58 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS AND TABLE ON SIMPLIFICATION 
AND BURDEN REDUCTION] ........................................................................................... 71 

ANNEX V. STAKEHOLDER CONSULTATION – SYNOPSIS REPORT ................................. 78 

ANNEX VI. ADDITIONAL EVIDENCE ..................................................................................... 99 

 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

BR 

BRP / BRPs 

BTR 

CAP 

CBAM 

CCS 

CfE 

COM 

COP 

CSP / CSPs 

DG / DGs 

DG CLIMA 

DG ENER 

DNSH 

EC 

EE 

EEA 

EED 

EEF 

EPBD 

EQ / EQs 

ESD 

ESR 

ESTAT 

ETS 

Better Regulation 

Building Renovation Plan(s) 

Biennial Transparency Report 

Common agricultural policy 

Carbon Border Adjustment Mechanism 

Carbon capture and storage 

Call for evidence 

European Commission 

Conference of the Parties of the United Nations Framework 
Convention on Climate Change 

Common agricultural policy strategic plan(s) 

Directorate-General(s) 

Directorate-General for Climate Action 

Directorate-General for Energy 

Do No Significant Harm 

European Commission 

Energy efficiency 

European Environment Agency 

Energy Efficiency Directive (Directive 2023/1791) 

Energy Efficiency First 

Energy Performance of Buildings Directive (Directive 
2010/31/EU) 

Evaluation Question(s) 

Effort Sharing Decision (Decision No 406/2009/EC) 

Effort Sharing Regulation (Regulation (EU) 2023/857) 

Eurostat 

Emissions Trading System 

 
 
EU  

EUR 

FTE 

GHG  

GR 

IA 

IPCC 

IT 

JTF 

European Union 

Euro 

Full-time equivalent 

Greenhouse gas 

Governance Regulation 

Impact Assessment 

Intergovernmental Panel on Climate Change 

Information technology 

Just Transition Fund 

LTRS / LTRSs 

LULUCF  

Long-term renovation strategy / strategies 

Land Use, Land Use Change and Forestry 

MCED / MCEDs 

Multi-level Climate and Energy Dialogue(s) 

MLG 

MMR 

MRV 

MS  

NA / NAs 

NCA / NCAs 

NDC 

NECP 

Multi-level governance 

Monitoring Mechanism Regulation (Regulation (EU) No 
525/2013)  

Monitoring, reporting and verification 

Member State(s) 

National Authority / Authorities 

National Competent Authority / Authorities 

Nationally determined contributions 

National energy and climate plan 

NECPR / NECPRs 

National Energy and Climate Progress Report(s) 

NEEAP / NEEAPs 

National energy efficiency action plan(s) 

NGO / NGOs 

NLTS / NLTSs 

NZIA 

PA  

PaM / PaMs 

PEC 

Non-governmental organisation(s) 

National long-term strategy / strategies 

Net-Zero Industry Act 

Paris Agreement 

Policy / policies and measure(s) 

Primary Energy Consumption 

 
 
QA 

QC 

R&I 

RED 

REFM 

RES 

RRF 

Quality assurance 

Quality control 

Research and Innovation 

Renewable Energy Directive (Directive 2023/2413) 

Renewable Energy Financing Mechanism 

Renewable Energy Sources 

Recovery and Resilience Facility 

RRP / RRPs 

Recovery and Resilience Plan(s) 

SCM 

SEA 

SDGs  

SO 

SWD 

TFEU 

Third sector 

TSO / TSOs 

UN 

UNFCCC 

WAM 

WEM 

WOM 

Standard Cost Model 

Strategic Environmental Assessment 

Sustainable Development Goals 

Specific objective 

Staff working document 

Treaty on the Functioning of the European Union 

All other stakeholders apart from industry and national 
authorities, where this includes NGOs, think tanks, individual 
experts, research institutes, civil society organisations, academia, 
etc. 

Transmission System Operator(s) 

United Nations 

United Nation Framework Convention on Climate Change 

‘With additional measures’ scenario 

‘With existing measures’ scenario 

‘Without measures’ scenario 

EU Member States 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
ES 

Austria 
Belgium 
Bulgaria 
Cyprus 
Czechia 
Germany 
Denmark 
Estonia 
Spain 

EL 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 

Greece 
Finland 
France 
Croatia 
Hungary 
Ireland 
Italy 
Lithuania 
Luxembourg 

LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

Latvia 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Sweden 
Slovenia 
Slovakia 

 
 
 
1. 

INTRODUCTION  

Purpose of the evaluation 

The  Regulation  on  the  Governance  of  the  Energy  Union  and  Climate  Action1  (‘the 
Regulation’)  creates  a  cooperative  governance  process  to  ensure  the  collective 
achievement, by Member States, of the EU’s Energy Union and climate action objectives. 
It also seeks to minimise the administrative burden and contribute to greater regulatory and 
investor certainty. In line with Article 45 of the Regulation, the Commission must report 
to the European Parliament and the Council on the operation of this Regulation within six 
months of each ‘global stocktake’ under Article 14 of the Paris Agreement2.  

The report should assess how the Regulation has functioned, how it has contributed to the 
governance of the Energy Union, to the long-term goals of the Paris Agreement, to progress 
on  the  2030  climate  and  energy  targets  and  the  EU’s  climate-neutrality  objective  and 
additional  Energy  Union  objectives.  It  should  also  assess  to  what  extent  the  planning, 
reporting, and monitoring provisions laid down in the Regulation are coherent with other 
EU law or decisions relating to the UNFCCC and the Paris Agreement. 

This Commission staff working document presents an evaluation of the Regulation in line 
with  the Commission’s policy on better regulation3, together with  the above-mentioned 
report4.  

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. 

2   The first global stock take  was concluded at COP28 in Dubai in December 2023, see:  EU at COP28 

Climate Change Conference - European Commission (europa.eu)). 

3   Better regulation - European Commission (europa.eu) 
4   COM(2024) 550 

1 

 
 
 
 
 
Scope of the evaluation 

The  evaluation  covers  the  Regulation  (including  amendments5  and  delegated  and 
implementing acts6) and its implementation in all EU Member States from its entry into 
force in December 20187 until the end of 20238. 

The Regulation  is  evaluated against  the five criteria set  out in  the Commission’s better 
regulation guidelines9:  

•  Effectiveness: looking into the extent to which actions under the Regulation have 

been implemented and whether this has resulted in achieving its objectives.  
•  Efficiency: assessing whether the obligations arising from implementation of the 

Regulation have been implemented in a cost-effective way. 

•  Coherence:  assessing  the  coherence  of  the  Regulation,  both  between  its  own 
provisions  (internal  coherence)  and  with  wider  EU  and  international  policy 
objectives and legislation (external coherence). 

•  EU  added  value:  comparing  impacts  that  are  due  to  the  Regulation  to  what 

Member States could have achieved without the Regulation.  

•  Relevance:  assessing  whether  the  objectives  and  the  regulatory  tools  of  the 
Regulation match current needs in view of the wider EU policy objectives, notably 
on  climate  neutrality,  climate  resilience,  energy  security  and  resilience,  energy 
affordability and competitiveness. 

Methodology, robustness, and limitations 

The  evaluation  is  partly  based  on  an  external  evaluation  carried  out  by  consultants10, 
complemented with internal analysis. 

The methodology for the study11 included consulting the public via a call for evidence12, 
comprehensive  desk  research,  a  mapping  of  planning,  reporting,  and  monitoring 
obligations stemming from the Regulation, online surveys of national authorities, industry 

5   The  latest  consolidated  version  is  available  at:  EUR-Lex  -  02018R1999-20231120  -  EN  -  EUR-Lex 

(europa.eu). 

6   Commission  Implementing  Regulation  (EU)  2020/1208  of  7  August  2020  on  structure,  format, 
submission processes and review of information reported by Member States, 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,  Delegated  Regulation  (EU)  2020/1044  with 
regard to values for global warming potentials and the inventory guidelines and with regard to the Union 
inventory system, and Implementing Regulation (EU) 2020/1294 of 15 September 2020 on the Union 
renewable energy financing mechanism. 

7   The evaluation also assesses the process of preparing the draft integrated national energy and climate 
plans which were due by 31 December 2018 (Article 9(1) of the Regulation) and thus started prior to 
the entry into force of the Regulation. 

8   While for the most part  the cut-off for the  evaluation is the end of 2023,  it also draws on input and 

publications from 2024 where relevant. 

9   The evaluation framework with detailed evaluation questions per criteria is included in Annex III. 
10   Support study for the evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union 

and Climate Action – final report (forthcoming) 

11   A detailed description of the methodological approach and its limitations can be found in Annex II. 
12   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  

2 

 
 
representatives  and  third-sector  organisations13,  interviews,  a  stakeholder  event  in 
Brussels14 and country case studies. 

Several  difficulties  have  complicated  the  assessment.  The  response  rate  to  the  various 
strands of consultation was lower than expected, resulting in a somewhat limited range of 
viewpoints. Consequently, the evaluation’s findings may in places lack the robustness that 
a  broader  participation  would  have  provided,  notably  in  terms  of  quantifying  costs  and 
benefits. 

Related literature and data were primarily sourced in English, but targeted searches in other 
EU languages were also made to close information gaps, particularly for the country case 
studies.  

Since the Regulation is an ‘umbrella’ piece of legislation, it was not always possible to 
establish  whether  it  had  a  clear  causal  effect  on  specific  aspects,  such  as  how  it  has 
contributed to the implementation of more ambitious climate and energy measures.  

Despite these limitations, the triangulation of data sources and extensive discussions with 
national  authorities  and  other  stakeholders  resulted  in  robust  conclusions  for  most 
evaluation questions.  

Structure of the staff working document 

This document is organised as follows:  

•  Section 2 describes the expected outcome of the Regulation;  
•  Section 3 outlines how the situation evolved over the evaluation period;  
•  Section 4 reports on the evaluation findings;  
•  Section  5  summarises  the  main  conclusions,  policy  considerations  and  open 

• 

questions;  
the  annexes  provide  complementary  information  on  procedures  (Annex  I), 
methodology  (Annex  II),  the  evaluation  matrix  (Annex  III),  costs  and  benefits 
(Annex IV), stakeholder consultation (Annex V) and additional evidence (Annex 
VI). 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1 Background and intervention logic  

Background 

The Regulation, adopted in December 201815, aimed to create a robust governance 
mechanism and coordinated action at EU level to achieve the EU’s energy and climate 

13   Third sector refers to all stakeholders other than national authorities and from industry including NGOs, 

think-tanks, individual experts, research institutes, civil society organisations, academia, etc. 

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

regulation-2024-01-11_en. 

15   It was published in the Official Journal on 21 December 2018 and entered into force three days later. 

3 

 
 
objectives. It sought to promote more integrated national energy and climate plans 
and  to  streamline,  merge  and  simplify  a  partly  overlapping  set  of  reporting  and 
monitoring requirements under EU energy and climate legislation16. The Commission 
proposed the Regulation in November 2016 as part of the ‘Clean Energy for all Europeans’ 
package, in the context of the Energy Union strategy17, the Paris Agreement and the EU’s 
climate policy.  

The Energy Union18, launched in 2015 as a key priority of the Commission, covers 
five  dimensions:  energy  security,  the  internal  energy  market,  energy  efficiency, 
decarbonisation  as  well  as  research,  innovation,  and  competitiveness.  With  ambitious 
energy and climate policies at its core, its goal is to give households and businesses secure, 
sustainable,  competitive,  and  affordable  energy  and  to  attract  investments  and  foster 
research and innovation. This requires a fundamental transformation of Europe's energy 
system, particularly by promoting energy efficiency and energy savings and by developing 
new and renewable forms of energy. The central idea behind the Energy Union is that this 
goal can only be achieved through coordinated action, combining both legislative and non-
legislative acts at EU, regional, national, and local level. 

Alongside the launch of the Energy Union, 2015 also saw the adoption by the Parties to 
the  United  Nations  Framework  Convention  on  Climate  Change  (UNFCCC)  of  the 
Paris  Agreement19,  emphasising  the need for the  EU to  deepen and accelerate  climate 
action  and  enhance  coordination  and  consistency  of  planning  and  reporting  activities. 
Aiming  to  keep  the  global  average  temperature  increase  to  well  below  2°C  above  pre-
industrial  levels  while  pursuing  efforts  to  limit  it  to  1.5°C,  the  Agreement  requires 
countries  to  prepare,  communicate  and  maintain  successive  ‘nationally  determined 
contributions’  (NDCs).  Each  successive  NDC  should  represent  a  progression  since  the 
previous NDC and reflect its highest possible ambition. The EU and its Member States 
submitted their ‘intended’ NDC to the UNFCCC already in March 2015; this was formally 
confirmed when the EU ratified the Agreement in October 2016. Since then, the EU’s NDC 
has been updated twice: first in December 2020 when it raised its overall target from 'at 
least 40%' to 'at least 55%' and second to reflect the EU’s Fit-for-55 package20, in October 
202321.  Parties  to  the  Paris  Agreement  were  also  expected  to  communicate  their  mid-
century, long-term low greenhouse gas emission development strategies by 2020, which 

16   Such  as,  on  the  climate  side,  Regulation  (EU)  No  525/2013  of  the  European  Parliament  and  of  the 
Council of 21 May 2013 on a mechanism for monitoring and reporting greenhouse gas emissions and 
for  reporting  other  information  at  national  and  Union  level  relevant  to  climate  change  (MMR 
Regulation). 

17   COM/2015/080  final  A  Framework  Strategy  for  a  Resilient  Energy  Union  with  a  Forward-Looking 

Climate Change Policy. 

18   See: Energy union (europa.eu) https://energy.ec.europa.eu/topics/energy-strategy/energy-union_en; The 
Strategy is linked to Sustainable Development Goals 7 (‘affordable and clean energy’) and 13 (‘climate 
action’). 

19   The Paris Agreement | UNFCCC 
20   Communication, Fit for 55: Delivering the EU’s 2030 Climate Target on the way to climate neutrality, 

COM 2021/550 final. 

21   See: https://unfccc.int/sites/default/files/NDC/2023-10/ES-2023-10-

17%20EU%20submission%20NDC%20update.pdf 

4 

 
 
the  EU  and  its  Member  States  did  in  March  2020.  The  Agreement  also  included  new 
reporting requirements. 

Several pieces of legislation were adopted in the context of the ‘Clean Energy for all 
Europeans’  package,  including  a  recast  of  the  Renewable  Energy  Directive22  and  an 
amendment of the Energy Efficiency Directive (Directive (EU) 2018/2002)23. Key pieces 
of  climate  legislation  were  also  adopted  in  2018  including  revisions  of  the  Emission 
Trading  System  Directive  (Directive  (EU)  2018/410),  the  Effort  Sharing  Regulation 
(Regulation  (EU)  2018/842)  as  well  as  the  Land  Use,  Land  Use  Change  and  Forestry 
Regulation (Regulation (EU) 2018/841). 

Against  this  overall  backdrop,  the  Governance  Regulation  has  aimed  to  support  the 
implementation of the Energy Union while increasing coherence between EU and national 
energy  and  climate  policies,  improving  and  streamlining  planning  and  reporting,  and 
aligning with the requirements and timelines under the UNFCCC and the Paris Agreement. 

Intervention logic 

As set out in the impact assessment (and the fitness check preceding it) that underpinned 
the  Commission’s  2016  legislative  proposal24,  the  Regulation  aimed  to  tackle  two  key 
problems: 

1.  Planning, reporting, and monitoring obligations not in line with the principles of better 

regulation 

The shortcomings identified under this heading concerned: 

• 

lack of suitability of those obligations to meet the EU’s 2030 climate and energy 
targets and Energy Union objectives; 
lack of policy coherence among scattered obligations across energy policy; 
lack of consistency between energy and climate policy fields; 

• 
• 
•  unnecessary administrative costs and inefficient framework for these obligations. 

2.  Inadequacy of the policy framework between Member States and the Commission to 

achieve the Energy Union objectives and implement the Paris Agreement 

Under this heading, two issues were highlighted:  

•  current policy framework inadequate to attain the EU's collective energy targets for 

2030, requiring a more coordinated and integrated framework; 

•  planning and reporting obligations not in line with the Paris Agreement. 

22   This introduced a new and binding EU-wide renewable energy target for 2030 of at least 32%, including 

a provision for a review to increase the EU-level target by 2023. 

23   This raised the EU-wide target for improvements in energy efficiency in 2030 to at least 32.5 % relative 
to the 2007 reference scenario and included a provision for a review to increase the target by 2023. 

24   SWD (2016) 394 final. 

5 

 
 
To  tackle  these  two  problems,  the  Regulation’s  overall  objective  was  to  'set  out  the 
necessary  legislative  foundation  for  reliable,  inclusive,  cost-efficient,  transparent  and 
predictable governance of the Energy Union and Climate Action (governance mechanism), 
which ensures the achievement of the 2030 and  long-term  objectives and targets of the 
Energy  Union  in  line  with  the  2015  Paris  Agreement  (...),  through  complementary, 
coherent  and  ambitious  efforts  by  the  Union  and  its  Member  States,  while  limiting 
administrative complexity'25. 

In  line  with  this,  the  specific  objectives  of  the  governance  mechanism  created  by  the 
Regulation were to26:  

• 

implement strategies and measures designed to meet the objectives and targets of the 
Energy  Union  and  the  EU's  long-term  greenhouse  gas  emissions  commitments 
consistent with the Paris Agreement, and, specifically for the first ten-year period from 
2021 to 2030, to meet the EU's 2030 targets for energy and climate;  

•  stimulate  cooperation  between  Member  States,  including,  where  appropriate,  at 
regional level, designed to achieve the objectives and targets of the Energy Union; 
•  ensure  the  timeliness,  transparency,  accuracy,  consistency,  comparability,  and 
completeness  of  reporting  by  the  EU  and  its  Member  States  to  the  UNFCCC 
Secretariat; 

•  contribute  to  greater  regulatory  and  investor  certainty  and  help  optimise  the 
opportunities for economic development, investment, job creation and social cohesion. 

To  achieve  these  objectives,  the  Regulation  is  structured  around  the  following  key 
planning, reporting, and monitoring ‘activities’: 

•  Member  States  are  to  draw  up  integrated  national  energy  and  climate  plans 
(NECPs - Chapter 2 of the Regulation)27 and national long-term strategies (LTSs - 
Chapter 3). Chapter 2 also requires Member States to ensure public consultation on 
NECPs and LTSs, to engage in multi-level climate and energy dialogue at national level 
and  to  ensure  regional  cooperation  among  Member  States  when  preparing  and 
implementing NECPs. These mid- and long-term planning instruments, crucial to meet 
the  EU’s  energy  and  climate  objectives  and  targets,  are  some  of  the  main  changes 
brought in by the Regulation. 

•  Member  States  are  to  report  on  their  progress  to  the  Commission  and  to  the 
UNFCCC Secretariat (Chapter 4), through biennial and annual reports. Biennial 
reporting  obligations  to  the  Commission  encompass  integrated  national  energy  and 
climate progress reports (NECPRs), integrated reports on GHG policies and measures 
and on GHG projections, as well as reports on national climate adaptation action. On 
the international side, the Regulation required Member States to submit biennial reports 

25   Recital 1 of the Regulation 
26   Article 1 of the Regulation 
27  

In the NECPs, Member States lay out how they will meet their obligations and targets under the Effort 
Sharing Regulation and the Land Use and Land Use Change Regulation and how they will contribute to 
the EU-wide renewable energy and energy efficiency targets. 

6 

 
 
under the UNFCCC/Kyoto Protocol (it does not yet provide a legal basis for submitting 
biennial transparency reports under the Paris Agreement however28). Annual reporting 
obligations concern the submission by Member States of GHG inventories, both to the 
Commission and the UNFCCC Secretariat (with the Commission submitting a GHG 
inventory  report  for  the  EU,  thus  tracking  progress  towards  implementing  the  EU's 
NDC). Member States also report annually on the use of auctioning revenues and on 
financial and technology support provided to developing countries.  

•  The Commission is to monitor progress towards meeting agreed objectives and 
targets, both at EU and Member State level (Chapter 5). This includes Commission 
assessments of and country-specific recommendations on draft NECPs; annual state of 
the  energy  union  reports  and  climate  action  progress  reports  (CAPR);  as  well  as  a 
mechanism  to  respond  if  the  NECPs  show  insufficient  ambition  and  insufficient 
progress is made on the EU's energy and climate objectives and targets.  

In addition, the Regulation requires: 

•  The  Commission  and  Member  States  to  establish  GHG  inventory  systems  and 
systems for GHG projections and policies and measures, with national inventory 
data  being  subject  to  a  comprehensive  review  by  the  Commission  and  the  EEA, 
including for the purposes of data submission to the UNFCCC Secretariat (Chapter 6). 
Inventory  systems  are  the  foundation  for  tracking  progress  both  towards  national 
targets and the EU’s NDCs under the Paris Agreement. The Regulation also specifies 
quality standards for inventories29.  

•  Member States to cooperate with each other and the EU in relation to obligations 
under the Regulation and the Paris Agreement. To foster these exchanges among the 
Member States and to support the Commission, the Regulation established the Climate 
Change Committee and the Energy Union Committee. The Regulation also states that 
the European Environment Agency (EEA) must assist the Commission in its work on 
the Regulation’s decarbonisation and energy efficiency dimensions (Chapter 7).

28   As of 2024, Parties to the Paris Agreement submit ‘biennial transparency reports’, replacing the earlier 
‘biennial reports’ under the UNFCCC. The Regulation has yet to be updated to formally incorporate the 
new reporting obligations under the Paris Agreement and the Enhanced Transparency Framework. 
29   As an example, following the revision of the LULUCF Regulation, Member States are encouraged to 
move towards higher reporting standards (tier 2 and tier 3). In this regard, the Commission is developing 
a methodology to estimate the climate change mitigation potential of planned interventions under the 
CAP strategic plan. 

7 

 
 
Figure 1: Intervention logic for the Regulation

8 

 
 
 
2.2   Point(s) of comparison and expected outcome 

As noted above and explained in more detail in the baseline description contained in Annex 
9  of  the  support  study  conducted  by  consultants30,  the  Regulation  aimed  to  merge  and 
simplify  a  partly  overlapping  set  of  planning,  reporting,  and  monitoring  requirements 
under EU energy and climate legislation in place before 2018. 

This evaluation assesses the extent to which the Regulation has achieved its general and 
specific  objectives  as  well  as  its  expected  outcomes  and  impacts  as  identified  in  the 
intervention logic (see Section 2.1 above). The evaluation describes how the Regulation 
functioned and was implemented in the period since it entered into force31. 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD?  

3.1  

Implementation by Member States and the Commission  

The table below gives an overview of the key planning, reporting, and monitoring activities 
(as  identified  in  the  intervention  logic  in  Section  2.1)  that  have  taken  place  since  the 
Regulation  entered  into  force  at  the  end  of  2018.  The  upper  part  (in  blue)  summarises 
legislative  activities  with  a  direct  effect  on  the  Regulation,  the  lower  part  (in  orange) 
summarises planning activities, the green part reporting and the yellow part monitoring.  

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

and Climate Action – final report (forthcoming) 

31   While for the most part the cut-off for the evaluation is the end of 2023, it also draws on input and 

publications from 2024 where relevant. 

9 

 
 
 
Table 1.. Key elements of the Governance Regulation 

Blue: legislation, orange: planning, green: reporting, yellow: monitoring. 

Note: for legibility, all annual obligations are presented on 1 fixed date, while in reality they have different submission dates. 

10 

 
 
 
The table shows that: 

• 

In terms of legislation, six targeted amendments were made to the Regulation (see also 
Section 3.2). In addition, one delegated and two implementing acts primarily related to 
reporting  were  adopted,  and  one  implementing  act  was  adopted  in  relation  to  the 
establishment and functioning of the renewable energy financing mechanism (REFM). 

•  On planning, an EU long-term strategy on climate action was adopted in 2018 and an 
EU methane strategy in 2020. Member States communicated drafts of their first NECPs 
at the end of 2018/in early 2019. Following an assessment by the Commission32 they 
submitted final plans for the period 2021-2030 by the end of that year33. The five-yearly 
process of updating NECPs stipulated by the Regulation was launched in mid-2023 
and is expected to conclude by mid-2024. By March 2024, all Member States, except 
Poland, have submitted their national LTSs.  

•  On  reporting,  since  2021  Member  States  have  fulfilled  several  biennial  and  annual 
reporting  obligations  under  the  Regulation  and  the  UNFCCC/Kyoto  Protocol,  for 
instance  reporting  on  national  policies  and  measures,  GHG  projections  and  climate 
change adaptation planning and strategies. Since 2023, this is complemented by (and 
for some parts streamlined in) integrated national energy and climate progress reports 
(NECPRs). 

•  On monitoring, the Commission assessed the first draft and final NECPs for the period 
2021-2030 in 2019 and 2020 and draft updated NECPs submitted by Member States 
in  202334.  It  published  a  first  assessment  of  national  LTSs  in  October  202135  (and 
updates in subsequent editions of the annual climate action progress reports). It also 
prepared a yearly comprehensive assessment package as part of the State of the Energy 
Union36. 

• 

In  terms  of  GHG  inventory  systems,  the  EU  and  Member  States  have  put  in  place 
robust  institutional  arrangements  and  processes  for  estimating  GHG  emissions  by 
sources and removal by sinks, including procedures to assess uncertainties and ensure 
quality assurance and quality control. This is key to ensure proper reporting of GHG 
inventories to the EU/EEA and the UNFCCC Secretariat. 

32   Commission  Communication  assessing  the  28  draft  NECPs  (COM/2019/285),  together with  specific   

recommendations and a detailed staff working document for each Member State. 

33   All  submitted  plans  can  be  found  here:  National  energy  and  climate  plans  (europa.eu) 

(https://commission.europa.eu/energy-climate-change-environment/implementation-eu-
countries/energy-and-climate-governance-and-reporting/national-energy-and-climate-plans_en). 
34   In the first half of 2024, it assessed the draft updates of five remaining Member States whose submissions 

were significantly late. 
35   SWD (2021) 298 final. 
36   All  State  of 

the  Energy  Union  reports  can  be  found  here:  Energy  union  (europa.eu) 

https://energy.ec.europa.eu/topics/energy-strategy/energy-union_en. 

11 

 
 
 
•  Similarly,  the  EU  and  Member  States  are  operating  the  Union  and  national  system 
respectively, for reporting on policies and measures and on projections of emissions 
and removals to the EU and the UNFCCC Secretariat. As of 2024 the submission of 
GHG  inventories  to  the  UNFCCC  will  be  governed  by  the  enhanced  transparency 
framework37 replacing the measurement, reporting and verification (MRV) system. 

•  Finally,  in  terms  of  cooperation,  it  is  worth  highlighting  that  for  the  first  round  of 
NECPs  (in  2019)  the  Commission  provided  extensive  guidance  to  Member  States, 
alongside  the  opportunity  to  exchange  best  practices  through  a  technical  working 
group. Similarly, to prepare the NECP update process (in 2023) and Member States’ 
reporting  obligations,  particularly  in  relation  to  the  first  round  of  NECPRs  (also  in 
2023), the Commission again made substantial guidance available38. The Commission 
also  supported  exchanges  through  various  working  groups  set  up  under  the  Energy 
Union  and  Climate  Change  Committees,  both  in  the  form  of  bilateral  technical 
discussions with Member States and regional fora such as high-level groups39. 

3.2   Policy and other developments 

As summarised in  the  figure below,  the European  and international  energy and climate 
policy  landscape  has  undergone  a  significant  transformation  since  the  Regulation  was 
adopted in 2018. This was both as a result of major EU policy developments during the 
current  Commission  (2019-2024),  including  the  European  Green  Deal,  the  European 
Climate  Law  and  the  ‘Fit-for-55’  package,  and  unprecedented  crises  caused  by  the 
COVID-19  pandemic  and  the  Russian  weaponization  of  energy  supply  related  to  the 
unprovoked and unjustified Russian aggression against Ukraine. 

37   This  was  adopted  at  COP  24  in  2018  and  finalised  at  COP26  in  2021.  The  enhanced  transparency 
framework  is  an  accountability  mechanism  aimed  at  ensuring  transparent  reporting  on  the 
implementation of Nationally Determined Contributions (NDCs) and the flow of support for climate 
action. 

38   Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy 

and climate plans (2022/C 495/02). 

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

12 

 
 
 
 
EU policy developments and major crises since the Regulation’s adoption    

Policy developments 

The  Governance  Regulation  was  adopted  as  part  of  the  EU’s  2018  legislative 
framework  to  meet  the  EU’s  (then)  climate  and  energy  targets  for  2030.  Prior  to 
subsequent  more  ambitious  revisions,  these  targets  included  a  40%  reduction  in  GHG 
emissions from 1990 levels, a 32% share for renewable energy in final energy consumption 
and a 32.5% improvement in energy efficiency.  

One year later, in December 2019, the European Green Deal laid the foundation for 
the  European  Climate  Law  (adopted  in  2021)  that  enshrined  into  EU  law  the  more 
ambitious climate objectives for 2030 (reducing net GHG emissions by at least 55% by 
2030 compared to 1990 levels) and 2050 (climate neutrality). This was followed by the 
adoption  of  the  Fit-for-55  package  (202340)  that  consisted  of  a  set  of  inter-connected 
legislation that operationalise the 2030 target with a balance between pricing mechanisms 
(notably strengthening and extension of the EU ETS and the new CBAM), targets (ESR, 
LULUCF, RED and EE), rules, and funding (Social Climate Fund and increased funding 
under  the  Modernisation  Fund  and  Innovation  Fund).  The  Green  Deal  also  contained 
commitments  to  boost  the  EU's  adaptive  capacity  and  resilience  and  aimed  to  further 
promote policy coherence, notably between energy, climate, and environmental policies 
(biodiversity,  pollution,  circular  economy,  water),  including  through  the  'do  no  harm' 
principle. 

40   At the time of writing this report, an agreement has not yet been found on the revision of the Energy 
Taxation Directive, see https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12227-
EU-Green-Deal-Revision-of-the-Energy-Taxation-Directive_en. 

13 

 
 
 
 
The  continued  importance  of  addressing  socio-economic  impacts  of  the  green 
transition led to the creation of the Just Transition Fund41 and the Social Climate Fund42. 

Action was also taken on climate resilience, notably in the form of the 2021 EU climate 
adaptation strategy43 under the Climate Law, and the Commission’s 2024 Communication 
on Managing Climate Risks44. This Communication emphasises, among other points, that 
climate risk planning needs strengthening in the energy sector too.  

In February 2024, Council and Parliament reached an agreement on an EU carbon 
removal  certification  framework  to  scale  up  carbon  removal  activities  and  fight 
greenwashing.  In 
issued  a  Communication 
recommending  that  by  2040,  the  EU’s  net  GHG  emissions  should  be  reduced  by  90% 
relative to 1990 levels45.  

the  same  month, 

the  Commission 

The EU has also adopted key energy strategies, notably on energy system integration46, 
hydrogen47,  offshore48,  solar  energy49,  wind50,  digitalisation  of  the  energy  system51 and 
grids52.  

Other related policy developments that have taken place at EU level  over the past 
years include the Net-Zero Industry Act, the Hydrogen Bank, the European Critical Raw 
Materials Act as well as a series of environmental initiatives (e.g., the zero pollution action 
plan, the circular economy action plan, the biodiversity strategy and the forest strategy) 
and the sustainable and smart mobility strategy. 

As  a  result  of  legislative  developments  after  2018,  the  Governance  Regulation  has 
been subject to several targeted amendments (see also Section 3.1 above). In 2021, in 
line with the European Climate Law, it was updated to reflect the EU’s climate-neutrality 
objective.  It  also  mandates  the  Commission  to  include  in  the  implementing  acts  the 
structure, format, technical details, and process for NECPRs, as well as a methodology to 
report on the phasing out of energy subsidies, particularly for fossil fuels. The Regulation 
was also aligned to the Fit-for-55 amendments to the Effort Sharing Regulation53, the Land 

41   Regulation (EU) 2021/1056. 
42   Regulation (EU) 2023/955. 
43   COM/2021/82 final. 
44   COM/2024/91 final. 
45   COM/2024/63 final. 
46   Powering a climate-neutral economy: an EU Strategy for Energy System Integration, COM (2020) 2999 

final. 

47   A hydrogen Strategy for a climate-neutral Europe, COM (2020) 301 final. 
48   An EU strategy to harness the potential of offshore renewable energy for a climate-neutral future, COM 

(2020) 741 final. 

49   An EU Solar Energy Strategy, COM (2022) 221 final. 
50   European Wind Power Action Plan, COM(2023) 669 final 
51   Digitalising the energy system – EU Action plan, COM (2022) 552 final. 
52   Grids, the missing link - An EU Action Plan for Grids, COM/2023/757 final. 
53   Regulation (EU) 2023/857. 

14 

 
 
Use, Land Use Change and Forestry Regulation54, to the Renewable Energy Directive55 
and to the recast Energy Efficiency Directive56.  

Although raising the ambition in energy and climate mitigation policies does not directly 
require changes to the planning, reporting, and monitoring processes under the Governance 
Regulation, it does imply that Member States need to revise their NECPs to meet the EU’s 
more ambitious objectives and targets. On climate change adaptation policy, actions are 
needed to improve the governance of climate risks across policy sectors.  

Major policy developments at international level include decisions and commitments 
under the Paris Agreement, for instance on the enhanced transparency framework, rules 
related  to  market  mechanisms  and  non-market  approaches57  and  climate  finance  for 
developing countries58. At COP28, Parties undertook the first Global Stocktake59 under the 
Paris Agreement and committed to transition away from fossil fuels in energy systems60, 
to triple global renewable energy capacity and to double the global average annual rate of 
energy  efficiency  improvements  by  203061.  Also,  at  COP28,  Parties  recognised  that 
limiting global warming to 1.5 °C requires reducing global GHG emissions by 43% by 
2030  and  60%  by  2035  compared  to  2019  levels  and  reaching  net-zero  carbon  dioxide 
emissions  by  2050.  They  also  agreed  on  a  'Global  Goal  on  Adaptation'  covering  broad 
global adaptation goals and key areas for action. 

The COVID-19 pandemic and the war in Ukraine 

The  COVID-19  pandemic  that  broke  out  in  2020  led  the  EU  to  a  establish  the 
Recovery and Resilience Facility (RRF), the €800 billion reform and investment tool 
at  the  heart  of  NextGenerationEU.  It  aimed  to  support  Member  States’  economic 
recovery and use it as a crucial opportunity to build back better, including by supporting 
the green transition. Member States must dedicate at least 37% of the total allocation under 
their national recovery and resilience plan to measures contributing to climate objectives. 
Article 4 of the Regulation establishing the Recovery and Resilience Facility (Regulation 

54   Regulation (EU) 2023/839. 
55   Directive EU/2023/2413. 
56   Directive EU/2023/1791. 
57   Also,  the  decision under  Article  6 of the Paris Agreement implies that each participating Party  must 
have, or have access to, a registry for the purpose of tracking and must ensure that such registry records, 
including through unique identifiers, as applicable: authorization, first transfer, transfer, acquisition and 
shall  have  accounts  as  necessary  (such  provisions  existed  in  the  MMR  for  the  Kyoto  registry  and 
activities). 

58   This includes financial support for climate mitigation and adaptation as well as for 'loss and damage'. 
59   The global stocktake confirmed the urgent need to redouble efforts to achieve the three key objectives 
of the Paris Agreement: climate mitigation, climate adaptation and the corresponding alignment of all 
financial flows. 

60   Parties agreed to 'transition away from fossil fuels in energy systems, in a just, orderly and equitable 
manner, accelerating action in this critical decade, so as to achieve net zero by 2050 in keeping with the 
science'. They also agreed to phase out inefficient fossil fuel subsidies. 

61   The Global Renewables and Energy Pledge sets global targets to triple the global installed capacity of 
renewable  energy  and  double  the  global  rate  of  energy  efficiency  improvements  by  2030  -  COP28: 
Global Renewables And Energy Efficiency Pledge. 

15 

 
 
(EU) 2021/241) stipulates that the Facility is designed to contribute to the achievement of 
the  EU’s  2030  climate  targets  and  its  objective  to  achieve  climate  neutrality  by  2050. 
Article 17  provides that  Member States’  RRPs  must be consistent with  the information 
included in the NECPs drawn up under the Governance Regulation.  

Accordingly, NECPs played an important guiding role in identifying the areas where 
measures and additional funding for investments is needed. The reverse is also true: 
the financial boost to Member States’ energy and climate measures had a significant impact 
on their GHG and energy trajectories, investment assumptions and planned policies and 
measures  compared  to  what  was  outlined  in  the  2019  NECPs.  The  new  RRF-funded 
support  measures  must  be  reported  as  part  of  the  biennial  reporting  of  policies  and 
measures under the Governance Regulation and be reflected in the updated NECPs to be 
submitted by the end of June 2024.  

Russia’s war of aggression against Ukraine launched in 2022 led to disruptions in the 
supply of Russian gas and contributed to a significant rise in energy prices across the 
EU. In response, the Commission proposed to end the EU’s reliance on Russian fossil fuels 
well before 2030 and launched the REPowerEU plan, a set of actions to diversify the EU’s 
energy supplies, save energy, and further promote renewable energy and energy efficiency.  

The RRF Regulation62, adopted in 2021, was amended in 2022 to address the objectives of 
REPowerEU.  Member  States  could  revise  their  recovery  and  resilience  plans  to  add 
REPowerEU  chapters  and  access  additional  funding  to  achieve  the  REPowerEU 
objectives.  The  Commission’s  guidance  to  Member  States  on  updating  their  NECPs 
included  recommendations  on  how  REPowerEU  measures  should  be  reflected  in  these 
plans63. Progress  on achieving  the objectives of the REPowerEU Plan  will be reported, 
among  others, in the  Commission’s  State  of  the  Energy  Union  reports  and  its  climate 
action progress reports. 

In launching the REPowerEU plan, the Commission also proposed to raise the ambition of 
the  new  renewable  energy  target  under  the  Renewable  Energy  Directive  and  the  new 
energy  efficiency  target  under  the  Energy  Efficiency  Directive,  eventually  resulting  in 
binding  collective  EU  targets  of  42.5%  for  renewable  energy  (with  the  collective 
endeavour to reach 45%) and 11.7%64 for energy efficiency65.  

The energy crisis triggered by the war against Ukraine impacted the objectives of the 
Governance Regulation in several ways, including:  

•  how energy data is monitored and reported by Member States and shared at EU 
level (e.g., need-to-know changes in gas storage and consumption with the shortest 
time lag possible);  

62   Regulation - 2021/241 - EN - rrf - EUR-Lex (europa.eu) 
63   Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy 

and climate plans (2022/C 495/02). 

64   Compared to the projections of the EU's 2020 reference scenario 
65   So that the EU’s final energy consumption amounts to no more than 763 Mtoe. 

16 

 
 
• 

• 

the need for stronger  coordination and cooperation among  Member States about 
gas supply (e.g., demand aggregation);  

the adoption of action plans to save gas in the short-term that may complement or 
interfere with the longer-term planning under the Regulation. 

•  new  provisions  to  accelerate  permitting  for  renewable  energy  in  renewable 

acceleration areas, emphasising the importance of good strategic planning; 

• 

the realisation that planning and building new types and capacity of infrastructure 
in the energy sector require better planning from the perspective of climate risks. 

Energy prices (which peaked in August 2022) led to a significant increase in the cost of 
living  for  citizens  and  reduced  the  global  competitiveness  of  EU  industry.  Coordinated 
action  by  the  EU  and  Member  States,  including  the  REPowerEU  plan  and  emergency 
legislative initiatives first adopted in 2022, mitigated the effects of the energy crisis for 
households  and  industry  in  a  coordinated  manner,  avoiding  fragmentation  of  the  single 
energy market. However, energy prices remain higher than they were before the energy 
crisis.  The  temporary  spike  in  energy  prices  highlighted  the  need  for  an  effective  and 
coordinated crisis response, to diversify supply across the energy sector, to promote energy 
savings  and  to  fast-forward  the  green  transition.  It  emphasised  the  relevance  of  the 
Regulation  as  the  cornerstone  for  coordinated  energy  and  climate  action  at  EU  level 
through the NECP and LTS process. 

17 

 
 
 
4.  EVALUATION FINDINGS  

Introduction 

This  chapter  assesses  the  impact  of  the  Governance  Regulation  against  the  criteria  of 
effectiveness, efficiency, coherence, EU added value and relevance. The assessment will 
be guided by 17 specific evaluation questions (see Annex III for the evaluation matrix and 
answers to the evaluation questions), which in turn are presented under three headings: 

1.  To what extent was the Regulation successful and why? (effectiveness, efficiency and 

coherence) 

2.  How did the EU intervention make a difference? (EU added value) 

3.  Is the Regulation still relevant as it stands? (relevance) 

Given we are still at a relatively early stage of the Regulation’s lifecycle, this assessment 
can only be partial. 

4.1 To what extent was the Governance Regulation successful and why? 

The  success  of  legislation  is  measured  largely  by  assessing  if  and  how  it  meets  its 
objectives. Accordingly, this section seeks to identify: 

• 

• 

the factors driving or impeding the Regulation’s progress in achieving its objectives 
(effectiveness);  

the extent to which the Regulation’s objectives are met in the most cost-effective 
way and with the least possible burden (efficiency); and 

•  whether  the  Regulation  is  internally  coherent  and  functions  well  in  conjunction 
with  other  related  EU  legislation  and  international  obligations  (internal  and 
external coherence). 

Effectiveness 

4.1.1 Contribution to better energy and climate policy planning 

The Regulation strengthened integrated energy and climate policy planning and has 
created  synergies  by  taking  an  innovative  approach.  It  brings  together  previously 
scattered  planning  (and  reporting)  obligations  across  energy,  climate,  and  other  Energy 
Union-related policy areas under one coherent Regulation and requires Member States to 
develop integrated NECPs and LTSs. There was a degree of agreement among national 
authorities that the Regulation has indeed helped integrate different but related planning 
obligations  and  has  improved  the  quality  and  accuracy  of  planning  at  national  level. 
Stakeholders generally recognise the benefit of replacing different sectoral national action 
plans with a single, coherent NECP that provides clear medium-term targets.  

18 

 
The  Regulation  has  also  improved  planning  by  increasing  cooperation  within 
Member  States.  Consulted  national  authorities  noted  that  integrated  planning  and 
reporting  improved  cooperation  and  coordination  between  and  within  different  national 
ministries  and  governmental  agencies.  However,  there  is  scope  to  further  improve  this 
cooperation and coordination, bearing in mind that increased coordination might require 
additional resources.  

At the same time, there are significant differences in the impact that NECPs have had 
on national planning processes (and vice versa). Some Member States already had well-
established  national  planning  mechanisms  for  climate  and  energy  policies  before  the 
Regulation was adopted. This may also have contributed to limited political buy-in into 
the  Regulation’s  planning  processes  in  some  countries.  In  such  cases,  some  national 
authorities argued that the Regulation has served more as a reporting than as a planning 
tool, with limited effectiveness in improving planning. They note, however, that even in 
those cases, merging multiple obligations into one framework still improved the planning 
processes. 

Despite the set template for NECPs  (Annex I to the Regulation) and LTSs (Annex 
IV), there are large differences in Member States’ plans and strategies. The scope, 
content, detail, quality and/or length vary greatly, including with respect to aspects such as 
the just transition, climate adaptation, the role of land use and removals, and measures to 
tackle  agricultural  emissions.  On  the  LTSs  specifically,  18  Member  States  expressed  a 
clear objective to achieve climate (or carbon) neutrality by 2050 or before; others aim to 
be largely climate neutral or to achieve reductions of 80-95% by that date66. 

While  the  flexibility  of  the  NECP  template  made  it  difficult  to  aggregate  certain 
indicators at EU level, some national authorities do not consider the template to be 
flexible enough to reflect a country’s specific national situation. On the LTSs, Article 
15(4) and the short ‘general framework’ in Annex IV provide relatively limited guidance 
on their expected content, leaving considerable discretion to Member States. Stakeholders 
also  highlighted  that  national  LTSs  are  not  always  effective  in  improving  energy  and 
climate planning (see Section 4.1.12). 

4.1.2 Contribution to the implementation of climate and energy policies 

There  are  indications  that  the  Regulation  has  had  a  positive  impact  on  the 
implementation of climate and energy policy policies. 24 out of 29 national authorities 
that responded to a survey indicated that the Regulation played a role in Member States 
adopting  and  implementing  policies  and  measures  (PaMs)  to  meet  national  energy  and 
climate contributions to a very large (5), large (8) or some (11) extent. 

66   Note that the deadline for submission of the national LTS (1 January 2020) was before the adoption of 

the Climate Law, which established the Union-wide climate neutrality objective. 

19 

 
 
 
 
Figure 3 Number of policies and measures (PaMs) reported per year. 

3205

2052

1849

1382

1513

3500

3000

2500

2000

1500

1000

500

2015

2017

2019

2021

2023

Source: ICF elaboration based on EEA reports 

Although it is difficult to measure the Regulation’s direct impact on implementation, 
many new PaMs were reported after it was adopted. There has been a steady increase 
over time in the number of PaMs reported as part of each reporting cycle (see Figure 3). 
The marked increase in reported PaMs since 2021 can be explained by the extension of 
reporting  beyond  GHG-related  PaMs  to  PaMs  covering  all  five  dimensions  in  the 
Regulation, by further implementing the NECPs and, more generally, by additional action 
taken by Member States to meet their 2030 climate and energy targets.  

As reported in the Commission’s 2023 progress assessment of the first NECPRs67 and as 
illustrated  in  Figure  4  below,  there  was  a  large  increase  in  new  PaMs  following  the 
adoption of the 2019-2020 NECPs (879 new PaMs, around 29% of the total). This indicates 
that many Member States put in place and will continue to implement new policies and 
measures to meet their 2030 climate and energy objectives and targets. Of these new PaMs, 
286 (33%) are planned, 219 (25%) are adopted and 359 (41%) are implemented.  

67   SWD (2023) 646 final. 

20 

 
 
 
Figure 4 Number of policies and measures reported by EU Member States per start year. 

Most  reported  national  PaMs  are  implemented  in  response  to  one  or  more  EU 
policies, with the most mentioned measures shown in Figure 5 below. Member States also 
report PaMs in response to EU policies that were adopted in subsequent years such as the 
RRF Regulation  (32 PaMs)  or  the  European Climate Law (19 PaMs). As  shown in  the 
figure, while several are reported to be implemented in direct response to the Regulation, 
many others are more indirectly linked to it, reflecting the Regulation’s ‘framework nature’ 
which integrates planning, reporting, and monitoring obligations from across EU energy 
and climate legislation, including the EED, RED, EPBD, ESR and the LULUCF.  

Figure  5.  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. 

21 

                                                                                                                                                                                                                                                   
 
 
Overall, Member States have made progress towards meeting the climate mitigation 
objectives, although there is a risk of an implementation gap. Member State abatement 
projections (WAM68) have improved over time69, but the draft updated NECPs that (most) 
Member States submitted in 2023 still fell short by about 4 pp70. of the EU’s 2030 target 
to reduce net emissions by at least 55% compared to 1990 levels. The trajectory identified 
in the draft updated NECPs71 fell short of reaching climate neutrality by 205072. Based on 
Member State GHG projections for 2023, the 2023 CAPR73 estimates a need for additional 
emission  reductions  of  around  1  600  million  tonnes  of  CO2  equivalent  (or  34  pp.)  to 
achieve climate neutrality by 2050.  

Member States have increased  their emission reductions under the  Effort Sharing 
Regulation  (ESR),  but  further  efforts  are  needed  by  2030.  Projected  emission 
reductions,  including  additional  measures,  for  sectors  covered  by  the  ESR  improved 
between the 2019 draft NECPs and 2020 final NECPs, from about 28%74 in 2019’s draft 
plans to 32% in the 2020 final plans. The projected reductions improved further to 33.8% 
in the 2023 draft updated NECPs. Although this is positive, the projected impact still falls 
short of the EU’s -40% 2030 ESR target75.  

Despite recent progress, the EU is currently not on track to meet its 2030 LULUCF 
target. LULUCF (WAM) projections from the draft updated NECPs indicate that Member 
States will need to remove an additional 40 to 50 net Mt CO2 eq. to reach the EU’s 2030 
target of -310 Mt CO₂ equivalent76. The Commission assessment therefore concluded that 
the draft NECPs lacked sufficient ambition or action in the sector, with only a few Member 
States demonstrating clear pathways to meet their national 2030 removal targets. 

On  the  contribution  the  Regulation  made  to  implementation  of  climate  change 
adaptation policies, progress is limited. The scope of information reported by Member 
States is limited, which impedes domestic adaptation planning, including through NECPs. 
These limitations notwithstanding, the coverage of adaptation policies and measures did 
somewhat  increase  in  the  draft  updated  NECPs  compared  to  the  2019/2020  plans.  The 

68   With additional measures. 
69   The  assessment  of  the  2019-2020  final  NECPs  shows  that  for  the  economy-wide  greenhouse  gas 
emissions reductions, including those covered by the EU ETS, emissions decrease by 41% v. 1990 levels 
under  the  WAM  scenario,  exceeding  the  EU’s  previous  40%  reduction  target.  This  represented  an 
improvement of about 1.5 pp compared to the draft NECPs. 

70   Net total GHG emissions, including LULUCF and excluding international transport. 
71   resource.html (europa.eu) 
72   This  assessment  might  evolve  following  the  submission  of  final  updated  NECPs  to  be  submitted  by 

Member States by 30 June 2024. 

73   Climate Action Progress Report 2023 - European Commission (europa.eu) 
74   Compared to 2005. 
75   Under the fit-for-55 package, the EU increased its ESR 2030 target from -29% to -40% with the 2023 
ESR  revision.  Read  more  here:  Effort  sharing  2021-2030:  targets  and  flexibilities  -  European 
Commission (europa.eu). 

76   The revised LULUCF regulation has a separate land-based net carbon removals target of 310 million 
tonnes of CO2 equivalent by 2030. When available, WAM projections provided in the draft updated 
NECPs  were  used.  If  WAM  projections  were  missing,  WEM  projections  were  used  instead. 
resource.html (europa.eu) 

22 

 
 
recently published first European Climate Risk Assessment77 offers a basis to strengthen 
and further develop this dimension of the plans.  

Member  States  have  also  made  progress  on  energy  efficiency  and  renewables’ 
objectives, particularly over the last few years. Some of the EU’s 2020 energy targets78 
were binding for each Member State, notably the renewable energy target of 20%79. With 
the  transition  to  more  ambitious  collective,  EU-wide  energy  efficiency  and  renewables 
targets for 2030, the Regulation became the primary framework to ensure effective  and 
coordinated  implementation.  Although  it  is  difficult  to  measure  the  impact  of  the 
Regulation,  Figure  6  and  Figure  7  below  show  that  there  has  been  some  progress  in 
implementing the 2030 targets, particularly over the last few years.  

Figure 6. Progress on implementing EU-wide 2030 energy efficiency targets, 2013-2022 

Source: Eurostat 

77   See: https://www.eea.europa.eu/publications/european-climate-risk-assessment 
78   COM (2010) 639 final. 
79   Directive 2009/28/EC, Art. 3. 

23 

 
 
 
Figure 7 Progress on implementing 2030 EU-wide renewable energy targets, 2013-2022 

Source: Eurostat 

However, implementation of energy objectives will need to be stepped up  by 2030. 
The 2023 EU-wide assessment of the draft updated NECPs80 found that, based on current 
national ambitions, the share of renewable energy in final energy consumption could reach 
between 38.6% and 39.3% in 2030 at EU level. While this is significantly higher than the 
previous target of 32% set in REDII, it is lower than the revised binding target of 42.5%. 
Similarly, the assessment found that only a handful of Member States propose a sufficient 
level of ambition on either primary energy consumption, final energy consumption or both 
to achieve the revised 2030 target. 

Some factors may have affected the Regulation’s contribution to implementation of 
energy  and  climate  policies.  The  lack  of  strong  compliance  mechanisms  (see  Section 
4.1.6) was identified as a factor hindering implementation of the NECPs, as are the varying 
levels of detail and lack of comprehensive and consistent overviews of public and private 
investment needs in the plans (see Section 4.1.7). The current NECP cycle (and level of 
ambition in the 2023 draft updated plans) was affected by the short time between finalising 
interinstitutional negotiations  on the Fit-for-55 package and the  deadline for  submitting 
draft updated NECPs.   

80   COM (2023) 796 final. This assessment might evolve following the submission of final updated NECPs 

to be submitted by Member States by 30 June 2024. 

24 

 
 
 
 
 
4.1.3 Contribution to raising the quality of reported information   

The Regulation has improved the quality of reported information to some extent. At 
the  same  time,  gaps  and  inconsistencies  in  the  information  reported  in  plans  and 
reports remain. Member States report information via the e-platform. The Commission, 
supported by the EEA and its European Topic Centres, carries out quality assurance and 
quality control procedures81 for several reporting obligations. These tools and procedures 
help standardise and raise the quality of the reported information over time. 

The quality of data on PaMs (Article 18, since 2023 streamlined in the NECPR PaMs 
reporting) has increased over the reporting period, but not since the entry into force 
of the Regulation. The completeness of data reported in the e-platform dataflow increased 
between  2017  and  2019.82  However  in  202183  and  202384,  although  there  was  a  large 
increase in reported PaMs (see Section 4.1.2.) the completeness did not improve.  

The issues with completeness notably concern data on emission reductions (achieved 
and expected), renewable energy production (achieved and expected), energy reductions 
(achieved and expected), and on the costs and benefits and financing of PaMs. With respect 
to  emission  reductions  specifically,  there  is  not  yet  a  clear  match  between  projections, 
WEM  and  WAM,  and  ex-ante  emission  savings  from  the  PaMs  reporting.  On  progress 
towards  financing  specifically,  some  Member  States  did  not  report  information  on 
financing  the  PaMs  (Article  17),  and  others  often  reported  incomplete  or  inconsistent 
information.  

Compared to 2021, the quality of PAMs deteriorated in 202385. This could partly be 
expected  as  the  2023  PaM  reporting  cycle  brought  in  several  new  requirements,  for 
instance  it  extended  reporting  to  all  dimensions  of  the  Energy  Union  in  an  integrated 
matter86. As PaMs reporting has evolved over the last decades, it has been observed that 
stable, predictable reporting requirements foster substantive improvements in data quality, 
whereas  shifts  in  reporting  requirements  lead  to  temporarily  reduced  quality.  This 
evaluation only takes account of one single reporting cycle for the new PaMs reporting 
requirements  and,  as  such,  does  not  capture  the  longer-term  trend  in  data  quality 

81   Following the UNFCCC’s TACCC principles: Transparency, Accuracy, Completeness, Comparability, 

and Consistency. 

82   Dauwe, T., Mandl, N., Young, K., and Jozwicka, M. 2019. “Overview of reported national policies and 
measures 
ETC/CME. 
https://www.eionet.europa.eu/etcs/etc-cme/products/etc-cme-reports/etc-cme-report-5-2019-overview-
of-reported-national-policies-and-measures-on-climate-change-mitigation-in-europe-in-2019 (accessed 
on 12 February 2024). 

change  mitigation 

climate 

Europe 

2019. 

on 

in 

in 

83   Dauwe, T. 2021. “Overview of reported national greenhouse gas policies and measures in Europe in 
https://www.eionet.europa.eu/etcs/etc-cme/products/etc-cme-reports/etc-cme-

2021”.  ETC/CME. 
report-5-2021-overview-of-reported-national-greenhouse-gas-policies-and-measures-in-europe-in-
2021 (accessed on 12 February 2024). 

84   Dauwe, T., Vella, A., Sammut, J., Gu, Y., Gleeson, L., Young, K., Perl, D. (2023). Overview of reported 
integrated national climate and energy policies and measures in Europe in 2023. EEA. ETC CM report 
2023/06: Overview of reported integrated national climate and energy policies and measures in Europe 
in 2023 — Eionet Portal (europa.eu) 

85   ETC  CM  report  2023/06:  Overview  of  reported  integrated  national  climate  and  energy  policies  and 

measures in Europe in 2023 — Eionet Portal (europa.eu) 
86   Previously only GHG emissions and removals were covered. 

25 

 
 
improvements  that  can  be  expected  with  subsequent  rounds  of  reporting.  Data  quality 
issues complicate a comprehensive analysis of the impacts of existing policies across the 
EU. 

By contrast, the quality of GHG projections reporting has increased (Article 18) over 
time, building on the work on data quality improvements starting already under the 
MMR. All Member States now provide complete information on their mandatory WEM 
scenarios, with a comprehensive split by sector and GHG. The number of Member States 
reporting on 2050 projections87 increased from 7 (2021) to 26 out of 27 (2023). There has 
also been a small increase in reporting on indicators (from 18 in 2021 to 21 in 2023) and 
sensitivity scenarios (21 in 2023 v 19 in 2021). Since the entry into force of the Regulation, 
Member  States  are  required  to  submit  LULUCF  projections,  and  full  compliance  was 
achieved in both 2021 and 2023. However, between 2021 and 2023, completeness on the 
voluntary ‘With Additional Measures’ (WAM) scenario decreased slightly (18 in 2023 v 
22 in 2021), and on the fact sheets on the models used (26 in 2023 and 27 in 2021) and 
number of parameters reported (156 unique parameters in 2023 and 389 in 2021) 88.  

In terms of the quality of reported information on climate change adaptation actions 
(Article  19  (1)),  the  results  are  mixed.  The  Regulation  streamlined  and  reduced 
fragmentation  of  reporting  on  adaptation  measures.  However,  the  Commission’s 
assessment  of  Member  States'  adaptation  policies  would  have  benefited  from  more 
extensive  and  better  information  on  domestic  adaptation  action.  The  coverage  and 
granularity of reported information on the financial support provided to developing 
countries (Article 19.3) has improved over the years.  

The  Regulation  has  increased  the  quality  of  GHG  inventory  data  by  establishing 
clearer roles and responsibilities for the Commission (with a key supporting role of 
the EEA) and Member States in the quality assurance and quality control (QA/QC) 
process.  The  EU  and  its  Member  States  are  parties  to  the  Paris  agreement  and  the 
UNFCCC. Therefore, when drawing up their inventory, they must first comply with the 
common rule book of the UNFCCC and IPCC guidelines. The initial checks and its QA/QC 
are  mandatory  provisions  from  the  UNFCCC89,  which  are  transposed  in  domestic 
legislation.  

The Regulation puts in place internal institutional arrangements for the EU and Member 
States  to  prepare  the  timely,  efficient,  and  coherent  submission  of  the  EU’s  inventory, 
which is the sum of Member States inventories, to the UNFCCC Secretariat. In addition, 
the Regulation provides a structured framework for the Commission to assess, report on, 
and follow up on the findings of inventory QA/QC, including by issuing recommendations 
for improvements (Article 38). It requires Member States to participate in the process. As 

87   This was only mandatory to report in 2023, and not in 2021. 
88   Martin Ortega, J., Akkermans, S., Lopez, P., Chornet, J., Szanto, C., Kampel E., Pinterits, M. “Analysis 
of  Member  States’  2023  GHG  projections”  ETC-CM.  https://www.eionet.europa.eu/etcs/etc-
cm/products/etc-cm-report-2023-08 (accessed on 12 April). 

89   Modalities, procedures, and guidelines (MPGs), Annex to decision 18/CMA.1. 

26 

 
 
a result, data reported through Article 26 (Annual Reporting) is less prone to errors than 
under the MMR.  

The NECPR process (Article 17) has increased the completeness of information. A lot 
of new information was digitally reported in NECPRs on progress towards the objectives 
in all five dimensions of the Energy Union (notably on Member States national ‘economy-
wide’ greenhouse gas emission reduction targets (18 Member States reported at least one 
national target for either 2030, 2040 or 2050) and climate-neutrality targets (16 Member 
States)) and  policies and measures to  achieve those objectives. Using an  e-platform  for 
reporting based on templates specified in an implementing regulation, and with additional 
reporting guidelines for Member States, improved the completeness and comparability of 
the data reported. 

4.1.4 Contribution to increased public accessibility of reported information 

Stakeholders  generally  agree  that  the  Regulation  has  resulted  in  more  publicly 
accessible climate and energy information. A large majority (44 out of 65) of surveyed 
stakeholders  found  that  the  Regulation  helped  improve  public  data  accessibility,  but 
opinions varied by stakeholder group. 23 out of 30 surveyed national authorities found that 
the Regulation has made the data in their national plans and reports more accessible to the 
public at least to some extent, while just over half of the surveyed industry representatives 
and third-sector stakeholders shared this view. 

Stakeholders pointed out that better public access to information resulted from the 
requirements  for  Member  States  to  collect  and  report  data  in  new  areas  and  to 
publish and consolidate that data in one place. A major added value from the Regulation 
is also that it provided access to more information from other Member States, with almost 
all surveyed national authorities agreeing. During the interviews, stakeholders noted that 
the State of the Energy Union report is particularly beneficial and that NECPs from other 
countries can be useful to learn about best practices. They also noted, however, that it can 
be  difficult  to  make  comparisons  between  countries  as  they  draw  up  their  NECPs  in 
different ways. 

Public access to energy and climate information is governed by specific requirements 
in  the  Regulation.  Articles  3(4),  17(7),  18(4)  and  19(4),  for  instance,  require  Member 
States to publish NECPs, NECPRs, national GHG projections, and reported information 
on national adaptation actions, financial and technology support for developing countries 
and auctioning revenues. Article 28(3) requires the Commission to facilitate public online 
access to the reports covered by Chapter 4 of the Regulation, the final integrated NECPs 
and their updates as well as the LTSs, and to publish these reports on the e-platform90.  

90   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, to promote cooperation among Member States and to facilitate 
public access to information. The e-platform supports all Member State reporting under this Regulation. 

27 

 
 
In practice, most plans and information prepared by Member States are indeed publicly 
available, albeit sometimes with delays (e.g., in 2023 many NECPs and NECPRs arrived 
late).  The  NECPRs  were  sometimes  published  without  certain  specific  elements  due  to 
restrictions  by  individual  Member  States  (see  Table  2  in  Annex  VI  for  more  details). 
Stakeholders  underlined  that  delays  in  providing  information  affects  its  usefulness  and 
their ability to contribute to policy making (see Section 4.1.5 below). 

While publicly available, certain aspects of reported energy and climate information 
are  not  always  sufficiently  understandable  to  the  wider  public.  For  instance, 
stakeholders reported that data can be difficult to understand for non-experts as they are 
compiled of numerous Excel tables without much context. Some stakeholders also noted 
that some plans and reports lacked detail, limiting the transparency and predictability of 
Member States’ policies.  

Some stakeholders suggested that the e-platform could be enhanced, for instance to 
give better control over the data submitted by improving the means to access, reuse and 
forward the data, or providing better visual tools so that authorities can present information 
on the NECPs in an accessible way (see also Section 4.1.11). The European Commission 
and the EEA already provide a range of tools such as EEA climate and energy platform91, 
Datahub92 and Climate-ADAPT93 through which the public can access some of the data 
reported  under  the  Governance  Regulation,  including  in  the  form  of  assessment, 
visualisations, and databases. The use of and information on the availability of these tools 
should be improved. 

Extending and upgrading the e-platform has been identified as a key action within the 
Commission-wide  initiative  to  streamline  reporting  obligations.  Substantial  work  is 
ongoing to integrate more reporting obligations (e.g., from integrated progress reporting by 
Energy  Community  parties,  obligations  stemming  from  the  revised  energy  efficiency 
directive  and  methane  legislation)  in  the  e-platform  and  to  increase  its  functionality  to 
further improve data reuse and user-friendliness (see Section 4.1.11). 

4.1.5 Timeliness of plans and reported information. 

Most Member States submit required plans and strategies too late. Only 8 out of 27 
draft updated NECPs were notified by the deadline of 30 June 2023. At the time of writing 
this report, Austria has still not yet submitted a draft updated NECP. In 2024, 4 Member 
States submitted their final updated NECP by the deadline of 30 June. Only 9 Member 
States submitted their LTS on time, with Poland not yet having submitted its LTS, over 
four years after the deadline. Table 1 in Annex VI summarises the main information on the 
timeliness of the Regulation’s key plans and reports. 

Member States also frequently miss deadlines for reporting obligations (see Table 2). 
Only 8 Member States submitted their NECPRs (Article 17) on time, and only 11 their 

91   For example, see https://climate-energy.eea.europa.eu. 
92   https://www.eea.europa.eu/en/datahub, which provides access to more detailed datasets. 
93   Climate-ADAPT (europa.eu) 

28 

 
 
integrated reporting on greenhouse gas policies and measures and on projections (Article 
18).  By  contrast,  Member  States  are  increasingly  meeting  their  deadlines  for  GHG 
inventory data (Article 26) and Adaptation (Article 19). Some Member States noted that 
certain  deadlines  were  too  close  to  each  other,  such  as  when  in  2023  the  draft  updated 
NECPs were due only 3.5 months after the NECPRs. This led to delays as both processes 
(reporting and planning) required the same national administrative resources. 

29 

 
 
 
Table 2. Timeliness of submissions (all reporting obligations under the Governance 
Regulation)94 

Number of Member States meeting/missing the deadline 

2017 

2019 

2021 

2023 

13 (48%) 
14 (52%) 

9 (32%) 
19 (68%) 

23 (85%) 
4 (15%) 

GHG inventory (15 January*) 
Deadline met 
Deadline missed 
Policies and measures (PaMs) (15 March) 
Deadline met 
Deadline missed 
GHG projections (15 March) 
Deadline met 
Deadline missed 
Approximate GHG inventory (31 July) 
Deadline met 
Deadline missed 
NECPR (15 March) 
Deadline met 
Deadline missed 
Adaptation (Article 19) (15 March) 
Deadline met 
Deadline missed 
Use of EU ETS auctioning revenues (31 July) 
20 (74%) 
Deadline met 
Deadline missed 
7 (26%) 
Support to developing countries (30 September) 
Deadline met 
Deadline missed 

26 (96%) 
1 (4%) 

16 (59%) 
11 (41%) 

n/a 
n/a 

n/a 
n/a 

24 (89%) 
3 (11%) 

26 (96%) 
1 (4%) 

27 (100%) 
0 (0%) 

9 (32%) 
19 (68%) 

15 (56%) 
12 (44%) 

11 (41%) 
16 (59%) 

16 (59%) 
11 (41%) 

12 (44%) 
15 (56%) 

15 (56%) 
12 (44%) 

27 (100%) 
0 (0%) 

20 (74%) 
7 (26%) 

24 (89%) 
3 (11%) 

n/a 
n/a 

n/a 
n/a 

8 (30%) 
19 (70%) 

16 (59%) 
11 (41%) 

17 (65%) 
9 (34%) 

22 (81%) 
5 (19%) 

23 (85%) 
4 (15%) 

18 (67%) 
9 (33%) 

20 (74%) 
7 (26%) 

24 (89%) 
3 (11%) 

16 (59%) 
11 (41%) 

16 (59%) 
11 (41%) 

Source: EEA 

*  Note:  the  preliminary  deadline  for  the  reporting  under  the  GHG  inventory  is  15  January,  annually. 
However,  the  final  deadline  is  15  March,  annually.  This  table  takes  into  account  only  the  preliminary 
deadline. 

Late submission of reports was already recognised as an issue in the fitness check and 
impact assessment underpinning the proposal for the Regulation. It is not possible to 
make a comprehensive comparison of how the Regulation has affected the timeliness of 
reported information as the reports to be submitted have changed and deadlines were not 
consistently  tracked  for  all  obligations  before  the  Regulation  entered  into  force.  The 
available evidence does however suggest that the timeliness of reported information and 

94   The  deadline  is  provided  next  to  each  reporting  obligation  in  brackets.  Reporting  in  2017  and  2019 
reflect reporting under the MMR and from 2021 reflect  reporting under the Governance Regulation. 
Timeliness for GHG inventories is taken from the EU’s inventory annual reports and does not factor in 
earlier  submission  for  preliminary  deadlines  (only  final  data  used  for  the  report).  The  NECPR  was 
reported  the  first  time  in  2023.  Under  the  MMR  adaptation,  reporting  was  only  every  four  years, 
therefore 2017 was not a mandatory reporting cycle. NECPR timeliness is based on the last submission 
made by a country for all relevant reporting elements. 

30 

 
  
 
plans remains an issue. The only exception is the GHG inventory, which rarely has late 
submissions for its preliminary deadline of 15 January and in the period of 2017 - 2023 
had no late submissions for its final deadline of 15 March. This is likely linked to the long 
consistency  of  the  reporting  templates  and  systems,  and  the  clearly  defined  period  of 
quality assurance built into the legislation (preliminary and final deadline). 

In most cases, delays did not prevent the Commission from performing its assessment 
or  from  monitoring  progress,  but  they  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. Several reporting deadlines were only missed by 
a few days or weeks, with some related to quality assurance. However, in certain cases, 
delays  were  substantially  longer  (such  as  for  NECPs,  NECPRs,  PaMs,  and  GHG 
projections). As regards the submission of LTSs, the national 2020 energy efficiency target 
reports  and  the  2023  draft  NECP  updates  specifically,  the  scope  of  Commission 
assessments had to be adjusted to account for late or missing submissions.  

At international level, 11 Member States did not deliver their Fifth Biennial Report 
(BR) on time. One Member State has still not delivered the report to this date. These delays 
have had negative consequences on the drafting of the UNFCCC synthesis reports95 as they 
led to  incomplete data integration, potentially  skewing global understanding  and policy 
responses to climate change.  

Stakeholders have different opinions on whether the Regulation has helped Member 
States  meet  their  planning  and  reporting  obligations  in  a  timelier  manner.  Most 
Member States are of the view that the Regulation has helped them, at least to some extent, 
to complete their planning and reporting on time. Some argue that their national or regional 
processes and planning cycles make it difficult to meet the Regulation’s deadlines. Others 
noted the short deadlines between some of the Regulation’s deliverables. Only a few of the 
consulted  third-sector  and  industry  stakeholders  found  that  the  Regulation  has  had  a 
substantial  impact  on  improved  timeliness.  Across  all  stakeholder  groups,  the  most 
common  response  was  that  the  Regulation  has  helped  Member  States  complete  their 
obligations and provide information on time ‘only to a small extent’ (18 out of 64 total 
responses); few found however that the Regulation had not improved timeliness at all96.  

95   Compilation and synthesis of fifth biennial reports of Parties included in Annex I to the Convention. 

Report by the secretariat. Addendum | UNFCCC 

96   The question asked to third-sector stakeholders focused on these organisations being able to access data 
on time (when they would need this information), whereas public authorities and industry stakeholders 
were just asked about their Member States meeting reporting and planning obligations on time. 

31 

 
 
 
 
4.1.6 Compliance mechanisms 

One significant limitation of the Regulation’s mechanisms to ensure compliance is its 
reliance on recommendations. While  Member States  must take them into account, 
they are not legally binding. Particularly third sector stakeholders recalled that Member 
States failed to address  a substantial  part of  the  recommendations  that  the Commission 
made on the 2019 draft NECPs in their final NECPs: an external review97 concluded that 
the majority (66% or 378) of recommendations were either only partially addressed (53% 
or  304)  or  not  at  all  (13%  or  74).  These  stakeholders  also  argued  that  infringement 
procedures  are  at  best  initiated  in  response  to  Member  States’  non-compliance  with 
procedural obligations (e.g., late submission of LTSs and NECPs98), but not for a failure 
to address Commission recommendations or, should such cases occur, to achieve targets 
set in sectoral legislation. 

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 
efficiency.  To  bridge  this  gap,  the  Energy  Efficiency  Directive99  and  the  Energy 
Performance  of  Building  Directive  (EPBD)100  were  revised  as  part  of  the  Fit  for  55 
package.  Should  the  Commission’s  assessment  of  final  updated  NECPs  confirm  a  new 
ambition gap at EU level and, in particular, in the context of renewable energy or energy 
efficiency, the ‘gap-filling’ mechanism would again require the Commission to propose 
measures  and  exercise its powers at  EU level.  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.   

Due to its nature as an ‘umbrella’ policy framework to achieve key EU energy and 
climate  objectives,  the  Regulation’s  contribution  to  implementation  should  be 
assessed in conjunction with related EU legislation and funding. Several pieces of EU 
insufficient 
energy  and  climate 
implementation of climate and energy measures. For instance, the EU ETS is based on a 
‘cap and trade’ model; the cap is reduced annually in line with the EU’s climate target, 

include  mechanisms 

to  respond 

legislation 

to 

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

and Climate Action – final report (forthcoming) 

98   In September 2022, the Commission launched an infringement procedure against four Member States 
for failure to notify a long-term strategy. Three infringement procedures were since closed following the 
submission of long-term strategies for those Member States. In December 2023, the Commission opened 
an infringement procedure against three Member States for failing to submit a draft updated NECP by 
30 June 2023. Two infringement procedures were since closed following the submission of the draft 
updated NECPs for those Member States. 

99   Directive  (EU)  2023/1791  of  the  European  Parliament  and  of  the  Council  of  13 September  2023  on  energy 
https://eur-lex.europa.eu/legal-

amending  Regulation 

2023/955 

(recast), 

efficiency 
content/EN/TXT/?uri=OJ%3AJOL_2023_231_R_0001. 

(EU) 

and 

100   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) 

32 

 
 
ensuring  that  over  time,  emissions  fall.  The  Effort  Sharing  (ESR)  and  LULUCF 
Regulations require Member States to submit a corrective action plan in case of insufficient 
progress towards meeting the national targets set under these regulations.  

Access to funding under the European Regional Development Fund and the Cohesion 
Fund is conditional upon on submission of an NECP101. However, there is no condition 
tied to the non-submission of an updated NECP or to the submission of LTS or NECPRs. 

4.1.7 Impact on stimulating energy and climate spending and investment 

There  is  limited  and  mixed  evidence  of  the  Regulation’s  impact  on  stimulating 
targeted  spending  and  investments.  Public  authorities  tended  to  have  more  positive 
views on the impact of the Regulation on stimulating investment than representatives from 
industry and the third sector. Most stakeholders, including from industry, were unable to 
link targeted spending and investment to the Regulation, though  in interviews some did 
acknowledge  the  Regulation’s  role  in  creating  a  more  predictable  environment  for 
investors. 

Stakeholder feedback suggests that several factors may have limited the Regulation’s 
potential to create a more predictable investment environment and provide a basis 
for more informed policy analysis. 

One obstacle stems from information gaps on investment needs and funding sources 
in NECPs and NECPRs. The Commission’s EU-wide assessments of draft (2019), final 
(2020)  and  draft  updated  NECPs  (2023)  all  note  the  need  for  NECPs  to  provide  more 
detailed information and analysis on short- and long-term investment needs and funding 
sources. NECPRs (2023) also lacked sufficient information on these aspects102. Major data 
gaps  were  on  the  actual  investments  made,  investment  needs,  and  financing  sources 
(national or European, public or private). Different investment assumptions also make it 
difficult to make a comparison of Member State submissions. This lack of systematically 
reported  data  on  investment  needs  and  financing  sources  reduces  predictability  for 
investors and stands in the way of informed policy analysis. Several stakeholders suggested 
that these data deficiencies stem from a lack of capacity in Member States to effectively 
map this type of information. 

Another  identified  obstacle  is  the  lack  of  information  with  a  truly  long-term 
perspective. Some stakeholders deemed the timeframe of the current NECP cycle (2021-
2030) to be too short, with some noting that LTSs may be more relevant as they cover at 
least 30 years. 

Lastly, NECPs provide information for policy experts that is not necessarily suited to 
the needs of investors. Industry stakeholders stressed the importance of public authorities 

101   OJ L 231, 30.6.2021, p. 159–706. 
102   Paci  D.,  Tsemekidi-Tzeiranaki,  S.,  Clementi,  E.  L.  (2023),  Assessment  of  the  2023  NECP  Reports: 
Monitoring  Member  States’  progress  in  their  energy  and  climate  plans  –  Summary  Report,  JRC 
Technical Report, Publications Office of the European Union, Luxembourg, 2023 (under publication) 

33 

 
 
fully  understanding  what  investors  need  in  terms  of  the  type  and  granularity  of  data 
contained in NECPs (e.g., regional and local level data).  

4.1.8 Ensuring regional cooperation. 

The Regulation has stimulated regional cooperation between Member States to some 
extent. The Commission’s EU-wide assessments of draft (2019), final (2020) and  draft 
updated NECPs (2023)103 generally found that Member States properly described the need 
for regional cooperation, with some making use of existing regional fora, such as the high-
level groups set up by the Commission104. The Commission’s 2023 assessment of progress 
towards the objectives of the Energy Union and  Climate Action105 concluded that most 
Member States reported on progress made on regional cooperation. Most reported projects 
that relate to more than one dimension of the Energy Union, with the majority focusing on 
energy  security,  the  internal  energy  market  and  decarbonisation.  The  Member  States 
around  the  North  Sea  included  a  joint  chapter  in  their  NECPs  reflecting  their  regional 
cooperation in the North Seas Energy Cooperation high-level group. 

Although there were examples of Member State cooperation on several dimensions 
of the Energy Union, there is scope to tap this potential further. The NECP assessments 
mentioned  above  highlighted  an  uneven  use  of  regional  consultation  fora  in  preparing 
NECPs and varying levels of detail on the measures that Member States have or plan to 
implement together with other Member States. An external review of the Commission’s 
assessments of final NECPs in 2020 concluded that while 29 (out of 51) recommendations 
related  to  regional  cooperation  had  either  been  fully  (17)  or  largely  (12)  addressed  by 
Member States; 22 were only partially (18) or not at all (4) addressed106.  

Few of the stakeholders interviewed expressed an opinion on regional cooperation. Those 
who did tended to agree that the Regulation has had a positive impact on this front. Some 
identified challenges such as short timelines to consult  other Member States on NECPs 
and limited comparability of or access to data from other countries (see also Section 4.1.4). 

Cross-border  collaboration  in  the  form  of  joint  investment  projects  has  improved 
with  the  introduction  of  the  Renewable  Energy  Financing  Mechanism  (REFM) 
created under Article 33 of the Regulation. The REFM organised a first successful tender 
in  2023,  allowing  282  MW  of  new  solar  PV  projects  in  Finland  to  be  eligible  for 

103  2019  Commission  EU-wide  assessment  of  2019  draft  NECPs  https://eur-lex.europa.eu/legal-

content/EN/TXT/?qid=1565713062913&uri=CELEX:52019DC0285  
2020  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  
2023 Commission EU-wide assessment of the 2023 draft updated NECPs https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2023%3A796%3AFIN. 

104   The  Commission  set  up  four  high-level  groups  to  provide  strategic  steering  and  policy  guidance  on 
regulatory and infrastructure development and to monitor progress of 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). 
105   SWD (2023) 646 final. 
106   Support study for the evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union 

and Climate Action – final report (forthcoming) 

34 

 
 
EUR 40 million  in  investment  support  financed  by  Luxembourg.  A  second  tender  is 
planned for Q3 2024 which will be open to more renewable energy generation technologies 
in several host countries, increasing the scale of the mechanism.  

The  REFM  remains  mostly  dependent  on  voluntary  contributions  from  Member  States, 
however. Luxembourg is the only contributor to date although the legal basis provides for 
other sources of funding (EU funds or private contributions). The Financial Regulation107 
now allows countries to commit a financial contribution to the mechanism over a multi-
year  period  instead  of  the  previous  year-by-year  approach,  which  provides  greater 
budgetary flexibility for contributors. Potential host countries may also be dissuaded by 
the need to transfer 80% of the national renewable energy statistics from projects in their 
country to another country. A potential way to strengthen the mechanism is to use it as 
‘top-up  mechanism’  as  an  incentive  for  Member  States  to  meet  the  aspirational  RES 
target108. 

4.1.9 Public consultation and multi-level and multi-stakeholder dialogue  

The Regulation aims to promote more effective public consultation and multi-level 
governance  of  energy  and  climate  policy  with  legal  requirements  covering  both 
aspects (Articles 10 and 11). In practice, however, implementation of these provisions 
varied  widely.  Several  Member  States  failed  to  set  up  public  consultation  processes  or 
multi-level stakeholder dialogues of sufficient quality or in a timely fashion. While such 
implementation challenges appear to be at least partially linked to issues at national level 
(e.g., lack of national experience, problems linked to administrative structures), it has also 
been argued that the Regulation’s provisions are not sufficiently precise or prescriptive to 
ensure timely and productive consultations of stakeholders and sub-national bodies.  

Article 10 of the Regulation requires Member States to ensure that the public is given 
early and effective opportunities to participate in the preparation of draft NECPs and 
LTSs. This provision is aligned with Article 7 of the Aarhus Convention109 to which both 
the EU and its Member States are parties. It represents a significant improvement compared 
to  the  situation  before  the  Regulation,  when  the  requirement  did  not  exist  or  was  very 
limited (for instance in relation to the preparation of national renewable action plans that 
were replaced by NECPs).  

Nonetheless,  while  most  Member  States  organised  consultations  on  draft  updated 
NECPs, few met all requirements on early and inclusive public participation in line 
with Article 10. Many of the draft updated NECPs that Member States submitted in 2023 
lacked  details  on  the  communication  channels  used  to  reach  the  public  and  reasonable 
timeframes to enable the public to express their views110. Also, under the Fit-for-Future 

107   Art.  22(2)(a)  of  Regulation  2018/1046  on  the  financial  rules  applicable  to  the  general  budget  of  the 

Union (recast). 

108   Article 19ac of the revised Electricity Market Directive invites the European Commission to assess if 

EU-wide auctions could be organised under the REFM for this purpose. 

109   United  Nations  Economic  Commission  for  Europe  (UNECE)  Convention  on  Access  to  Information, 

Public Participation in Decision-making and Access to Justice in Environmental Matters. 

110   COM (2023) 796 final. 

35 

 
 
Platform111, practitioners and experts were not given the possibility to make a meaningful 
contribution to the design of LTSs. Many of the draft NECPs lacked information on the 
public’s views or on how they were taken into account. Similarly, respondents to the call 
for  evidence  for  this  evaluation  complained  about  weak  levels  of  compliance  with  the 
public  participation  requirements  in  terms  of  reasonable  timeframes  to  reply  to 
consultations, limited choice of options and availability of information underpinning the 
draft NECPs.  

Some stakeholders argued that the Article 10 public consultation requirements are 
not  precise  enough.  In  2021,  the  Aarhus  Convention  Compliance  Committee  (ACCC) 
took a critical position on the Regulation’s public consultation provisions on NECPs112. In 
response, the Commission prepared an action plan with concrete measures to implement 
the ACCC's recommendations, such as providing assistance to Member States or assessing 
progress  on public participation in  preparing  the NECPs 113. The Commission  guidance 
published in 2022 to prepare the NECP update cycle also included recommendations on 
public participation114. 

Article 11 of the Regulation requires Member States to set up a multi-level climate 
and energy dialogue aimed at actively engaging local authorities, stakeholders, and the 
general public in discussions on energy and climate policies. Member States must report 
biennially on progress in engaging in such dialogues in their NECPRs.  

Article 11 dialogues have not completely achieved their objective and the quality of 
dialogues  varies  significantly  across  the  Member  States.  According 
the 
Commission’s  2023  assessment  of  NECPRs115,  most  Member  States  reported  activities 
relating to the establishment of multi-level dialogues. However, the level of maturity of 
such dialogues varied widely and several Member States did not describe them in much 
detail116. According to stakeholders, this is linked to two problems. 

to 

First,  the  Regulation’s  requirements  for  setting  up  the  dialogues  are  not  deemed 
precise or prescriptive enough117. Although most stakeholders agree on the merit of the 
Regulation having created an innovative mechanism in EU legislation, few consider the 
provisions  to  be  properly  implemented  by  Member  States.  They  link  this  issue  to  the 
requirements  in  the  Regulation  being  too  vague,  to  insufficient  guidance  on  which 
stakeholders  to  involve  and  how  to  operationalise  dialogues  (structure,  share  of 
responsibilities amongst participants, meeting frequency etc.). On the other hand, a more 
generally worded provision arguably allows Member States to adapt the dialogues to their 

111   Opinion from the Fit for Future Platform on the Regulation on the Governance of Energy Union and 
Climate Action (2022): https://commission.europa.eu/document/download/2c74cf68-6d44-441c-9183-
759bfc1267d9_en?filename=final_opinion_2022_sbgr1_03_governance_of_energy_and_climate_fup.
pdf. 

112   Decision VII/8f concerning compliance by the European Union with its obligations under the Aarhus 

Convention. 

113   Circabc (europa.eu) 
114   2022/C 495/02. 
115   SWD (2023) 646 final and COM (2023) 796 final. 
116   COM (2023) 796 final. 
117   For instance, EEB, NECP Reporting, The missing voice of the public. Full report available here. 

36 

 
 
specific circumstances, in line with the subsidiarity principle. In 2022, ahead of the NECP 
update cycle, the Commission did provide additional guidance on multi-level dialogues118.  

Second, some stakeholders mentioned lack of national experience and political will 
and problems linked to administrative structures. Not all Member States have put in 
place structured and continuous processes to develop and implement long-term plans and 
strategies  or  to  review  national  systems  for  reporting.  Some  national  authorities  do  not 
consider NECPs a political priority, preventing them from engaging in robust multi-level 
dialogues. It is also argued that in certain Member States, competences and obligations are 
shared between different administrative levels, presenting coordination challenges.  

118   2022/C 495/02. 

37 

 
 
 
 
Efficiency 

4.1.10 Streamlining of planning, reporting and monitoring obligations and cost savings in 
terms of policy coherence and administrative burden 

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  Regulation119  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 baseline120. 

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 
on  information  collected  by  the  Commission  and  national  authorities  for  the  support 
study121,  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. A substantial part of these costs 
relate to obligations that existed before the Regulation, and that were either streamlined in 
the NECPs and NECPRs or taken over directly in the Regulation. 

It is difficult to compare the cost figures from this evaluation with the  costs in the 
2016  impact  assessment  that  underpinned  the  Commission’s  initial  proposal.  The 
figures are based on a limited number of strongly varying inputs that are also impacted by 
inflation. The scope of the obligations is not exactly the same due to the amendments made 
to the Commission's original proposal. For example, during interinstitutional negotiations, 
obligations were added for the Commission to issue reports on competitiveness and energy 
subsidies.  While  it  is  not  possible  to  give  a  quantitative  estimate  of  the  direct  savings 
achieved  by  the  Regulation,  estimates  in  the  study  appear  comparable  with  the  5% 
estimated savings from streamlining provided in the original impact assessment. 

The Regulation also produces efficiency benefits that cannot be quantified. Feedback 
from survey respondents suggests that merging multiple strategic planning documents into 
a single NECP with a streamlined process and prescribed templates reduced administrative 
burden. The unified approach to NECPR reporting has also improved the links between 
individuals  involved  in  reporting  and  monitoring,  leading  to  greater  data  consistency, 

119   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. 

120   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. 

121   See Section 4.1.10 and Annexes II and IV to the staff working document. 

38 

 
 
enhancing both the efficiency and quality of the reporting process. Examples include the 
use of digital tables instead of PDFs, which simplify data management and analysis, as 
well  as  the  advantage  of  a  unified  reporting  platform.  These  advantages,  although 
intangible,  hold  substantial  value,  particularly  to  the  extent  that  better  data  and  more 
coherent planning support policy making in the long run. 

On  balance,  the  more  streamlined  and  integrated  reporting  provided  by  the 
Regulation appears to have had a positive impact on proportionality. This is based on 
an  estimated  modest  reduction  in  the  administrative  burden  described  above  combined 
with  added  advantages  such  as  increased  transparency  and  predictability,  better 
coordination and cooperation among different national authorities involved in the reporting 
process, higher coherence of planning and reporting timelines and procedures, and better-
established processes, policies, and procedures. 

At the same time, more can be done to reduce the administrative burden associated 
with energy and climate policy obligations. Despite the efficiency benefits mentioned 
above, many consulted national authorities considered that implementing the Regulation 
required more financial and human resources. Beyond increased needs for cross-service 
coordination and data compilation this is also due to the fact that national policy planning 
is not always fully aligned with the Regulation, resulting in parallel planning processes. 
Based on the evidence collected, preparing the NECPs is the most complex and resource-
intensive obligation, involving large numbers of staff from different national authorities. 
At the same time, stakeholders (especially national authorities) acknowledged that there is 
a ‘learning curve.’ Although they perceived the initial planning and reporting cycles under 
the  Regulation  as  complex,  there  is  an  expectation  that  the  process  will  become  less 
burdensome  over  time  as  experience  with  the  obligations  is  accrued  and  output 
expectations, tools and templates are fine-tuned. 

Certain  factors  may  influence  the  perceived  impacts  of  the  Regulation  on 
administrative  costs.  Not  all  consulted  national  experts  are  likely  to  have  directly 
experienced the situation before the Regulation entered into force in 2018122. In addition, 
energy and climate policies have increased both in terms of scope, ambition, and political 
salience  since  the  adoption  of  the  Regulation  (see  Section  3)  with  knock-on  effects  on 
planning  and  reporting  requirements.  Several  of  these  policy  developments  are  already 
included in the current NECP/R cycle, either by way of legal amendments or guidance123. 
This means that although the overall administrative burden of energy and climate policy 
may have increased, the Regulation is already mitigating this impact by merging some of 
these developments into a single framework.  

Stakeholders recognised that streamlining is a continuous process and particularly 
some national authorities underlined the need to refocus the Regulation’s obligations 

122   In total, the Commission’s proposal for the Regulation integrates, streamlines or repeals more than 50 
existing  individual  planning,  reporting,  and  monitoring  obligations  under  energy  and  climate  law 
(integrating 31 and deleting 23). COM (2016) 759 final/2 2016/0375(COD). 

123   Commission Notice on the Guidance to Member States for the update of the 2021-2030 national energy 

and climate plans (2022/C 495/02). 

39 

 
 
on  those  that  are  essential  to  achieve  the  EU’s  energy  and  climate  objectives  and 
international reporting requirements. In other words, they recommended exploring how 
to find a better balance between the number and granularity of planning,  reporting, and 
monitoring obligations on the one hand, and the essential information needed for the EU 
to meet its target on the other. 

The Commission is already looking into further potential to reduce the administrative 
burden.  In  parallel  to  this  evaluation  and  as  part  of  the  Commission’s  commitment  to 
reduce  the  administrative  burden  from  reporting  obligations  by  25%,  it  has  prepared 
targeted rationalisation plans based on a screening of the reporting obligations in climate 
and energy legislation. The rationalisation plan for this Regulation includes the planned 
removal of the reporting on oil stocks124 and the expansion and improved functionality of 
the  e-platform.  The  findings  of  this  evaluation  combined  with  the  screening  identified 
scope  for  further  streamlining  the  reporting  obligations  and  processes  under  the 
Regulation,  for  instance  improving  the  sequencing  and  timing  of  different  obligations, 
streamline overlaps in requirements, and reuse of common components across planning 
and reporting, which are currently under assessment. 

4.1.11 Contribution to efficiency gains through increased digitalisation 

The Regulation has made energy and climate reporting more efficient by increasing 
digitalisation.  Article  28  of  the  Regulation  recognises  this  potential,  requiring  an  e-
platform to be set up (representing a EUR 5 million investment by the EU). The use of 
digital templates instead of text-based reports and non-harmonised spreadsheets used for 
many  previous  reporting  periods  made  a  strong  contribution  to  improving  the 
comparability of reported data and the ease of reuse. The e-platform is also progressively 
being  used  to  integrate  environment,  energy,  and  other  obligations  from  outside  the 
Regulation,  generating  substantial  costs  savings and  synergies.  The  e-platform  has  also 
significantly  reduced  the  burden  for  the  Commission  in  managing  reporting,  analysing 
reported data, and making data available for reuse. Digital templates are not yet used for 
NECPs or LTSs. 

More  broadly,  the  platform  helps  identify  what  information  and  data  should  be 
collected  and  submitted  by  the  Member  States,  including  through  automated  quality 
checks. National authorities also noted that it enables access to reported information by 
several users at the same time, who can check and validate information, thus minimising 
the risk of errors when reporting data. 

Though this is an improvement on the previous situation, the platform could still be 
made more user-friendly. Some national authorities consider parts of the design complex 
and unintuitive, complicating data import, review and data visualisation when exporting 
(see also Section 4.1.4). Differences in the design of different parts of the platform on the 
one hand and the tables in the templates of the Regulation on the other sometimes required 
national  authorities  to  reformulate  information  before  submission,  increasing  reporting 

124   Article 26(1)c of the Regulation. 

40 

 
 
time.  The  co-existence  of  two  different  reporting  platforms  (ReportNET3  and 
ReportENER) was criticised by some national authorities and other stakeholders. At the 
same time, technical assistance and tutorials on how to use the platforms by the European 
Commission and the EEA were deemed particularly useful. As noted in Section 4.1.10, 
national authorities also recognised the importance of learning by doing.  

Finally, there is scope to improve the technical functionalities of reporting tools, for 
instance  by  enabling  Member  States  to  pre-load  data  on  policies  and  measures  and 
information on adaptation action into the biennial transparency report (BTR) format of the 
UNFCCC125. This would ease the reporting burden of Member States, who could mutualise 
the reporting effort under the Governance Regulation to meet their reporting obligations 
under the Paris Agreement.  

Coherence 

Internal 

coherence 

When assessing coherence, a distinction can be made between internal and external 
coherence. 
the  different 
planning/reporting/monitoring processes and the related timeframes set in the Governance 
Regulation. External coherence is about how well the Regulation functions in conjunction 
with  other  parts  of  EU  energy  and  climate  law,  other  related  EU  legislation  and  with 
international obligations, in particular the UNFCCC and Paris Agreement.  

coherence 

among 

refers 

to 

In  practice,  the  Regulation  and  its  related  implementing  regulations  and  guidance  have 
been ‘living documents’ able to support an iterative process and learning by doing. None 
of  the  stakeholders  consulted  criticised  the  Regulation’s  general  objective  to  improve 
coherence  in  energy  and  climate  policy.  However,  most  acknowledge  the  challenge  of 
achieving  coherence  within  a  broad  and  complex  framework  and  made  suggestions  to 
correct possible flaws or finetune practical aspects such as misaligned timeframes.  

4.1.12 Internal coherence 

A significant majority of the stakeholders consulted found that the Regulation has 
improved coherence between previous EU energy and climate-related planning and 
reporting  obligations.  In  total,  the  original  proposal  for  the  Regulation  merged, 
streamlined, or repealed over 50 individual planning, reporting and monitoring obligations 
under energy and climate legislation126. On climate policy, it took a more holistic approach 
than its ‘predecessor’ (the Monitoring Mechanism  Regulation) including  by embedding 
reporting on greenhouse gas policies and measures within the broader framework of the 
Energy  Union’s  objectives.  On  energy  policy,  an  example  is  that  it  replaced  separate 
national renewable energy and energy efficiency action plans by integrated NECPs. The 
Regulation also covers, to some extent, several key cross-cutting issues and policies (e.g., 

125   Functionality  is  currently  under  development  alongside  the  UNFCCC  launch  of  a  new  international  reporting 

platform. It is expected to be available within the coming year. 

126  In total, the Commission’s proposal for the Regulation merged, 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). 

41 

 
 
the energy efficiency first principle, energy poverty, the just transition and climate change 
adaptation).  

The remaining inconsistencies are largely due to the complexity of merging numerous 
obligations in a single framework. Although this can create synergies and effectiveness 
gains, it also creates certain challenges such as: 

•  greater complexity, for instance  in  the data  to  be reported under several  articles 
(such  as  adaptation  under  Article  17  and  19,  and  policies  and  measures  under 
Articles 17 to 25) or the use of several data collection processes; 
the  difficulty  of  keeping  an  umbrella  framework  connected  to  many  pieces  of 
legislation up to date, e.g., with the Fit-for-55 package, where each legal proposal 
had its own timeline and specific interlinkages with the Regulation; 

• 

•  sector-specific aspects  and needs may not  be sufficiently  reflected to  trigger the 

necessary action. 

The Regulation’s iterative planning and reporting regime is conducive to learning by 
doing,  which  should  partly  alleviate  such  challenges  over  time.  Some  of  the  work 
covered  by  the  Regulation  (notably  planning  and  reporting  in  areas  such  as  climate 
mitigation,  renewable  energy,  and  energy  efficiency)  build  on  a  longer  tradition  than 
others. The learning-by-doing approach is supported by implementing regulations setting 
out the structure, format, technical details and process of reporting, Commission guidance 
issued  to  prepare  the  NECP  update  process127  as  well  as  expert  meetings.  The 
improvements in quality and coverage (for instance as regards energy poverty, skills and 
just transition)  of NECPs between the first  2019-2020 cycle to  their updates in  2023 is 
testimony to the effect of this learning-by-doing approach. Another example is provided 
by Economidou et  al.  (2022)128 who analysed the experience gained and improvements 
made in the planning, reporting, and monitoring of energy efficiency policies from the first 
national  energy  efficiency  action  plans  (NEEAPs)  in  2007-2008  to  2020  under  the 
Governance Regulation. 

One specific  area  where  stakeholders have raised  consistency issues  is  the relation 
between  national  LTSs  and  NECPs.  According  to  Article  15(6)  of  the  Regulation, 
NECPs  should  be  consistent  with  LTSs.  Stakeholders  noted  that  there  is  an  apparent 
misalignment in the sequencing of NECPs and LTSs: the first LTSs had to be submitted 
after the first NECPs and the Regulation does not contain a legal obligation for Member 
States to revise them until 1 January 2029, in parallel with NECPs.129 Stakeholders also 
noted that there are fewer substantive and process requirements for LTSs than for NECPs, 
for instance in terms of a mandatory template (several LTSs did not cover all the mandatory 

127   https://energy.ec.europa.eu/publications/guidance-ms-updated-necps-2021-2030_en 
128   Economidou, M., Ringel, M., Valentova, M., Castellazzi, L., Zancanella, P., Zangheri, P., Serrenho, T., 
Paci,  D.,  &  Bertoldi,  P.  (2022).  Strategic  energy  and  climate  policy  planning:  Lessons  learned  from 
113225. 
European 
https://doi.org/10.1016/j.enpol.2022.113225. 

efficiency 

policies. 

Energy 

Policy, 

energy 

171, 

129   Members are only requested to update their LTSs by 1 January 2025 ‘where necessary’. 

42 

 
 
content130 under Article 15(4) of the Regulation), mandatory updates after their adoption 
and monitoring. Also, unlike for the NECPs, LTSs are not subject to an iterative process 
with Member States first submitting a draft strategy. Overall, these differences make LTSs 
more likely to be outdated and less useful as tools to inform energy and policy planning, 
especially in the context of recent increases to energy and climate ambitions.  

4.1.13 External coherence 

The Regulation has improved coherence with other parts of EU energy and climate 
law,  as  well  as  with  other  related  EU  legislation  and  international  obligations,  in 
particular  under  the  UNFCCC  and  Paris  Agreement.    It  has  integrated  energy  and 
climate-related  planning and reporting obligations that were previously  scattered  across 
different  pieces  of  legislation.  To  some  extent,  the  Regulation  also  covers  other  policy 
areas  including  environment,  transport,  and  agriculture.  It  has  helped  align  EU  climate 
planning  and  reporting  with  processes  under  the  Paris  Agreement.  As  with  internal 
coherence,  national  authorities  expressed  overall  positive  views  of  the  impact  of  the 
Regulation on external coherence. Third-sector organisations were also positive overall on 
this, but to a lesser extent. 

Nonetheless, there are several areas where external coherence can be improved. The 
Regulation,  for  instance,  is  not  yet  fully  coherent  with  new  or  updated  EU  energy 
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, the related iterative gap-filling mechanism under Article 4(6) and the 
flexibility objectives under the electricity market design reform. 

The Regulation currently does not provide for a mechanism for Member States to report 
on their bilateral and plurilateral initiatives. With an increasing number of energy transition 
initiatives  in  the context of UNFCCC and relevant  bilateral  processes linked to  the EU 
policy agenda, such as on hydrogen, critical raw materials, and methane abatement, there 
is an increasing risk of incoherent or inefficient EU level energy diplomacy.  

There is also scope for further alignment with EU climate legislation. For instance, 
the Regulation’s climate progress assessments can be aligned with those carried out 
for the Effort Sharing  and  LULUCF Regulations. NECP assessments  partly overlap 
with the Article 29(5)(b) assessments carried out for ESR and LULUCF131. In addition, 
there is some inconsistency between Article 17132 and Articles 18 and 29(5)(b), to which 

130   For instance, several LTS did not provide enough or clear information on the exact scope of projected 
GHG  emission  reductions  at sectoral  level,  including  for  LULUCF.  For  background,  see:  cc21a745-
d691-4028-bb0f-7527d115587c_en (europa.eu). 

131   While the draft and final NECPs should be reflected by 31 October in the annual progress assessment 
performed under Article 29(5)(b) for ESR and LULUCF, the NECPs 30 June deadline is in practice too 
late to be able to carry out a complete assessment. 

132   Reporting  under  Article  18  (Integrated  reporting  on  greenhouse  gas  policies  and  measures  and  on 
projections) of the Regulation is necessary to assess annual progress towards the EU’s economy-wide 
2030 and 2050 targets, and for the national and EU-wide ESR and LULUCF targets, which are assessed 

43 

 
 
 
both the ESR and LULUCF Regulations cross reference. The Regulation also includes an 
inconsistency  in  LULUCF  assessments133.  These  overlaps  and  inconsistencies  create 
unnecessary burden and complexities.  

Coherence can also be improved between the climate assessments carried out under 
the Regulation and those under the European Climate Law. The substance and follow-
up of the assessments partly overlap134. The timelines of upcoming assessments can also 
be better aligned135.  

In  terms  of  coherence  between  the  Regulation  and  other  policy  areas,  the 
Commission’s assessment of draft updated NECPs found that Member States have 
only  partially described and exploited synergies136. For instance, biodiversity,  nature 
restoration  and  nature-based  solutions  can  still  be  better  integrated  in  plans  to  enhance 
carbon sinks. The majority of draft updated NECPs also lack sufficient ambition and action 
on land use and few Member States refer to CAP strategic plans (CSPs). Over half of the 
draft plans do not include the required information on the impact of policies on projected 
emissions  of  the  main  air  pollutants  regulated  under  the  National  Emissions  Reduction 
Commitments  Directive137  nor  on  the  alignment  of  National  Air  Pollution  Control 
Programme (NAPCP) with energy and climate programmes. Similarly, most plans could 
take more account of water, zero pollution and circular economy policies, both in view of 
their contribution to climate mitigation and adaptation and to foster strategic autonomy. 

on  a  biennial  basis  under  Article  29(5)(b).  Based  on  this  assessment,  both  the  ESR  and  LULUCF 
Regulations  provide  for  corrective  action  if  a  Member  State  makes  insufficient  progress  towards  its 
national targets. However, although both Articles 17 (Integrated national energy and climate progress 
reports)  and  18  require  biennial  reporting  as  of  15  March  2023,  only  the  latter  requires  substantial 
changes to be reported in years where there is no Article 17 reporting. As a result, only Article 18 ensures 
that the annual assessment under Article 29(5)(b) draws on annual data from the Member States. 
133   While Article 30 specifically requires Member States to include in their NECPs LULUCF PaMs to show 
progress under the LULUCF Regulation should they intend to use the Article 7 ESR flexibility, Member 
States already need to report under the LULUCF Regulation on progress in their NECPs (irrespective 
of whether they intend to use the Article 7 ESR flexibility). This in addition to the overlap between 
NECPR and Article 29(5)(b) assessments. 

134   In  2023  the  Commission  published  in  the  CAPR  its  five-yearly  assessment  of  Union  progress  and 
measures (Article 6 ECL) and national measures (Article 7 ECL). Based on its assessment, which is 
closely  linked  in  substance  to  assessments  carried  out  under  the  Regulation,  the  Commission  issued 
recommendations to Member States in December 2023 under the ECL. At the same time, Member States 
also received recommendations on their draft updated NECPs. The recommendations under the ECL 
focused  on  the  consistency  of  their  measures  with  the  EU’s  climate-neutrality  objective,  and  with 
ensuring progress on adaptation (Article 7 ECL). The follow-up on the recommendations under Article 
7 ECL has one additional step compared to the follow up of Article 34 (Commission recommendations 
to Member States) of the Regulation. 

135   The  ECL’s  five-yearly  assessment  (done  in  September)  is  both  linked  to  the  timing  of  the  yearly 
assessment of progress under the Regulation and to the global stocktake (occurring at the end of 2023 
and every 5 years thereafter). During the next assessment cycle there is a risk that certain information 
will not be available in time to inform planning processes under the Regulation as draft and final NECPs 
for the 2031-2040 period are due by 1 January 2028 and 1 January 2029, but assessments under Articles 
6 and 7 of the ECL are already due by 30 September 2028. 

136   The Commission’s Guidance for the update of the NECPs encouraged Member States to identify and 
create synergies between energy and climate planning and with relevant policy areas, see: Guidance to 
MS for updated NECPs 2021-2030 - European Commission (europa.eu). 

137   Directive 2016/2284 on the reduction of national emissions of certain atmospheric pollutants 

44 

 
 
In a similar vein, stakeholders argued that the Regulation could better reflect transport and 
industrial policy (e.g., as regards recharging infrastructure and the Net-Zero Industry Act) 
as well as the EU’s economic governance framework. Clarifying the link between national 
commitments  to  phase  out  fossil  fuels  including  coal  and  regional  commitments  in 
territorial just transition plans138 would also be useful. Stakeholders also mentioned that 
time periods and deadlines set in different EU plans (e.g., NECPs, REPowerEU chapters 
and national Social Climate Plans) are not aligned.  

Most  stakeholders  expressed  positive  views  on  the  Regulation’s  coherence  with 
international legislation and obligations. The common rules for planning, reporting, and 
monitoring facilitate work to meet international obligations such as those stemming from 
the  UNFCCC  and  the  Paris  Agreement.  It  also  ensures  that  Member  States  report  on 
adaptation to climate change and on the provision of financial, technological, and capacity-
building support to developing countries.  

Nonetheless, coherence with the EU’s international obligations can still be improved. 
The  Regulation’s  NECPR  reporting  cycle  occurs  in  odd  years  (on  15 March)  but  the 
UNFCCC reporting cycle takes place in even years (31 December). In practice this means 
that the EU’s BTRs will not include the latest figures139. In addition, Article 17 will need 
to  be  updated  since  the  biennial  reports  have  been  replaced  with  biennial  transparency 
reports.  

Finally,  there  may  be  scope  to  strengthen  coherence  with  national  and  regional 
planning cycles. Several stakeholders pointed out inconsistencies with national, regional, 
and local planning cycles. Some Member States prepare national climate and/or energy 
plans  that  are  not  fully  aligned  with  their  NECP,  either  because  they  are  prepared  at  a 
different time or because they have a different scope. Another example are the local heating 
and  cooling  plans  required  by  the  new  EED  (Article  25(6)),  how  the  plans  should  be 
coordinated with the national comprehensive heating and cooling assessments, and then 
reflected in NECPs.  

4.2 EU added value: how did the EU intervention make a difference and to whom? 

Building on Section 4.1, this section assesses the EU added value of the Regulation, i.e., 
the  extent  to  which  it  has  produced  results  beyond  what  would  have  been  achieved  by 
Member States acting alone. 

4.2.1. Coordination and consistency of Member States’ energy and climate policies 

On the whole, stakeholders tended to agree that there has been an improvement in 
the  coordination  and  consistency  of  national  energy  and  climate  policies.  Most 
surveyed national authorities (18 of 25) indicated that the Regulation has contributed to 
more coordinated and consistent national energy and climate policies to a very large, large 

138   Prepared within the context of the Just Transition Fund Regulation (2021/1056). 
139   Data from NECPs can also not be included in the EU’s BTR, as the June 30 deadlines come too late. 

45 

 
 
or some extent. Third-sector representatives found the Regulation to have had a smaller 
EU added value, with industry stakeholders providing mixed replies. 

By  promoting  more  coordinated  and  consistent  action,  the  Regulation’s  common 
framework  and  mechanisms  provide  EU  added  value  and  contribute  to  the 
achievement of the EU’s energy and climate objectives for 2030 and beyond. While 
some of the 2020 energy targets were binding on individual Member States (notably the 
renewable  energy  target  of  20%)140,  the  energy  targets  for  2030  must  be  achieved  by 
Member  States  collectively.  Without  the  Regulation  it  would  have  been  difficult  for 
Member  States  to  coordinate  the  necessary  national  contributions  to  EU-wide  energy 
targets. Data reported and plans submitted under the Regulation provide information on 
national ambition levels and implementation. It's helpful in assessing progress, identifying 
synergies, promoting policy coherence and fostering transparency among Member States.  

This is confirmed by some of the stakeholders consulted who highlighted the added value 
of  uniform  and  structured  reporting  systems  to  assess  progress  against  targets  in  a 
consistent  way.  Stakeholders,  including  some  national  authorities,  also  commented  that 
access  to  other  countries’  NECPs  in  similar  and  comparable  formats  is  helpful  to 
cooperation, sharing best practices and learning.  

4.2.2  Provision  of  information  at  EU  or  national  level  that  would  not  otherwise  be 
available. 

While the Regulation has supported Member State planning and reporting, its added 
value partly depends on the national processes in place before its adoption. Around 
half  (14  out  of  27)  of  the  national  authorities  participating  in  the  survey  indicated  that 
without  the  Regulation  the  same  level  of  planning  and  reporting  would  not  have  been 
achieved. Just over a third (10 out of 27) said that they would have achieved the same level 
of planning and reporting in absence of the Regulation.  

The replies from survey respondents representing the third sector were more consistent, 
with a clear majority (10 out of 14) indicating that in the absence of the Regulation the 
planning and reporting in their Member State(s) would not have been at the same level. 

Feedback from targeted interviews also indicates that the Regulation provides added 
value to planning and reporting processes. All nine interviewees who commented on 
this question felt that planning and reporting processes are better than they would have 
been in the absence of the Regulation (see also Section 4.1). Interviewees highlighted the 
EU  added  value  of  having  mandatory  templates  to  ensure  comparable  and  consistent 
reporting and the obligation to tie national level planning to EU targets. The Regulation’s 
added  value  depended  in  part  on  the  national  planning  and  reporting  requirements  that 
Member States had in place before adoption of the Regulation (with higher added value in 
Member States that lacked comparable planning requirements in national law). 

140   Directive 2009/28/EC, Art. 3. 

46 

 
 
4.2.3 Transparency and predictability of Member States’ energy and climate policies 

Stakeholders  indicated  that  the  Regulation  has  increased  data  availability  and 
improved  transparency  and  predictability  of  Member  States’  energy  and  climate 
policies. A majority (13 of 25) of national authorities that responded to the survey agreed 
to  a  very  large  or  large  extent  that  the  Regulation  contributed  to  more  transparent  and 
predictable national energy and climate policies. An additional seven believed that it did 
so to some extent.  

Stakeholders see the Regulation’s added value especially in terms of the publication 
of  NECPs  and  EU-wide  datasets  on  the  new  e-platform.  Some  also  argued  that  the 
transparency and predictability resulting from a stable governance framework in general 
and NECPs in particular can support decision-making by both policy makers and investors. 
In  addition  to  planning,  they  noted  that  standardised  reporting  processes  and  timelines, 
coordination mechanisms and public access to information are also positive features. 

However,  stakeholders  noted  delays  in  data  availability  and  the  fact  that  data  is 
sometimes incomplete and not always understandable. They identified some areas for 
improvement in terms of both transparency and re-usability of information, and as regards 
public access to information (see Sections 4.1.3 and 4.1.4 for further details). 

4.2.4 Added value in ensuring accountability and access to justice141  

Stakeholders expressed differing views on the Regulation’s added value in ensuring 
accountability and access to justice, primarily due to uneven national implementation. 
Access to justice is fundamental to ensure that acts and administrative decisions comply 
with EU environmental legislation and promote accountability of public authorities, both 
Member States and EU142.  

The  Aarhus  Convention  and  the  Strategic  Environmental  Assessment  Directive143  are 
relevant for access to justice on EU environmental legislation. The Regulation refers to the 
applicability of provisions in both the Convention and the Directive. 

Stakeholders  identified  some  areas  where  the  Regulation  has  provided  EU  added 
value in terms of accountability. They include EU checks on the quality of Member State 
data  and  the  level  of  ambition  of  planning,  the  ability  to  request  improvements  in  both 
respects, the  extension of  planning  and  reporting to  new areas and  better  monitoring  of 
Member States’ achievement of climate and energy targets. Increased public information 

141   This evaluation assesses aspects related to access to justice as stated by the European Commission on 

the occasion of the adoption of Regulation (EU) 2023/857 and Regulation (EU) 2023/839. 

142   Article 9 of the Aarhus Convention, to which both the EU and Member States are parties, enshrines the 
right to effective remedy against acts or omissions contravening environmental law, subject to certain 
conditions. In this context, the Union and Member States must provide members of the public, including 
environmental associations, with enough possibilities through administrative or judicial review to legally 
challenge acts for violations of environmental law. 

143   Directive - 2001/42 - EN - EUR-Lex (europa.eu) 

47 

 
 
on progress and future planning makes it easier to track Member States’ progress towards 
objectives and therefore supports public accountability.  

Nonetheless, the majority of third-sector respondents did not believe that access to 
justice  and  accountability  had  improved  with  the  Regulation.  In  their  view,  the 
Regulation lacks sufficient mechanisms to hold Member States and the EU accountable for 
their obligations under the Regulation and the Aarhus Convention, to which both EU and 
Member States are parties. As regards access to justice, some noted the lack of a specific 
and direct right of access to justice provision in the Regulation to challenge NECPs or LTSs 
before national courts across the EU, which leads to inconsistent application of the access 
to justice right among Member States144. Some studies indicate that challenges to NECPs 
and LTS on the grounds of the Regulation are limited to unfulfilled procedural or content 
requirements,  and  consequently,  policies  and  measures  in  the  NECPs  can  only  be 
challenged indirectly if they are against European or domestic law, which is not satisfactory 
to fulfil Aarhus Convention requirements, according to third-sector stakeholders145.  

The Regulation refers to the applicability of provisions in both the Aarhus Convention and 
the Strategic Environmental Assessment Directive. However, some stakeholders argued 
that further clarity on its applicability to NECPs could ensure access to justice rights in all 
Member States. 

Stakeholders  suggested  that  including  a  horizontal  access  to  justice  provision  in  the 
Regulation  could  be  useful,  for  instance  where  Member  States  breach  the  Regulation's 
provisions  on  public  participation,  e.g.,  in  relation  to  NECPs  or  any  substantive 
requirements of European environmental law.  

Most  of  the  surveyed  national  authorities,  however,  considered  that  the  Regulation  has 
improved both accountability and access to justice.  

4.3 Is the Governance Regulation still relevant as it stands? 

The Regulation’s core objective of providing an integrated governance structure that 
both enables and pushes Member States to commit to and meet ambitious energy and 
climate targets is  still fully relevant. The Regulation  may however require updates  in 
light of several important developments and events that have taken place since 2018 (see 
also Section 3.2).  

4.3.1 Relevance in view of legislative and policy developments at EU and international 
level 

Despite the evolving regulatory and policy framework both at EU and international 
level, the Regulation has provided a stable and useful framework for planning and 
reporting. This is partly because related EU legislation adopted after 2018 has given rise 
to targeted amendments to the Regulation. However, regulatory and policy developments 

144   See for example: EEB (2024) A revised and responsive Governance Regulation. 
145   Juliette Robert,  (2023) The EU´s climate and Energy framework in light of the Aarhus Convention, 

Brussels School of Governance. 

48 

 
 
do not necessarily require updates to the Regulation to be taken into account by Member 
States in their plans and reports. The guidelines issued by the Commission on the process 
to update their NECPs contain several recommendations to this effect. For example, they 
cover the contribution of the circular economy to the climate transition and application of 
the ‘do no significant harm’ (DNSH) principle when drawing up policies and measures. 
Several stakeholders notably from the third sector suggested that this does not always occur 
in practice, however. 

In course of the consultation, most national authorities gave positive feedback on how 
up to date the Regulation is, however other stakeholders argued that certain aspects 
are  not  sufficiently  covered  in  the  current  Regulation.  They  mentioned  economic 
aspects (investment needs, sources for financing and macroeconomic impacts as having a 
limited  space  in  NECPs),  the  availability  of  labour  resources  needed  to  implement  the 
technological  transition,  indicators  tracking  energy  sufficiency,  grid  deployment, 
electrification,  and  climate  adaptation.  As  regards  investment  needs,  the  NECPs  have 
played certain role in identifying investment needs and new RRF-funded support measures 
must  be  reported  as  part  of  the  biennial  reporting  of  policies  and  measures  under  the 
Regulation and reflected in the updated NECPs to be submitted by 30 June 2024. However, 
a consolidated assessment of investment needs and the sources of financing for the policies 
and measures planned to achieve the objectives and targets can be better reflected in the 
NECPs.  

Another  issue  raised  is  whether  the  plans  produced  by  Member  States  and  the 
Commission are updated with sufficient frequency. For instance, several third sector 
stakeholders argued that the Commission’s 2018 LTS, adopted under Article 15(2) of the 
Regulation, is outdated and no longer in line with the current policy landscape (see also 
Section 4.1).  

The Regulation’s role in ensuring proper reporting by the EU and its Member States 
under the UNFCCC and the Paris Agreement remains fully relevant. At the same time, 
specific  provisions  may  require  updating  in  the  light  of  recent  developments  such  as 
decisions,  arrangements,  procedures  and  guidelines  under  enhanced  transparency 
framework, the agreement at COP28 to transition away from fossil fuels in energy systems 
and the Global Goal on Adaptation. This also concerns the reporting obligations stemming 
from  Article  6  of  the  Paris  Agreement  which  may  be  reported  in  conjunction  with  the 
Biennial Transparency Reports. 

4.3.2 Relevance in view of socio-economic, environmental, and geopolitical changes and 
risks 

The  Regulation’s  core  objectives  have  gained  in  relevance  given  the  increasing 
urgency to tackle climate change and the increasingly complex needs that energy and 
climate policies must address.  

The IPCC's 2023 Sixth Assessment Report predicts higher climate-related risks than the 
previous assessment report published in 2014. In Europe, the first ever European Climate 

49 

 
Risk Assessment146 forecasts that in the best-case scenario where global warming is limited 
to 1.5 degrees above pre-industrial levels, Europe – which is heating at twice the global 
rate – will be 3 degrees warmer and consequently impacted by more heatwaves and other 
weather extremes.  

In this context, mainstreaming resilience and climate adaptation considerations in climate 
mitigation and energy  policy  has  become prominent  areas of action for  the Regulation. 
Climate change increases the risks for energy security, in particular electricity disruption 
due  to  heat,  wildfires,  droughts,  and  floods  affecting  peak  demand  and  impacting 
production, storage, transport, and distribution.  

The  recent  geopolitical  and  other  crises  have  also  confirmed  the  relevance  of  the 
Regulation and have brought to the forefront critical issues such as energy security, 
industrial competitiveness and social issues that could be better integrated into the 
Regulation. The energy supply crisis following the Russian aggression against Ukraine 
and  the  COVID-19  pandemic  disrupted  several  aspects  of  EU  energy  policy  and  made 
European policymakers acutely aware of the risks associated with large and undiversified 
reliance on energy supplies from third countries. These crises heightened the relevance of 
the Energy Union’s objectives and accelerating the need for a clean energy transition. They 
also  triggered  a  recalibration  of  immediate  policy  priorities  and  highlighted  transition 
challenges,  leading  to  the  adoption  of  the  REPowerEU  plan.  As  pointed  out  in  other 
sections,  the  energy  crisis  impacted  the  Regulation’s  objectives  by,  for  example, 
emphasising the need for stronger coordination and cooperation among Member States on 
gas supply (e.g., joint purchasing). 

Survey  results  indicate  that  national  competent  authorities  and  civil  society  are 
divided  on  whether  the  Regulation’s  governance  mechanism  has  responded 
adequately to these events. National authorities tended to take a neutral or positive stance, 
but  third-sector  respondents  overwhelmingly  found  the  Regulation’s  governance 
mechanism to be inadequate. 

146  EEA (2024), European Climate Risk Assessment, ISSN 1977-8449, 

https://www.eea.europa.eu/publications/european-climate-risk-assessment. 

50 

 
 
 
 
Stakeholders  suggested  that  the  Regulation  does  not  adequately  cover  socio-economic 
issues such as energy poverty, labour shortages and wider sustainable development goals. 
They  argued  that  this  is  exacerbated  by  the  lack  of  robust  economic  macroeconomic 
assessments  of  the  policies  and  measures  included  in  the  NECPs.  In  line  with  these 
observations, the Commission, in its assessment of the draft updated NECPs found that 
most  NECPs  still  lack  structural  policies  and  measures  to  alleviate  energy  poverty147. 
Stakeholders also suggested that NECPs do not sufficiently link to economic governance 
and should include more information on lowering dependence on fossil fuels and taking a 
binding path to a carbon-negative economy within planetary boundaries.  

147   Commission Communication of 18 December 2023, EU-wide assessment of the draft updated National 
Energy and Climate Plans - An important step towards the more ambitious 2030 energy and climate 
objectives under the European Green Deal and RePowerEU, COM (2023) 796 final.  

51 

 
 
 
5.  CONCLUSIONS AND LESSONS LEARNED 

The Governance Regulation, which entered into force in December 2018, provides a 
first-of-a-kind  framework  that  combines  strategic,  long  and  mid-term  energy  and 
climate  planning  with  robust  reporting  and  monitoring  mechanisms  to  ensure 
delivery on the ground.   

The  Regulation  thus  plays  an  important  role  in  meeting  the  EU’s  energy  and  climate 
objectives and targets and promoting the long-term investments needed for the climate and 
energy transition. Although it is too early to draw definitive conclusions, the Regulation 
has proved a valuable tool despite some concerns over a lack of sufficient mechanisms to 
tackle ambition and implementation gaps. The Regulation's core objective of providing a 
governance structure that both enables and pushes Member States to commit to and meet 
ambitious energy and climate objectives and targets remains more relevant than ever given 
the  growing  urgency  of  climate  mitigation  and  adaptation  action  and  the  increasingly 
complex needs that Member States' energy and climate policies must address. 

The  Regulation  has  strengthened  integrated  energy  and  climate  policy  planning, 
streamlined  reporting,  increased  the  coherence  of  timelines  and  procedures,  and 
improved transparency and predictability. National energy and climate policies have 
become more consistent, though impacts varied across Member States partly depending on 
national processes that preceded the Regulation.  

Importantly, the Regulation has enabled the EU and Member States to comply with 
the UNFCCC reporting requirements and report on their progress  to address  climate 
change and reach their objectives and targets under the UNFCCC/Kyoto Protocol. Updates 
in the reporting regime under the Paris Agreement are yet to be incorporated. 

Despite  having  integrated,  streamlined,  or  repealed  multiple  individual  planning, 
reporting,  and  monitoring  obligations  of  energy  and  climate  legislation,  many 
national administrations do not yet perceive a reduction in  administrative burden. 
This may at least be partly explained by the fact that more integrated processes require 
more policy coordination, and that the learning curve for new reporting cycles has not yet 
reached its peak.  

The Regulation has improved cooperation among different ministries and authorities 
at national level. To some extent, it has also stimulated regional cooperation between 
Member States in developing their plans. While the Regulation is perceived as a step 
forward in terms of stakeholder consultation and multi-level dialogue, concerns have been 
expressed over its provisions being too unspecific to ensure a sufficient and comparable 
level  of  consultation  across  Member  States.  Coordination  with  local  and  regional  level 
bodies may also merit more attention. 

The Regulation has improved the quality of information in plans and reporting, but 
significant information gaps remain, particularly in terms of the actual effects of policies 

52 

 
and measures. More detailed information is also needed on investment needs, funding 
sources and macro-economic impacts.  

The Regulation has improved the management of energy and climate data, promoting 
a clearer and more open mechanism for sharing information and making decisions. 
The digitalisation of reporting through online platforms and the use of common templates 
has significantly simplified the submission, assessment, and accessibility of data, however 
several  stakeholders  have  remarked  that  accessibility  still  should  be  further  improved, 
notably for the public and non-expert users. Importantly, this process has identified scope 
to further align the timing and content of different obligations inside and outside of the 
Regulation. 

The  Regulation  has  improved  accountability  to  some  extent,  nevertheless,  some 
stakeholders  argued  that access  to  justice is  not  applied  consistently  across  the EU  and 
called on more clear, harmonised, and effective access to justice rights as regards NECPs 
and LTS in line with the Aarhus Convention. 

The Regulation is not yet fully in sync with the significant transformation that the 
European and international energy and climate policy landscape has undergone  in 
recent  years,  both  as  result  of  the  European  Green  Deal  and  the  unprecedented  crises 
caused by the COVID-19 pandemic and the Russian war of aggression against Ukraine.   

Moving  forward,  the  Regulation  needs  to  help  the  EU  meet  a  set  of  widening  and 
increasingly  ambitious  energy  and  climate  objectives  beyond  achieving  its  2030 
targets. It should provide a basis to shape and implement future EU policy in these areas, 
particularly  the  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,  provide  certainty  for  investments  in  industrial  decarbonisation,  
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 
Assessment148. 

148   https://www.eea.europa.eu/publications/european-climate-risk-assessment  

53 

 
 
 
ANNEX I:  PROCEDURAL INFORMATION 

Lead DG and Decide reference 

The evaluation was led by the European Commission’s Directorates-General for Energy and Climate 
Action. 

Decide entry: PLAN/2023/658. 

Organisation and timing 

The  call  for  evidence149  was  published  for  feedback  for  a  four-week  period  from  6 July  to 
3 August 2023. 

An  Interservice  Steering  Group  (ISG)  was  set  up  compromising  the  following  services:  SG,  SG-
RECOVER, LS, AGRI, BUDG, CNECT, ECFIN, EMPL, ENV, ESTAT, FISMA, GROW, INTPA, 
JRC, JUST, MOVE, NEAR, REFORM, REGIO, RTD, TAXUD, TRADE, as well as the European 
External Action Service and the European Environmental Agency. Five meetings of the ISG were 
held on 26 April, 5 September, 26 October 2023, 11 January, and 18 June 2024. 

Evidence and sources 

The  European  Commission,  Directorates-General  for  Energy  and  Climate  Action  contracted  a 
consortium led by ICF to carry out a support study150 for this evaluation from July 2023 to May 2024. 

The  methodology151  for  the  study  included:  a  call  for  evidence,  comprehensive  desk  research, 
including  the  key  deliverables  (long-term  strategies,  NECPs  and  progress  reports)  under  the 
Governance Regulation, a legal mapping of planning, reporting and monitoring obligations stemming 
from the Governance Regulation, an online survey of national authorities, industry representatives 
and third-sector organisations, telephone interviews, country case studies and a stakeholder event in 
Brussels. 

149   Energy Union and climate action – Review report on the Governance Regulation (europa.eu) 
150   Support study for the evaluation of Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate 

Action – final report (forthcoming) 

151   A detailed description of the methodological approach and its limitations can be found in Annex II. 

54 

 
 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

This Annex describes the methods and sources used during this evaluation, including the limitations 
encountered.  

The evaluation was underpinned by a study undertaken by a consortium led by ICF. The contractor 
conducted the consultation activities mentioned below, analysed the results, and provided replies to 
the evaluation questions. It also prepared technical annexes.  

The  support  study  provided  a  good  basis  for  the  Commission  evaluation.  However,  since  its 
conclusions  drew  mainly  on  the  consultation  activities,  they  required  further  desk  research  from 
Commission departments to improve their robustness. 

Central to the methodology were the evaluation (sub)questions (See Annex III) developed based on 
the five evaluation criteria: effectiveness, efficiency, coherence, relevance, and EU added value. The 
analytical  approach  used  to  evaluate  the  Regulation  was  based  on  the  analysis  of  consultation 
findings, a triangulation of stakeholder views, qualification and quantification of costs and benefits 
estimates. 

To gather information to conduct the evaluation,  the Commission carried out a range of  activities 
with the support of the contractor. The summary below summarises the used sources of information: 

Literature review. A comprehensive literature review to identify relevant secondary sources 
of  information  and  data.  It  drew  on  relevant  literature  and  data  from  a  variety  of  sources 
including  the European Commission, the Member States and peer-reviewed literature. The 
review  included  mapping  obligations,  which  included  a  comprehensive  set  of  legislative, 
implementing, and delegated acts, as well as other non-legislative documents related to EU 
climate and energy legislation. The review of literature also provided important information 
on the costs and benefits of the Regulation to feed into the baseline and assessment of the 
Regulation’s efficiency. 

-  Call for evidence. Between 6 July 2023 and 3 August 2023, the Commission conducted a call 
for evidence on the 'Have your say' portal.152 The objective was to provide stakeholders and 
the public with an opportunity to share their views on the functioning of the Regulation. The 
target audience included organisations, social partners, the scientific community, the general 
public, Member State authorities and other public authorities. 53 respondents, covering eight 
respondent groups, replied to the call for evidence (see also Annex V). The most represented 
stakeholder  group  were  non-governmental  organisations  (NGOs)  (34%,  18  in  number), 
followed by public authorities (15%, 8) and business associations (13%, 7). Other respondents 
included  EU  citizens  (9%,  5),  companies/businesses  (9%,  5),  environmental  organisations 
(9%,  5)  and  academic  or  research  institutions  (6%,  3).  The  responses  came  from  16  EU 
Member  States  and  two  third  countries  (the  United  Kingdom  and  Australia).  Most  of  the 
stakeholders  provided  a  position  paper  accompanying  their  submission,  or  less  structured 
views on the Regulation and/or on the EU’s overall climate and energy policy framework. 

152   Energy Union and climate action – Review report on the Governance Regulation (europa.eu) 

55 

 
 
Many  of  the  submissions  covered  forward-looking  aspects  of  governance  that  would  be 
relevant to a possible impact assessment. 

-  Targeted surveys. The evaluation included input from a set of targeted surveys from national 
authorities,  industry  organisations  and  third-sector  stakeholders.  The  surveys  covered 
questions  of  relevance  to  the  evaluation  and  some  scoping  questions  on  the  problem 
definition.  The  surveys  elicited  a  total  of  70  responses.  This  included  33  responses  from 
national  authorities,  20  responses  from  third-sector  stakeholders  and  17  responses  from 
industry organisations. 

- 

Interviews. 10 scoping interviews and 35 key informant interviews were conducted as part of 
the evaluation, and a further 35 targeted interviews were conducted as the basis for the case 
studies.  Despite  taking  several  mitigating  measures  to  boost  the  participation  rate  for 
interviews, the contractor did  not  manage to  conduct  the 60 interviews initially  hoped for. 
Consequently, the answers to the evaluation questions are based on less first-hand information 
and narrower feedback than initially envisaged, which may have prevented or hindered robust 
conclusions from being drawn. 

-  Stakeholder  event.  A  stakeholder  event  was  organised  by  DG  ENER  and  DG  CLIMA  on 
11 January 2024, involving approximately 120 representatives from Member States’ national 
authorities,  industry  organisations  as  well  as  civil  society  stakeholders.  The  study  team 
presented some of the preliminary findings of the evaluation at this event. The main points 
emerging from the discussion have been integrated into the findings of the evaluation.  

-  Case studies. During the evaluation, seven country-focused case studies (Belgium, Denmark, 
France,  Germany,  Malta,  Romania,  and  Poland)  were  conducted  to  explore,  in-depth,  the 
procedures and processes used in the Member States to comply with the reporting obligations 
set by the Governance Regulation and the related costs (including administrative burden) and 
benefits. The case studies also explored three main topics: i) public consultation and multi-
level climate and energy dialogues, ii) regional cooperation, and iii) compliance.  The case 
studies draw on the general programme of stakeholder consultation, as well as more targeted 
desk research and stakeholder interviews in the seven case study Member States. 

-  Efficiency analysis. An in-depth  screening  of the reporting and planning  obligations  under 
energy  and  climate  law,  and  links  between  reporting  in  the  energy/climate  sectors  with 
sustainability reporting obligations in other policy areas, was carried out and assisted by AI. 
In total, over 900 reporting obligations were screened, 39 of which under the Regulation. The 
same tool was used to collect data on the costs and benefits of the related obligations for both 
Member States and for the Commission. The analysis focused on quantifying and monetising 
the key direct cost and benefits for which information was available. The remaining costs and 
benefits were assessed qualitatively. The costs are assessed against a baseline representing the 
situation before the Governance Regulation entered into force. The costs were estimated in 
euro, in current prices (2023 prices). More details can be found in Annex X of the support 
study. 

56 

 
 
 
Limitations and data robustness 

Literature and data were primarily sourced in English, but targeted searches in other EU languages 
were conducted to bridge the information gaps, particularly for the country case studies. However, it 
is acknowledged that some pertinent non-English information may have been overlooked.  

The response rate to the various strands of consultation was lower than expected. Efforts were made 
to increase participation by contacting stakeholders directly via email and occasionally via telephone 
and LinkedIn, and by sending reminder emails. The timeline for the consultation was also extended 
to  the  maximum  extent.  Despite  these  efforts,  participation  levels  remained  below  expectations, 
resulting in a narrower range of viewpoints. Consequently, the evaluation’s findings may in places 
lack the robustness that a broader participation could have provided.  

Given the Regulation is an ‘umbrella’ piece of legislation it was not always possible to establish a 
clear  causal  effect  of  the  Regulation  on  specific  aspects,  such  as  how  it  has  contributed  to  the 
implementation of more ambitious climate and energy measures.  

For  the  efficiency  analysis,  evidence  collected  from  the  Member  States  provided  limited  and 
fragmented information on the current costs and benefits of implementing the Regulation. This was 
due to the low response rate, but also because the responsibility for reporting obligations were often 
split among different administrations, and several respondents had limited knowledge of the costs of 
previous rounds of reporting and the situation before the Regulation entered into force. The analysis 
therefore is based on a set of assumptions and simplifications and needs to be taken with some caution.  

Despite  these  limitations,  by  triangulating  data  sources  and  holding  extensive  discussions  with 
national authorities and stakeholders, the Commission obtained robust conclusions for most of the 
evaluation questions.  

57 

 
Analysis cross 
reference  

See Section 5.111 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION) 

Evaluation questions &  
sub-questions 

Judgement criteria 

Indicators and information 
requirements 

Data sources 

EFFECTIVENESS  
To what extent has the Regulation effectively achieved its key objectives, across the five dimensions of the Energy Union 

Legal mapping. 

■ 
■  Desk research, including desk review 
of EC assessments of draft / final 
NECPs, and of wider stakeholder 
assessments (reports from ECA, 
academics or think tanks) on potential 
scope for better coverage. 

■  Mapping of information requirements 

along the five dimensions vs 
information available. 
EU-level interviews. 
Interviews with MS authorities. 
Targeted surveys with MS authorities. 

■ 
■ 
■ 
■  Case studies. 
■  Workshop on draft evaluation results. 

EQ1 – To what extent has the Regulation led to increased 

■ 

quality, increased timeliness and increased (public) 
accessibility of the reported information across the 
Energy Union’s five dimensions and on all aspects related 
to the Regulation’s objectives, notably in terms of 
national energy and climate plans (NECPs), Long-Term 
Strategies, and annual and biennial reports? 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

EQ1.1 – To what extent did the Regulation contribute 
to improved plans, reports, and monitoring, including 
through more integrated and streamlined processes? 
EQ1.2 – To what extent do Member States fulfil their 
current planning and reporting obligations in a 
complete and timely manner? 
EQ1.3 – Are the indicators used in the reports 
effective in tracking progress across all dimensions? 
EQ1.4 – What are the main reasons for any 
limitations / deficiencies of the plans and reports?  
EQ1.5 -To what extent have the guidance documents 
produced by the EC been appropriate and up to date? 
To what extent have the Member States followed the 
guidance documents provided by the 
Commission? What problems have been observed and 
why?  
EQ1.6 – To what extent has the dedicated technical 
support funded by the Commission facilitated the 
planning and reporting process? 
EQ1.7 – To what extent has the Regulation led to 
increased transparency and public accessibility of 
reported information? 

The information is made available in 
an accurate, complete, and timely 
manner. 

Quantitative indicators 
■  Number of documents / reports submitted on time 

to the Commission. 

■  Member States fulfilled their current 

■  Number of views / downloads of the publicly 

planning and reporting obligations 
correctly in terms of timeliness, 
completeness, consistency, 
comparability, coherence, 
transparency, and accuracy. 
Indicators used in the reports 
effectively and comparably tracked 
progress across all dimensions. There 
are no information gaps, no areas 
where increased coverage would 
yield benefits (without resulting in 
disproportionate costs for concerned 
entities).  
The Regulation led to increased 
transparency and public accessibility 
of reported information. 

available documents / reports.  

Qualitative indicators 

■ 

■ 

■ 

■  Quality / degree of completeness of planning 
documents and data/ reports provided. 
Public availability of complete planning 
documents and data/ reports. 
Stakeholders’ degree of satisfaction with current 
coverage of information 
Extent to which the EC guidance was adhered to 
and facilitated the planning / reporting processes. 
Extent to which dedicated technical support 
funded by the Commission facilitated the process 
(take up statistics, views on its usefulness). 
■  Main limitations or deficiencies in the plans and 
reports submitted by the MS, as identified by key 
stakeholders.  

■ 

Further information requirements 
■  Reasons put forward by some MS for not 

submitting documents / reports (e.g., LTS), or not 
on time, and consequences for the EU / 
international level and wider stakeholders. 
■  Any further room for improvement / support tool 

■ 

that could be implemented. 
Suggestions made by stakeholders for improving 
or expanding coverage / timeliness / transparency 
/ accessibility and feasibility of addressing these 
needs. 

Answer 

The Regulation has led to increased quality of information across the Energy Union’s five dimensions and on all aspects related to the Regulation’s objectives.  

Quality of reported information 

58 

 
 
 
 
 
 
 
 
 
Evaluation questions &  
sub-questions 

Judgement criteria 

Indicators and information 
requirements 

Data sources 

Analysis cross 
reference  

While the Regulation enhanced the quality of reported information in NECPs to a sufficient extent, some gaps and issues with the completeness of reported data remain. There are indications that individual Member States have taken 
differing approaches to this, potentially influencing the nature of the collected information. The Regulation has effectively contributed to an improved accuracy of the available data around the five dimensions to be covered under 
Article 15(4) of the Regulation in LTSs. However, the evaluation found that differing national planning traditions negatively impacted the completeness of the LTSs, with Member States sometimes not reporting all the mandatory 
content under Article 15(4) or doing so not coherently with their NECPs. On the quality of reported information for the  biennial progress reports and their follow-up, the evaluation finds that enforcement of Articles 17 to 25 
proved effective only to some extent, with significant data gaps remaining. Concerning integrated planning and reporting on GHG policies and measures and on projections (Article 18), the evaluation finds that, although the 
number of PaMs has increased over time, the completeness of reported information (particularly quantitative information) has not improved to the same extent. The quality of information on projections of anthropogenic greenhouse 
gas emissions by sources and removals by sinks increased from 2017 to 2021.  

Timeliness of reported information  
The draft NECPs were not always submitted on time. It is unclear whether this problem is directly linked to the Regulation or whether it results from practices and/or procedural bottlenecks occurring at a Member State level. There 
were also significant delays in the submission of LTSs, with this resulting in delays and inefficiencies in the process of  producing an EU-wide assessment of the LTSs by the Commission. There are indications that the lack of 
timeliness in the submission of LTSs derives from both an insufficient administrative capacity at national level to fulfil the reporting obligations under the Regulation and the sequencing of the planning and reporting obligations (e.g., 
NECPs deadline before the LTS deadline). Nonetheless, there is no evidence that the Regulation as such was ineffective in ensuring that LTSs were submitted on time. Enforcement and administrative burden seem to have caused the 
delay. The biennial progress reports and their follow-up (NECPRs and reporting obligations stemming from Article 17 of the Regulation) were either submitted on time or with a small delay, not affecting the effectiveness of 
the Regulation.  
The timeliness of information on PaMs remained stable between 2017 and 2019, improved in 2021, and then deteriorated in 2023. The information reported on projections of anthropogenic greenhouse gas emissions by sources 
and removals by sinks improved in 2019 compared to 2017 and then deteriorated in 2021. Notwithstanding this, the evaluation does not find a lack of effectiveness that can be attributed to the Regulation.  

(Public) accessibility of reported information  
The Regulation has increased (public) accessibility of reported information at least to some extent. Stakeholders have partly divergent views and have highlighted areas in which the public accessibility of reported information 

proved limited. However, it remains unclear whether these issues are linked to the Regulation as such or to implementation issues and/or different national traditions across the EU.  

59 

 
 
 
 
 
EQ2 – What difference has the Regulation made in terms of 
promoting better planning processes and effective 
implementation of plans and reports? 

■ 

■ 

■ 

■ 

EQ2.1 – What qualitative or quantitative evidence is 
there that Member States make proper use of the 
information contained in NECPs, LTSs and annual 
and biennial reports for policy (energy and climate-
related reforms and investments, energy poverty and 
just transition strategies etc.) and communication 
purposes?  
EQ2.2 – What evidence is there that the Commission 
makes effective use of that information to develop or 
adapt EU energy and climate policies?  
EQ2.3 – Is there qualitative or quantitative evidence 
that the Regulation has increased the effectiveness of 
Member States’ national planning and has resulted in 
more substantial implementation of climate, energy 
policies and other relevant policies (reforms and 
investments) and faster progress towards national 
energy and climate objectives, targets, and 
contributions?  
EQ2.4 – Is there any qualitative or quantitative 
evidence of any barriers in implementing NECPs and 
fulfilling reporting requirements? 

■ 

■ 

■ 

There is evidence of information 
provided in the context of the 
Regulation being used at Member 
State and EU level. 
There is ownership of Regulation 
tools at the national level. 
There has been progress towards the 
national objectives, targets, and 
contributions along the five 
dimensions of the Energy Union, at 
MS level and collectively at EU 
level. 
The role and contribution of the 
Regulation can be identified. 
There is evidence of progress with 
measures (reforms and investment). 
There is evidence to suggest that the 
Regulation accelerated, consolidated, 
or promoted measures (reforms and 
investment) in certain areas.  
■  Barriers to the implementation of 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

NECPs are adequately monitored and 
actions are planned / taken to correct 
them as appropriate. 

■ 

See Section 5.1.1.2 

■ 

Literature review of actual progress on 
the national objectives, targets, and 
contributions vs plans / expectations 
(e.g., National GHG PaMs in Europe – 
European Environment Agency 
(europa.eu)). 
■ 
EU-level interviews.  
■ 
International-level interviews. 
■ 
Interviews with MS authorities. 
■ 
Targeted surveys with MS authorities. 
■  Workshop on draft evaluation results. 
■ 
EU-level interviews.  
■ 
International-level interviews. 
■ 
Interviews with MS authorities. 
■ 
Targeted surveys with MS authorities. 
■  Workshop on draft evaluation results. 

Qualitative indicators 
Extent to which MS authorities agree that MS 
make proper use of the information contained in 
NECPs, LTSs and annual and biennial reports for 
policy and communication purposes. 
Specific examples of where the information 
contained in NECPs, LTSs and annual and 
biennial reports has been used by MS for policy 
and communication purposes. 
Specific examples of where information from 
NECPs, LTSs and annual and biennial reports has 
not been adequately used by the MS. 
Extent to which EU stakeholders agree that the 
Commission makes adequate use of the 
information contained in NECPs, LTSs and 
annual and biennial reports for policy and 
communication purposes. 
Specific examples of where the information 
contained in NECPs, LTSs and annual and 
biennial reports has been used for policy and 
communication purposes by the Commission. 
Specific examples of where information from 
NECPs, LTSs and annual and biennial reports has 
not been adequately used by the Commission. 

Quantitative indicators 
■  Number of non-compliance cases identified at EU 

level or internationally (UNFCCC/ Paris 
Agreement). 

■  Distance to targets i.e., extent to which latest 

climate and energy data is in line with i) NECPs 
targets and trajectories; ii) EU targets and iii) 
international commitments. 

■  Overall implementation status of planned 

measures as per the integrated national energy and 
climate progress reports e.g., share of measures 
that are on track.  

Qualitative indicators 

■ 

Extent to which inter-ministerial teams are set up 
and work consistently to implement, update and 
monitor national energy and climate policy. 
■  Qualitative assessment of overall progress made 

■ 

with relevant policies and measures.  
Stakeholders’ and experts’ views on the specific 
contribution of the Regulation to progress made. 

Further information requirements 

60 

 
 
 
 
 
 
■  Any factors constraining the implementation of 

NECPs (identifying any barriers to the 
deployment of some measures) and planned 
corrective / mitigating measures. 

61 

 
Evaluation questions &  
sub-questions 

Judgement criteria 

Indicators and information 
requirements 

Data sources 

Analysis cross 
reference  

Answer 
The Regulation has been effective in promoting better planning processes and effective implementation of plans and reports. For instance, the Regulation helped streamline the planning processes across the energy and 
climate domains, increasing cooperation among different ministries/authorities at national level. Nevertheless, in several Member States, NECPs are seen as less important for national planning processes and are mainly 
drawn up to meet an EU obligation. Similarly, LTSs are partly outdated and do not necessarily serve as the basis for drawing up the NECPs.  

EQ3 – How effective has the Regulation been in responding 
to any ambition or implementation deficit (enforcement)?  

■ 

■ 

■ 

EQ3.1 – To what extent did the review-and-
recommendations system (Chapter 5 of the 
Regulation) prove to be sufficient? 
EQ3.2 – What were the consequences if Member 
States did not report on time and adequately? 
EQ3.3 – Have the ambition gap-filling mechanisms 
under Articles 31 and 32 of the Regulation been used 
effectively? 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

The EU has tools to deploy if it 
detects ambition gaps or 
implementation deficits. 
These tools are effectively deployed 
when needed. 
These tools are effective when 
deployed. 
The ambition gap-filling mechanisms 
are fit for purpose, they prompt MS 
to act to cover the gap (when 
needed). 
The need to explain how the gap will 
be covered in a progress report is a 
powerful incentive. 
Potential gap-filling measures work 
as planned. 
The RES financing mechanism is fit 
for its gap-filling purpose. 

Quantitative indicators 
■  Number of times the gap-filling mechanism has 
been used (e.g., number of EU or national 
measures taken number / size of voluntary 
financial contributions made). 

■  Number / share of Commission recommendations 

taken into account by MS in their final NECPs. 
■  Number of additional measures taken by MS to 

cover the gap, where appropriate.  

Further information requirements 

Stakeholders’ and experts’ view on (anticipated) 
effectiveness of the tools and potential scope for 
improvement. 

■ 

See Section 
5.1.1.3 

■ 

Legal mapping of the available tools 
and desk review of their use including 
statistics / mapping on the use of the 
EU-level measures, gap-filling 
mechanisms for RES, EE and GHG 
goals, mapping of Commission 
recommendations to MS and follow up 
to EC recommendations. 
■ 
International-level interviews. 
■ 
EU-level interviews. 
■  MS-level interviews. 
■ 
■  Case studies. 
■  Workshop on draft evaluation results. 

Targeted surveys with MS authorities. 

Answer 

Evidence shows that the main factor when it comes to implementation deficits is the fact that the enforcement mechanism is mainly based on recommendations, which are not legally binding.  

EQ4 – What difference has the Regulation made in terms of 
stimulating spending and investment? 

■ 

■ 

■ 

■ 

EQ4.1 – Is there qualitative or quantitative evidence 
that NECPs created a more stable and predictable 
regulatory framework to create investment certainty 
and stimulate public and private energy and climate 
spending and investments? 
EQ4.2 – To what extent has the Regulation helped MS 
take full advantage of opportunities for economic 
development, investment stimulation, job creation and 
social cohesion? 
EQ4.3 – Which elements of the framework (still) 
hindered such investor certainty?  
EQ4.4 -To what extent has the Regulation resulted in 
reliable information on investment needs and sources 
of private and public finance? What bottlenecks can be 
identified in this regard? 

■ 

■ 

There has been increased investment 
in sustainable technologies. 
The role and contribution of the 
NECPs can be identified. 

■ 

■ 

■ 

■ 

Quantitative indicators 

Investment needs at Energy Union priority level 
or sector level in NECPs for 2021-2030. 
Source of public/private financing at EU and 
national level in NECPs for 2021-2030. 
Investment levels in sustainable technologies in 
Member States and at EU level (trends before / 
after the Regulation). 
Funds incl. EU funds deployed to support the 
ambition of the NECPs. 

■  Desk research. 
■ 

EU-level interviews (with 
representatives of the investor 
community / industry). 
■  MS-level interviews (with 

representatives of the investor 
community / industry). 
Targeted survey of energy industry and 
of energy-intensive industries 

■ 

■  Case studies. 

See Section 5.1.1.4 

■  Awareness levels of the investor community / 
industry about NECPs in survey results. 
Share of respondents assessing the contribution of 
NECPs to investment levels as essential / 
anecdotal.  

■ 

Qualitative indicators 

■ 

Stakeholder views on contribution of NECPs to 
investment levels (qualitative). 

Further information requirements 

62 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation questions &  
sub-questions 

Judgement criteria 

Indicators and information 
requirements 

■ 

Examples / instances where NECPs were used as 
a capital-raising plan. 

■  Any factors still hindering investor certainty. 

Data sources 

Analysis cross 
reference  

Answer 

There was limited feedback on the Regulation’s impact on stimulating targeted spending and investments and on creating increased predictability for investors. The Commission’s assessments reveal that NECPs lacked detail on 
investment needs and funding sources. This was confirmed by the industry stakeholders consulted during the data collection process. Overall, the stakeholders interviewed were not always knowledgeable about all the objectives, 
obligations, and outputs stemming from the Regulation, with many mainly providing feedback on the NECPs and NLTSs. Additionally, the stakeholders consulted were not always aware of the situation before the entry into 
force of the Regulation or could not link specific trends (e.g., on investments) to the entry into force of the Regulation.  

EQ5 – How successful has the Regulation been in ensuring 
regional cooperation? 

■  MS have cooperated with each other 
in the preparation of their NECP. 

■ 

EQ5.1 – How successful has the Regulation been in 
stimulating regional cooperation between Member 
States? Can any barriers be identified in this respect? 

■  MS have had sufficient opportunity 
to comment on other MS draft 
NECPs. 
The Commission has facilitated 
cooperation between the MS on 
preparing their NECPs. 

■ 

See Section 5.1.1.5 

■  Desk research including review of 
regional cooperation activities 
undertaken as summarised in NECPs, 
review of the outcomes of the 
NECPlatform project.  
EU-level interviews. 
Targeted surveys of MS authorities. 

■ 
■ 
■  MS-level interviews.  
■  Case studies. 
■  Workshop on draft evaluation results. 

Quantitative indicators 
■  Number of times MS have cooperated bilaterally 
or multilaterally with other MS in preparing their 
NECPs.  

■ 

■ 

■ 

Qualitative indicators 

Level of regional cooperation in drawing up the 
plan, as reported by MSs in their NECPs. 
Steps taken on regional cooperation in 
transnational regions when preparing / 
implementing the plan. 
Extent to which MS authorities believe the 
Commission has adequately supported 
cooperation between the MS. 

Further information requirements 

■  Any factors facilitating / constraining regional 

cooperation.  

Answer 

The stakeholders consulted were not always aware of the situation before the entry into force of the Regulation or could not link specific trends (e.g., on investments, on regional cooperation) to the entry into force of the 
Regulation. It is important to note that, while a lot of reports are published by external stakeholders / NGOs on the public consultation/multi-level dialogues, research on the NECPs and NLTS / other reporting obligations is more 
limited and hence a lot is based on the European Commission reports and assessments. 

EQ6. How successful has the Regulation been in ensuring 
adequate multi-level and multi-stakeholder dialogue 
and consultation?  

■  Appropriate multi-level climate and 
energy dialogues were set up. 
■  Regional cooperation activities were 

■ 

■ 

■ 

■ 

EQ6.1 – How successful has the Regulation been in 
ensuring Member States set up adequate multi-level 
climate and energy dialogues involving sub-national 
authorities and other relevant actors in national energy 
and climate policymaking?  
EQ6.2 – How successful has the Regulation been in 
involving the public in designing NECPs? Was the 
public feedback considered in drafting and updating of 
NECPs? 
EQ6.3 – Can any barriers to the effective consultation 
of stakeholders be identified?  

conducted. 

■  Appropriate public consultations 

were conducted.  

■ 

■ 

Quantitative indicators 
Existence of a permanent structure acting as 
multi-level climate and energy dialogue, with 
participation of sub-national authorities and other 
stakeholders.  
Extent to which the platform is used consistently 
throughout implementation of the NECPs, 
including mandatory reporting. 
Extent to which activities were in line with the 
Aarhus Convention (e.g., broad consultations, 
open for sufficiently long periods with real scope 
to provide input). 

■  Desk research including review of 

 See Section 5.1.1.6 

consultation activities undertaken as 
summarised in NECPs, review of the 
outcomes of the NECPlatform project.  
EU-level interviews. 
Targeted surveys of MS authorities. 

■ 
■ 
■  MS-level interviews including 

interviews of sub-national authorities 
and stakeholders. 
Targeted interviews.  

■ 
■  Case studies. 
■  Workshop on draft evaluation results. 

■  Number of MS where a public consultation on the 

draft NECP was conducted. 

63 

 
 
 
 
 
 
 
 
 
 
 
Evaluation questions &  
sub-questions 

Judgement criteria 

Indicators and information 
requirements 
Extent to which national stakeholders feel they 
were adequately consulted on MS draft NECPs. 

■ 

Further information requirements 

■  Any factors facilitating / constraining regional 

cooperation.  

Data sources 

Analysis cross 
reference  

Answer 

The available evidence shows that although the introduction of Articles 10 and 11 of the Regulation is perceived as a significant step forward, the Regulation has not been particularly successful in ensuring adequate multi-level 
and multi-stakeholder dialogue and consultation, as several Member States failed to set up public consultation or multi-level and multi-stakeholder dialogue of an acceptable quality. 

EFFICIENCY 
To what extent has the Regulation achieved its key objectives in an efficient manner? 

Quantitative indicators 

■  Desk research, including data on 

 Section 5.1.2.1 

■ 

Streamlining the energy and climate 
planning, reporting, and monitoring 
obligations have led to cost savings / 
reduced administrative burden at both 
EU and MS level. 

■ 

■  Costs and administrative burden are 

■ 

■ 

assessed to be and seen as 
proportionate. 
The rationalised administrative 
burden for integrated planning and 
reporting process is justified given 
the benefits (in terms of improved 
policy coherence, regional 
cooperation, impact assessment, etc.). 

EQ7 – To what extent have the integrated and streamlined 
planning and reporting processes led to cost savings (in 
terms of policy coherence and administrative burden) and 
can costs and administrative burden be considered as 
proportionate? 

■ 

■ 

■ 

■ 

EQ7.1 – Has the harmonised, integrated, and 
predictable nature of the Regulation resulted in the 
expected cost savings at MS and EU level in terms of 
administrative burden and policy coherence (both in 
terms of energy and climate policies and across other 
policy areas such as environmental protection)?  
EQ7.2 – Is the (already rationalised) administrative 
burden of Member States' planning and reporting 
obligations proportionate to the need for a harmonised 
and integrated planning and reporting process across 
the five dimensions of the Energy Union?  
EQ7.3 – Do the benefits of this harmonised and 
integrated process (in terms of improved policy 
coherence, regional cooperation, impact assessment, 
etc.) justify the higher complexity compared to 
individual processes? 
EQ7.4 – What factors most influence the costs and 
administrative burden of Member States' planning and 
reporting obligations? Is there qualitative or 
quantitative evidence making it possible to weigh the 
impact of each factor on costs? 

enforcement and compliance costs 
from the 2016 fitness check. 
■ 
EU-level interviews. 
■  MS-level interviews. 
■  Case studies. 
■ 

SCM for costs and administrative 
burden for Member States and 
Commission (including European 
Environmental Agency), including 
from the use of the e-platform.  
■  Cost benefit assessment or cost-

effectiveness assessment of obligations 
(in terms of administrative and 
implementation costs as well as 
administrative benefits). 
Targeted survey of MS authorities.  

■ 
■  Workshop on draft evaluation results. 

Enforcement and compliance costs (incl. admin 
burden) for Member States and the Commission 
as reported in the baseline scenario /in the 2016 
fitness check. 
Enforcement and compliance costs (incl. admin 
burden) resulting from the implementation of the 
Regulation, as reported by Member States, the 
Commission, and the European Environmental 
Agency.  

■  Administrative and financial benefits resulting 
from implementation of the Regulation, as 
reported by Member States, the Commission, and 
the European Environmental Agency.  

■  Number / share of respondents reporting 

favourable changes in costs since the entry into 
force of the Regulation, and comparison of results 
with expectations when adopting the Regulation. 
■  Number / share of respondents agreeing that the 

actual benefits (until now) are higher than the 
costs / agreeing that the actual and expected 
benefits (e.g., by 2030) are expected to be higher 
than the costs. 

■  Number / share of reporting and planning teams 
who deem the allocated time to be sufficient to 
perform their duties adequately. 

Qualitative indicators 

■ 

Extent to which the expected benefits are already 
tangible now (e.g., ease of reporting process) or 
are expected to materialise in the medium to long 
term (e.g., benefits coming with stability / 
predictability of regulatory framework, impact on 
investor confidence). 

64 

 
 
 
 
 
 
 
 
 
Evaluation questions &  
sub-questions 

Judgement criteria 

Indicators and information 
requirements 
Extent to which the costs / benefits are balanced 
across the five dimensions. 

■ 

Data sources 

Analysis cross 
reference  

Answer 

The efficiency analysis produced mixed results. The regulation has streamlined some aspects of energy policy planning and reporting, but several Member States also note a rise in administrative burden, while others seem to have 
noticed actual savings in time and/or resources. However, it is difficult to disentangle the workload created by the Regulation from aspects more related to the organisational aspects of the national administrations concerned 
(including limited coordination between those involved in the reporting obligations, changes to the legislative framework and the additional workload imposed by the Regulation – if any – compared to reporting obligations that 
would be in place anyway). Recognised advantages brought by the Regulation include greater transparency and predictability, better coordination and cooperation among different national authorities involved in the reporting 
process, greater coherence of planning and reporting timelines and procedures, and better-established processes, policies, and procedures.  

The benefits of the Regulation also include its role in providing a stable framework for clean energy businesses, which is crucial for long-term investment and development in the sector. Even if this is not yet fully materialised, 
many stakeholders (especially within national authorities) considered that the Regulation is pushing national administrations to work more closely and establish coordination procedures when they did not exist before. 
Stakeholders also acknowledged that there is a ‘learning curve’ component (especially national authorities): while the initial reporting cycles are more complex and burdensome, they acknowledged that the whole process will 
become simpler (and thus less burdensome) over time, the more reporting are files and assessed, the more clarity is provided on the expected content, and the more the tools and templates are fine-tuned.  

EQ8. What is the role played by the electronic reporting 
platform and/or common templates as well as digital 
technologies? 
■ 

■  Development and use of the reporting 

electronic platform led to decreased 
administrative burden and costs for 
the Member States.  

Quantitative indicators 
■  Administrative and financial benefits for Member 
States and the Commission resulting from 
reporting via an electronic platform instead of text 
format. 

■  Desk research. 
■  MS-level interviews. 
■  Case studies. 
■ 

Targeted survey of MS authorities. 

 See Section 5.1.2.2 

■ 

EQ8.1 – Regarding progress reporting, to what extent 
does the availability of an electronic reporting 
platform and/or common templates decrease the 
administrative burden and costs of Member States 
and/or make it easier for the Commission to evaluate 
and use the information and data provided? 
EQ8.2 – Are the current Member States' and 
Commission's planning and reporting obligations 
designed in such a way that they make efficient use of 
developments in the fields of digital technologies and 
processes of collecting, organising, and analysing 
large sets of data (big data analytics, machine-to-
machine reporting)? 

■ 

Further information requirements 
Stakeholder views on main cost drivers – 
distinguishing between one-off implementation 
costs (cost for developing or adapting the IT 
infrastructure, bringing in organisational changes / 
establishing processes, cost of organising the 
consultation on draft NECP) and regular costs 
(cost of ongoing coordination between different 
entities compiling or providing data, cost of 
preparing/ submitting progress reports). 

Answer 

The evidence suggests that the Regulation has partially streamlined the planning, reporting, and monitoring processes by introducing digital tools. Yet it falls short of achieving complete harmonisation and timely alignment with 
EU and international obligations, as indicated by the mixed stakeholder feedback and survey responses. Among the difficulties, stakeholders mentioned the alignment of timetables for various tasks, such as preparing the NECPs 
and NECPRs, resulting in a lack of adequate incorporation of lessons learned from previous cycles, and the overlapping of draft NECP update and NECPR in 2023. Among other EU obligations, the main difficulties included the 
synchronisation with obligations like Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants, and National Air Pollution Control Programmes under the NEC Directive, leading to 
challenges in achieving coherence in implementation efforts. Concerning international obligations, both the NECPR and the UNFCCC Biennial Transparency Report include biennial reporting obligations, but each in different 
year (even years for UNFCCC/BTR -, and odd years for NECPR) (more details are provided in Section 5.1.3).  

EQ9 – To what extent has the Regulation contributed to 
streamlined planning, reporting, and monitoring including 
through further digitalisation or consolidation?  

■ 

EQ9.1 – To what extent are the timing and periodicity 
of the different planning and reporting obligations, 
both within the Regulation and outside, consistent? 

■ 

■ 

The current set up is suitable (to 
facilitate communication, to facilitate 
public access to information) and 
reflects latest digital developments. 
There is consistency between 
different planning, reporting, and 
monitoring obligations in different 

■ 

Qualitative indicators 
Extent to which the e-platform fulfils all its 
functions repository for plans, reports and 
strategies tracker function (making it possible to 
follow live the latest developments in the 
implementation of the NECPs) access to data and 
underlying assumptions in a user-friendly manner 

■  Mapping the functions of the e-

 See Section 5.1.2.3 

■ 
■ 

platform.  
Legal mapping. 
EU-level interviews and international 
level interviews (feedback from those 
receiving the information). 

65 

 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation questions &  
sub-questions 

■ 

■ 

EQ9.2 – Is there evidence of red tape due to overlaps 
with other EU or national planning and reporting 
procedures?  
EQ9.3 – To what extent have the planning and 
reporting processes taken into consideration other 
reporting and planning obligations (e.g., JTM, RRF, 
etc.) to avoid potential peak reporting and planning 
periods? 

■ 

Judgement criteria 

fields that is directly related to the 
energy and climate (in terms of 
timing / periodicity / scope) – 
including synchronicity with the 
Paris Agreement / other international 
obligations.  
There is no scope to further 
consolidate obligations on 
governance between the Regulation 
and other related EU law. 

Data sources 

Analysis cross 
reference  

■  MS-level interviews (feedback from 

those producing the information). 
Targeted survey of MS authorities. 

■ 
■  Case studies.  
■  Workshop on draft evaluation results. 

Indicators and information 
requirements 
(e.g., those underpinning impact assessment of 
planned policies and measures) interactivity 
(allowing multi-level, cross-national dialogue).  
Extent to which e-platform / common templates 
match users / needs. 

■ 

Further information requirements 
■  Room for improvement, any best practice 

example at MS (solutions for streamlining and 
digital processing). 

■  Main factors / obligations, within or beyond the 

■ 

scope of the Regulation, adding to administrative 
burden and/or undermining policy coherence 
(e.g., new initiatives adopted since the entry into 
force of the Regulation, international obligations, 
domestic planning, and reporting procedures) 
Potential to further streamline obligations (e.g., 
better alignment of the periodicity of planning, 
reporting, and monitoring obligations with 
obligations at international level, potential to 
streamline parallel domestic planning and 
reporting procedures). 

Answer 
Mixed views were also reported on the benefits of using common templates and platforms. The same number of national authorities reported that savings in time and/or resources – thanks to the use of IT tools – led to more efficient 
planning and reporting in their Member States, as those reporting the opposite view. Although the majority of national authorities reported that entering data on EU electronic platforms led to cost increases, the number of those who 
said that the costs remained the same or decreased is almost the same. Among the reasons for costs increases, stakeholders referred to the need to reformulate data and information before uploading it to the platforms. They also 
emphasised the lack of an easily sharable tool for compiling a comprehensive answer from different contributing authorities in the same reporting country, as well as the lack of strong links between the platforms.  

The reasons behind the reported reduction in  costs / and burden included the fact that the platforms  enable users to know what information and data should be collected and submitted, help avoid developing national tools for 
submissions and enable access to the reported information by several users at the same time, who can check and validate information, thus minimising the risk of errors. Having two separated platforms has garnered some criticism 
from many stakeholders, in particular due to poor links between the two, including the formats. However, some stakeholders appreciated having two platforms, for instance due to their role in standardising reporting and systematising 
data collection, hence facilitating availability and comparability of information. 

COHERENCE  
To what extent has the Regulation achieved its key objectives in a coherent manner? 

■  Domestic, EU and international 

Quantitative indicators 

■  Number / share of stakeholders agreeing that 

■  Review of targets, plans and policies to 
check alignment and consistencies. 

 See Section 5.1.3.1 

EQ10 – To what extent does the harmonised and integrated 
nature of planning, reporting, and monitoring lead to improved 
coherence of MS and EU climate and energy policy within the 
remit of the Regulation? (Internal coherence) 

■ 

EQ10.1 – To what extent are the different planning, 
reporting, and monitoring obligations under the 
Regulation coherent with one another? 

objectives are reconciled, the NECP 
process with drafts and revisions has 
resulted in MS increasing national 
targets to reach the overall EU target.  
■  National governance framework is in 

place in MS.  

■  Cross-national dimensions of MS 

energy policies are better 
coordinated, MS taking up cross-

governance framework / coordination processes 
are adequate in terms of whole-of-government 
coordination, coordination with sub-national 
levels of government as appropriate, ex ante and 
ex post impact assessment practices consistently 
measuring climate / energy / environmental 
impacts of policies across areas. 

■  Review of the information at 

international level (UNFCCC/ Paris 
Agreement) by the EU and EU MS. 

■  Review of EU assessments and 
international (UNFCCC/ Paris 
Agreement) reviews.  

■  Review of the national climate 

governance framework in place in MS.  
International-level interviews. 

■ 

66 

 
 
 
 
 
 
 
 
 
 
 
 
Evaluation questions &  
sub-questions 

Judgement criteria 

Indicators and information 
requirements 

Data sources 

Analysis cross 
reference  

■ 

border considerations in their revised 
NECPs. 
Synergies, potential trade-offs and 
spillovers across climate and energy 
policy areas are better addressed. 

■ 

■ 

■ 

■ 
EU-level interviews. 
■  MS-level interviews. 
■  Case studies. 
■  Workshop on draft evaluation results. 

Qualitative indicators 
Extent to which EU-level reports are consistent 
with those submitted by EU Member States.  
Extent to which the information in the plans and 
reports are assessed to be consistent including no 
mismatch between targets, consistency of 
definitions, consistency between targets / planned 
measures, alignment between measures planned / 
measures financed and timely alignment of the 
different obligations. 
Extent to which adequate processes are in place 
for consulting / coordinating with other MS on 
national planning activities with a regional scope.  

Further information requirements 

■  Any best practice examples illustrating increased 
policy coherence at national / transnational level 
and remaining challenges. 

Answer 
Overall, evidence shows that the Regulation streamlined previously existing planning and reporting obligations from various pieces of legislation across energy, climate, and other Energy Union related policy areas. Evidence 
suggests though that some inconsistencies affect both the internal and external coherence of the Regulation. Issues on internal coherence are mostly due to the complexity of integrating many obligations in a single framework and 
to the many changes occurred since the adoption of the Regulation in December 2018.  

EQ11 – To what extent is the Regulation coherent with other 
EU and international obligations (external coherence)? 

■ 

■ 

- 

EQ11.1 – To what extent is the Regulation coherent 
notably with: 
- 

Obligations from other EU energy and climate 
legislation, such as those stemming from the 
European Climate Law, and other relevant parts 
of the European Green Deal, Fit-For-55?  
International obligations, including from the 
Paris Agreement and its enhanced transparency 
framework, the Sustainable Development Goals, 
the Aarhus Convention, and other relevant 
international conventions and for a (e.g., G7, 
G20)?  
Other relevant EU policy fields? 

- 
EQ11.2 – To what extent has the Regulation helped 
MS identify and address trade-offs and synergies with 
environmental policies, including as regards 
biodiversity, in the NECPs and LTSs? 

■  Objectives from the Regulation are 
well aligned (in terms of ambition 
/content / substance) with other 
pieces of legislation / funding 
instruments. 
Synergies, potential trade-offs, and 
spillovers with other policy areas are 
better addressed. 

■ 

Quantitative indicators 

■ 

■  Number of MS covering particular trade-offs and 
synergies in their draft, final and revised NECPs. 

Legal mapping including review of the 
different provisions stemming from the 
different legal bases and the areas of 
potential incoherence.  

 See Section 5.1.3.2 

Qualitative indicators 

■ 

Extent to which potential incoherences are 
minimised. 

■  Desk research. 
■ 
International-level interviews. 
■ 
EU-level interviews. 
■  MS-level interviews. 
■  Case studies. 
■  Workshop on draft evaluation results. 

Answer  
Issues on external coherence are mostly related to the fact that several EU-level instruments have been created and/or updated after 2018, notably policies developed under the European Green Deal and several reporting 
timelines that are different from the UNFCCC reporting cycle, and the timing of different reporting/planning obligations are not always aligned. For instance, the Energy Efficiency Directive (EED) recast includes many new 
elements to strengthen governance that are not currently incorporated nor streamlined into the Regulation. Similarly, with the revised Renewable Energy Directive (RED), new elements were brought in, which are not reflected 
in the Regulation. 

67 

 
 
 
 
 
 
 
 
 
Evaluation questions &  
sub-questions 

Judgement criteria 

Indicators and information 
requirements 

Data sources 

Analysis cross 
reference  

EU ADDED VALUE  
How did the Regulation make a difference and to whom? 

EQ12 – To what extent could the improved consistency of 
Member States national energy and climate policies and 
coordination of energy and climate policies at EU level also 
have been achieved without the current Regulation’s planning, 
reporting, and monitoring obligations?  

■ 

The improved consistency of 
Member States national energy and 
climate policies and the coordination 
of energy and climate policies at EU 
level could not have been achieved 
without the Regulation. 

■ 

■ 

Qualitative indicators 

Extent to which MS would be able to plan their 
policies and measures in the energy and climate 
fields to achieve the Energy Union objectives 
across its five dimensions in the absence of the 
formal consultation / coordination process with 
the EU / other MS stemming from the current 
Regulation. 
Extent to which the Commission could assess 
whether MS are collectively on track to achieve 
the Energy Union objectives / could intervene in 
the case of insufficient progress made in the 
absence of the current Regulation. 

■  Desk research. 
■ 
EU-level interviews. 
■  MS-level interviews. 
■  Case studies. 
■  Workshop on draft evaluation results. 

 See Section 5.2.1.1 

Answer 
The EU added value of the Regulation stems from a notable improvement in terms of enhanced consistency in national energy and climate policies, though such impact varied across Member States and depended on national 
processes that preceded the Regulation. The Regulation contributed to enhance coordination in national energy and climate policies. While stakeholders agreed that it contributed to enhanced cooperation, they also noted that 
coordination with sub-national actors could be further strengthened. 

EQ13 – To what extent do the current planning and reporting 
obligations provide information at EU or national level that 
would not otherwise be available?  

■ 

The current planning, reporting, and 
monitoring obligations provide 
benefits in terms of useful 
information at EU or national level 
that would not otherwise be 
available.  

■ 

■ 

Qualitative indicators 

Extent of the usefulness of the information 
provided by the current obligations as assessed by 
stakeholders. 
Extent to which the Regulation makes additional 
information accessible or available, provides 
information that would not be available from 
other sources by other regulations, as assessed by 
stakeholders. 

■ 

Legal mapping of obligations and their 
rationale. 
■  Desk research. 
■ 
EU-level interviews. 
■  MS-level interviews. 
■ 
■  Case studies. 
■  Workshop on draft evaluation results. 

Survey of MS authorities. 

See Section 5.2.1.2 

Answer 
The planning and reporting obligations set out in the Regulation provided additional information at EU and national level. The Regulation increased information availability by publishing reports and data for Member States who 
may not have done so themselves and by requesting data on indicators that certain Member States may not have reported on or collected before. Stakeholders highlighted the information they can access from other Member States 
as an element that brings added value stemming from the Regulation, both by being able to access other Member States’ plans and by assessing and reporting by the European Commission. Importantly, the Regulation has improved 
the management of energy and climate data in the EU, promoting a clearer and more open setting for sharing information and making decisions. 

EQ14 – What is the added value of the Regulation for the 
transparency and predictability of Member States’ energy 
and climate policies?  

■ 

The transparency and predictability 
of Member States’ energy and 
climate policies increased according 
to a wider set of stakeholders. 

■ 

Qualitative indicators 

Extent to which the Regulation is seen as 
providing added value for the transparency and 
predictability of Member States’ energy and 
climate policies. 

See Section 5.2.1.3 

■  Desk research. 
■ 
■ 

International-level interviews. 
EU-level interviews including wider 
stakeholders’ views (e.g., views from 
representatives from private sector / 
civil society / academia). 

■  MS-level interviews including survey 

of views from wider stakeholders of 
MS authorities. 

■  Case studies. 

68 

 
 
 
 
 
 
 
 
 
Evaluation questions &  
sub-questions 

Judgement criteria 

Indicators and information 
requirements 

Data sources 

Analysis cross 
reference  

■  Workshop on draft evaluation results. 

Answer 
While the Regulation improved the reporting, availability and predictability of data, stakeholders highlighted issues related to the timely submission, quality (in terms of completeness), accessibility and transparency of reported data.  

EQ15 – What is the added value of the Regulation in terms of 
ensuring accountability and   access to justice? 

■ 

■ 

■ 

EQ15.1 – To what extent has the Regulation enabled 
public and private actors to hold MS and the EU 
accountable for their obligations under the 
Regulation? 
EQ15.2 – Is the Regulation fit for purpose in terms of 
safeguarding the rights of public and private actors to 
have access to justice? 

■ 

The Regulation provides adequate 
mechanisms to hold the MS and EU 
accountable for their obligations 
under the Regulation. 
The Regulation supports access to 
justice. 

■ 

■ 

■ 

■ 

Qualitative indicators 

Extent to which the Regulation is seen as 
providing added value in terms of enabling 
accountability in relation to energy and climate 
policies. 
Extent to which the Regulation is seen as 
providing added value in terms of access to justice 
issues in relation energy and climate policies.  
Extent to which the obligations under the 
Regulation are enforceable by the public.  

■  Desk research. 
■ 
■ 

International-level interviews. 
EU-level interviews including wider 
stakeholders’ views (e.g., views from 
representatives of the private sector / 
civil society. 

■  MS-level interviews, including wider 

stakeholders’ views.  
Survey of MS authorities. 

■ 
■  Case studies. 
■  Workshop on draft evaluation results. 

See Section 
5.2.1.4 

Further information requirements 
Examples of when information produced within 
the framework of the Regulation was used e.g., by 
CSOs to hold MS / EU accountable (e.g., climate 
litigation cases) 

Answer 
There were contrasting views on the added value of the Regulation in terms of ensuring accountability and access to justice, with some stakeholders highlighting that the Regulation enabled better accountability and access to justice 
across several key domains, and others highlighting that significant improvements should be made to enhance accountability and access to justice. 

RELEVANCE  
Is the Regulation still relevant? 

EQ16 – Are the Member States’ and Commission’s planning, 
reporting, and monitoring obligations under the Regulation still 
relevant in view of legislative developments153 ?  

■ 

■ 

■ 

■ 

EQ16.1 – Are there planning, reporting, and 
monitoring obligations missing from the Regulation in 
view of recent legislative developments? 
EQ16.2 – Are there planning, reporting, and 
monitoring obligations under the Regulation that have 
become obsolete? 

■ 

■ 

Existing planning, reporting, and 
monitoring obligations remain 
relevant. 
Existing planning, reporting, and 
monitoring obligations continue to be 
sufficient, there are no missing 
elements that ought to be covered 
given the new legislation adopted 
after the entry into force of the 
Regulation. 

Qualitative indicators 

Extent of the completeness of the template for 
NECPs. 
Extent of completeness of the template for 
progress reports. 

■  Assessment of coverage of final / revised NECPs. 
■ 

Extent to which the updated NECPs covered the 
missing elements (e.g., to detail how EU funding 
e.g., from the Recovery and Resilience Facility 
will support the deployment of the Facility). 
Extent of completeness of the template for 
national adaptation reporting. 
Extent to which stakeholders agree that the 
planning, reporting, and monitoring obligations of 

■ 

■ 

Legal mapping. 

■ 
■  Desk research including mapping of 

 See Section 5.3.1.1 

final / revised NECPs.  
■ 
International-level interviews. 
■ 
EU-level interviews. 
■  MS-level interviews. 
■ 
■  Case studies. 
■  Workshop on draft evaluation results. 

Survey of MS authorities. 

153   (The European Green Deal) and related follow-up legislation, the European Climate Law, the Recovery and Resilience Facility and REPowerEU, the Green Deal Industrial Plan, the 
(planned) Net-Zero Industry Act and the Critical Raw Materials Act, international developments under the UNFCCC and the Paris Agreement, the enhanced international dimension 
of energy and climate policy,  and any other energy and climate legislation adopted after the entry into force of the Regulation) 

69 

 
 
 
 
 
 
 
 
 
 
 
 
Evaluation questions &  
sub-questions 

Judgement criteria 

Indicators and information 
requirements 

the Regulation are still relevant in view of recent 
legislative developments. 

Data sources 

Analysis cross 
reference  

Answer 
The evaluation found that Regulation's core objective of providing a governance structure that both enables and pushes Member States to commit to and deliver on ambitious climate targets has not lost its relevance. On the contrary, 
it has become more relevant given the growing urgency of climate action and the increasingly complex needs that Member States' energy and climate policies must address. As the outlook for climate change and its associated impacts 
is both worsening and becoming more clear-cut, the core objective of the Regulation – to enable and support climate action – is more relevant than ever.  

Since the adoption of the Regulation in 2018, EU energy and climate law has undergone major changes, notably in the 'Fit-for-55' package. As a primarily procedural framework that does not itself set specific targets, this has not 
rendered the Regulation obsolete as an instrument. However, certain issues reflected in recent legislation need to be better addressed in the 'products' adopted under the Regulation, such as the NECPs. 

EQ17 – How well has the governance mechanism set out by 
the Regulation responded to socio-economic, environmental, 
and geopolitical changes & risks?  

■ 

■ 

EQ17.1 – To what extent is the information it 
provides relevant, complete, and timely in the context 
of the current geopolitical context, in context of the 
accelerated energy transition (including increasing 
macroeconomic impact of energy and climate policy) 
and in view of scientific/technological progress and 
innovation?  

■ 

There are mechanisms in place to 
ensure information produced under 
the Regulation reflects new priorities 
(e.g., accelerated timetable for energy 
transition in view of scientific / 
technological progress). 
The Regulation is fit for purpose to 
make the required information 
readily available at times of crisis.  

■ 

■ 

■ 

■ 

Qualitative indicators 
Extent to which reporting / review processes are 
seen as frequent enough. 
Extent to which final / revised NECPs reflect 
emerging priorities. 
Frequency of update of the Commission guidance 
and extent to which templates factor in new 
priorities. 
Extent to which the required information was 
available during the recent energy crisis. 

■ 

Legal mapping of reporting / review 
processes. 

■  Desk research including mapping of 

final / revised NECPs. 
■ 
International-level interviews. 
■ 
EU-level interviews. 
■  MS-level interviews 
■ 
■  Case studies. 
■  Workshop on draft evaluation results. 

Survey of MS authorities. 

 See Section 5.3.1.2 

Answer 
The governance mechanisms of the Regulation do not adequately address some of the issues that have come to the forefront of energy policy due to more recent geopolitical and legislative developments. These include climate 
adaptation and energy sufficiency. This may negatively impact the ability of the Regulation framework to fully respond to emerging needs in European energy and climate policy. The Russian aggression against Ukraine disrupted 
EU energy policy across several dimensions. Although this heightened the relevance of the Directive to the Energy Union’s objectives and the need to accelerate the clean energy transition it also required a recalibration of immediate 
policy priorities and highlighted transition challenges.  

The energy supply crisis following the Russian aggression and the COVID-19 pandemic both highlighted the social and economic challenges that need to be overcome to meet the EU's climate change and just transition goals in the 
long term. Feedback from stakeholders suggest that socio-economic issues such as energy poverty and labour shortages are not adequately covered by the governance mechanisms of the Regulation. This inadequacy is exacerbated 
by the lack of robust macroeconomic assessments of the measures included in the NECPs.  

70 

 
 
 
 
 
 
 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS AND TABLE ON SIMPLIFICATION AND BURDEN REDUCTION] 

Overview of costs and benefits identified in the evaluation 

Citizens/consumers  

Businesses 

Administrations 

European Commission 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative 

Comment  

Quantitative 

Comment 

Costs 

N/A 

N/A 

Citizens/consumer
s are not subject to 
any obligations 
related to the 
implementation of 
the Regulation 

Businesses are not 
subject to any 
obligations related 
to the 
implementation of 
the Regulation 

Total costs:  

NECP: EUR 
2.9 million to 
EUR 3.7 
million (2023 
prices) 

Figures based on 
estimates derived 
from previous 
studies 
accompanying 
the Governance 
Regulation 

NECPR: EUR 
1.5 to EUR 1.9 
million (2023 
prices) 

Reporting on 
2020 targets is a 
one-off 
obligation 

Costs related 
to reporting 
exercises: 
EUR 1.1 
million  

IT costs: EUR 
5 million for 
design and 
implementatio
n of e-
platform  

Costs based on 
self-assessment 
from EU 
institutions 

Direct compliance costs  
administrative costs 

One-off 
costs 

National 
LTSs: EUR 
2.1 million to 
EUR 2.9 
million (2023 
prices) 

GHG reporting 
and 
projections: 
EUR 0.6 
million to 
EUR 0.8 (2023 
prices) 

71 

 
 
                        
 
 
 
 
 
 
 
 
Direct compliance costs  
administrative costs 

Recurrent 
costs (per 
year) 

Reporting on 
2020 targets: 
EUR 0.8 
million to 
EUR 1.3 
million (2023 
prices) 

N/A 

N/A 

Citizens/consumer
s are not subject to 
any obligations 
related to the 
implementation of 
the Regulation 

Businesses are not 
subject to any 
obligations related 
to the 
implementation of 
the Regulation 

Total costs of 
reporting and 
planning: EUR 
13.9 million to 
EUR 19.5 
million 

The largest 
costs items are 
(per year in 
2023 prices): 

NECP: EUR 
2.9 million to 
EUR 3.7 
million  

NECPR:  EUR 
3.7  million to 
EUR 4.7  
million 

National long-
term 
strategies:  
EUR 1.1  
million to 
EUR 1.4  
million  

Integrated 
reporting on 
greenhouse 
gas policies 
and measures 

72 

 
 
 
 
 
 
 
 
 
and on 
projections:  
EUR 1.4  
million to 
EUR 1.9 
million 

NAP/NAS 
EUR 1.9 
million to 
EUR 3.2 
million  

Annual 
reporting 
(cumulative): 
EUR 2.9 
million to 
EUR 4.5 
million (2023 
prices)  

Benefits 

N/A 

N/A 

Increased 
transparency and 
predictability of 
climate policies. 

N/A 

Contribution to 
creating a stable 
framework for 
clean energy 
businesses, which 
is crucial for long-
term investment 
and development in 
the sector.  

Benefits: 
Direct benefits  

Recurrent  

Reduced burden 
in monitoring 
resulting from 
more 
streamlined and 
digitalised 
reporting. 

Increased 
transparency and 
predictability. 

Better 
coordination and 
cooperation 
among different 
national 
authorities.  

Greater 
coherence of 
planning and 
reporting 
timelines and 
procedures. 

N/A 

73 

 
 
 
 
 
 
 
 
 
Better-
established 
processes, 
policies, and 
procedures. 

Effects on 
administrative 
burden are 
uncertain. 

‘Learning curve’ 
component 
acknowledged 
by national 
authorities thus it 
is expected that 
the burden will 
fall over time. 

74 

 
 
 
 
 
 
 
Simplification and burden reduction 

 Simplification and burden reduction (savings already achieved)  
Report any simplification, burden reduction and cost savings achieved already by the intervention evaluated, including the points of comparison where available (e.g., REFIT savings predicted in the IA 
or other sources).  

Citizens / consumers / workers 

Businesses 

Administrations 

Commission  

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative 

Comment  

Quantitative 

Comment 

Type: Recurrent 

Not applicable 

Not applicable 

Citizens / consumers are 
not subject to any 
obligations related to 
the implementation of 
the Regulation. 

N/A 

Businesses are not 
subject to any 
obligations related 
to the 
implementation of 
the Regulation.  

N/A 

Reduced 
burden in 
monitoring 
resulting from 
more 
streamlined 
and digitalised 
reporting. 

The Regulation 
has streamlined 
energy policy 
planning and 
reporting. The 
impact 
assessment 
estimates a   
reduction of 
direct reporting 
costs of around 
5% per year 
compared to the 
baseline.  

However, some 
Member States 
note a rise in 
administrative 
burden, while 
others report 
actual savings in 
time and/or 
resources.  

It is difficult to 
disentangle the 
workload created 
by the 
Governance 
Regulation from 
aspects of the 

75 

 
               
 
 
 
 
 
national 
administrations 
(including 
limited 
coordination 
between those 
involved in the 
reporting 
obligations, and 
the additional 
workload 
imposed by the 
Regulation – if 
any – compared 
to reporting 
obligations 
already in the 
baseline.) 

Identify further potential simplification and savings that could be achieved with a view to make the initiative more effective and efficient without prejudice to its policy objectives154. 

PART II: II Potential simplification and burden reduction (savings) 

Citizens/Consumers/Workers 

Businesses 

Administrations 

All 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative 

Comment  

Quantitative 

Comment 

Description: 

Type:  Recurrent 

Not applicable 

Not applicable 

Citizens / consumers are 
not subject to any 
obligations related to the 
implementation of the 
Regulation 

Businesses are not 
subject to any 
obligations related to 
the implementation 
of the Regulation 

Costs for 
annual 
reporting 
(cumulative) 
represent 
about 22% of 
the recurrent 
costs incurred 
by Member 
States to 
comply with 
the 
Governance 

Streamlining of 
the NECPs and 
LTSs 

N/A 

Alignment with 
obligations under 
Directive (EU) 
2016/2284 on the 
reduction of 
national 
emissions of 
certain 
atmospheric 

Expansion 
and improved 
functionality 
of the e-
platform, for 
instance to 
allow for 
more 
effective 
reuse of 
information. 

154    This assessment is without prejudice to a possible future impact assessment. 

76 

 
 
 
 
 
 
 
Regulation 
on a yearly 
basis. 
Reducing the 
frequency of 
this 
obligation 
(e.g., every 
two years 
instead of 
every year) 
would reduce 
by half the 
costs of the 
obligation, 
and by 12% 
the annual 
costs for 
Member 
States. 

pollutants, and 
National Air 
Pollution Control 
Programmes 
under the NEC 
Directive 

Alignment of 
frameworks on 
GHG emissions 
with UN 
obligations: both 
include biennial 
reporting 
obligations, but 
each in different 
year (even years 
for 
UNFCCC/BTR – 
Biennial 
Transparency 
Report, and odd 
years for 
NECPR. 

Removal of the 
reporting on oil 
stocks. 

Expansion and 
improved 
functionality of 
the e-platform, 
for instance to 
allow for more 
effective reuse of 
information. 

77 

 
 
 
 
 
 
 
ANNEX V. STAKEHOLDER CONSULTATION – SYNOPSIS REPORT  

Introduction 

This  synopsis  report  summarises  the  consultation  outreach  and  stakeholder  feedback 
received  during the study155. Section  1  presents  the approach to  the consultation, while 
Section 2 summarises stakeholder feedback. 

Approach to the consultation 

The stakeholder consultation  comprised a call for evidence, scoping  interviews, a main 
interview programme, and three online surveys that were tailored to different stakeholder 
groups. A hybrid (in-person and online) validation workshop was also organised by DG 
ENER and DG CLIMA after submission of the evaluation’s second intermediate report 
providing an opportunity for participants to discuss the preliminary study findings.  

Overview of the consultation strategy 

Before launching the stakeholder consultation, a comprehensive consultation strategy was 
developed detailing the stakeholder groups to be approached, the consultation methods to 
be used for each group, and the lines of enquiry and specific questions to be covered. Table 
1 below shows the number of stakeholders contacted and consulted. 

Overview of consultation strategy and results 

Stakeholder group 

Consultation  
method 

Stakeholders 
contacted 

Feedback  
received 

EU entities  

European 
Commission  
(including DG ENER, DG 
CLIMA,  as  well  as  other 
DGs) 

Semi-structured 
online interviews 

European  Environment 
Agency (EEA) 

Semi-structured 
online interviews 

European  Committee  of 
the Regions 

Semi-structured 
online interviews 

Joint  Research  Centre 
(JRC) 

Semi-structured 
online interviews 

5 

2 

1 

4 

5 interviews 

2 interviews 

1 interview 

2 interviews 

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

and Climate Action – final report (forthcoming) 

78 

 
 
 
 
 
 
Member State national authorities 

responsible 
Authorities 
for  planning  /  reporting 
obligations 

Other  national  authorities 
and agencies 

Industry stakeholders 

EU-level  and  national 
industry  associations  and 
organisations 

Semi-structured 
online interviews 
Online survey of 
national authorities 

Semi-structured 
online interviews 
Online survey of 
national authorities 

Semi-structured 
online interviews 
Online survey of 
industry stakeholders 

Third-sector stakeholders  

Civil 
society 
organisations  and  non-
governmental 
organisations (NGOs) 

Consumer organisations 

Individual experts 

Academic institutions and 
research organisations 

Trade unions 

Semi-structured 
online interviews 
Online survey of 
third-sector 
stakeholders 

Semi-structured 
online interviews 
Online survey of 
third-sector 
stakeholders 

Semi-structured 
online interviews 
Online survey of 
third-sector 
stakeholders 

Semi-structured 
online interviews 
Online survey of 
third-sector 
stakeholders 

Semi-structured 
online interviews 
Online survey of 
third-sector 
stakeholders 

87 

140 

295 

79 

7 interviews  
(13 national 
authorities)156 
31 survey responses 

2 interviews  
(3 national 
authorities) 
2 survey responses 

4 interviews 
17 survey responses  

16 interviews  
(15 organisations) 
12 survey responses 

6 

X 

17 

1 interview 

55 

3 interviews 
6 survey responses 

3 

1 survey response 

156   Some interviews had more than one authority from the same Member State taking part at the same time. 

79 

 
 
Other stakeholder groups 

International 
organisations 

Semi-structured 
online interviews 

13 

X 

Results per consultation method 

The  following  sub-sections  summarise  the  number  of  stakeholders  reached  by  each 
consultation method. 

Online interviews 

44 semi-structured online interviews were conducted during the evaluation, including 10 
scoping interviews during the inception stage (between July and August 2023), and 32 key 
informant interviews with stakeholders between September and December 2023.  

In  total,  invitations  were  sent  to  699  individual  contacts,  including  219  contacts  within 
national  authorities  (representing  85  national  authorities),  299  industry  contacts 
(representing 210 industry organisations) and 160 third-sector stakeholders (representing 
115 organisations and 17 individual experts). 

An  additional  36  interviews  were  conducted  for  the  case  studies  between  January  and 
March 2024. These included 22 interviews with national authorities, 13 interviews  with 
third-sector stakeholders and one interview with an industry organisation. 

Overview of interviews conducted for the case studies 

Case study 

BELGIUM 

Interviews conducted 

National authorities: 5 interviews 

Third-sector stakeholders: 1 interview 

DENMARK 

National authorities: 1 interview 

FRANCE 

GERMANY 

MALTA 

POLAND 

National authorities: 3 interviews 

Third-sector stakeholders: 4 interviews 

National authorities: 4 interviews 

Third-sector stakeholders: 3 interviews 

National authorities: 4 interviews 

Third-sector stakeholders: 3 interviews 

National authorities: 2 interviews 

National authorities: 3 interviews 

ROMANIA 

Third-sector stakeholders: 2 interviews 

Industry organisations: 1 interview 

80 

 
36 

TOTAL INTERVIEWS 
CONDUCTED 
The number of scoping interviews conducted met the target for the evaluation. However, 
only  around  half  the  planned  key  informant  interviews  could  be  conducted.  This  was 
despite the strategies adopted by the support study team to try and increase the participation 
rate, which included contacting additional stakeholders, asking stakeholders for references 
and to share the invitation to their own contacts, sending reminders and using alternative 
contact methods (e.g., phoning) or channels where relevant. Nearly all stakeholders that 
declined  to  be  interviewed  did  not  specify  a  reason,  though  a  small  minority  indicated 
either not being available or not feeling capable to comment on the Regulation.  

Online surveys 

Three targeted online surveys were carried out during the evaluation: 

-  One  survey  for  national  authorities.  The  survey  was  sent  to  219  contacts 

(representing 85 national authorities) and received 20 responses. 

-  One  survey  for  industry  stakeholders.  The  survey  was  sent  to  289  contacts 
(representing 210 different industry organisations) and received 17 responses. 

-  One survey for third-sector stakeholders. The survey was sent to 146 stakeholders 
(representing 115 different organisations and 17 individual experts) and received 
19 responses. 

The surveys were launched in English on 4 October 2023 and remained open for seven 
weeks,  until  27 November 2023.  The  surveys  were  kept  open  two  weeks  longer  than 
initially planned in an attempt to boost the response rates. Although the surveys generated 
considerable  interest,  the  final  number  of  usable  responses  was  around  half  the  level 
initially anticipated. No responses to the online surveys appeared to have been submitted 
as part of a coordinated campaign. Several largely incomplete responses were discarded 
during the data cleaning and analysis process to ensure the integrity of the final dataset.  

Call for evidence 

The call for evidence hosted on the European Commission’s ‘Have Your Say’ website157 
ran between July and August 2023, eliciting 53 responses from the public. The majority of 
respondents answered on behalf of an NGO (34%), an environmental organisation (9%) or 
an academic / research institution (6%). Public authorities accounted for 15% of responses, 
while around one in five respondents represented either a business association (13%) or a 
company (9%). 9% of responses were submitted by EU citizens in their personal capacity. 
Responses came from 16 EU Member States and two third countries (Australia and the 
United Kingdom), with the most represented countries being Belgium (18 responses) and 

157   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 

81 

 
 
Germany  (9  responses).  Around  half  the  responses  from  stakeholders  in  Belgium  were 
from EU interest organisations.  

Stakeholder event 

The  European  Commission  also  organised  a  hybrid  stakeholder  event  on  11 January 
2024158.  The  event  included  around  120  representatives  from  Member  States’  national 
authorities,  industry  organisations,  as  well  as  civil  society  stakeholders.  A  total  of  460 
online connections159 were registered during the event, with a peak online viewership160 of 
174.  

After introductory remarks by the European Commission, ICF161 presented the emerging 
findings of the evaluation. Participants were then invited to discuss, question, validate or 
refute the data and emerging findings. The event was organised in three thematic sessions 
covering  (1)  target  achievement,  (2)  integrated  planning  and  streamlining,  and  (3) 
cooperation and consultation. The discussion included an online interactive polling session 
where participants were invited to score and express their views on a series of questions 
and statements about the Governance Regulation.  

Summarised stakeholder feedback 

Relevance of the Regulation 

Most  of  the  stakeholders  consulted  agreed  that  the  Governance  Regulation  remains  a 
relevant  piece  of  legislation  to  govern  EU  climate  action  and  energy  policy  goals.  The 
stakeholders  interviewed  generally  indicated  that  it  remains  a  relevant  instrument162, 
although several asked for it to be updated to reflect recent EU and international legislative 
and policy initiatives163. 

Relevance vis-à-vis the EU legislative framework 

The national authorities and third-sector stakeholders that responded to the online surveys 
had noticeably different views about the continued and future relevance of the Governance 
Regulation.  Around  half  (13/25)  of  the  responding  national  authorities  agreed  that  the 
Governance  Regulation’s  provisions  and  obligations  remain  relevant  and  up-to-date  in 
light of EU legislative developments. Only about a third (4/14) of responding third-sector 
stakeholders  agreed.  Half  the  third-sector  stakeholders  that  participated  in  the  survey 
disagreed  (2/14)  or  strongly  disagreed  (5/14)  that  the  provisions  and  obligations  of  the 
Governance  Regulation  remain  relevant  and  up-to-date,  as  did  the  seven  national 

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

regulation-2024-01-11_en  

159   A  viewer  can  generate  more  than  one  connection  during  the  live  event,  e.g.,  close  and  reopen  the 

streaming page later, this counts as double connection. 

160   Maximum simultaneous unique viewers at a specific moment in time. 
161   The external contractor leading the support study. 
162   Key informant interviews with two EU bodies, one national authority, one individual expert and five 

civil society organisations. 

163   Key  informant  interviews  with  one  EU  body,  two  national  authorities,  one  individual  expert,  two 

research organisations and seven civil society organisations. 

82 

 
 
authorities that indicated that the Governance Regulation is no longer relevant or aligned 
with EU developments.  

Respondents to the call for evidence highlighted that legislative changes made after 2018 
had significantly reduced the relevance of the Governance Regulation164. These changes 
include the adoption of the European Green Deal, the Fit-for-55 package, the REPowerEU 
plan, the European Climate Law, and the collective commitment to a long-term climate-
neutrality objective. For instance, seven stakeholders highlighted elements brought in by 
the  new  Renewable  Energy  Directive  and  the  Energy  Efficiency  Directive  that  are  not 
aligned with the Governance Regulation. 

Three stakeholders also explained that the EU has not updated its 2018 long-term strategy 
(‘Clean Planet for all Europeans’), which made it outdated and not in line with the new EU 
legislative  and  policy  landscape  on  energy  and  climate165.  Four  respondents  underlined 
that  the  Governance  Regulation  does  not  capture  nor  define  the  important  concept  of 
energy sufficiency166.  

Participants in the stakeholder event generally found that the Governance Regulation, its 
planning  and  reporting  tools  have  helped  achieve  national  or  EU  energy  and  climate 
objectives167. 

Relevance vis-à-vis the international framework 

The survey results were similar in relation to developments in the international framework: 
most  national  authorities  (14/21)  thought  the  Governance  Regulation  remains  relevant, 
while half of responding third-sector stakeholders disagreed (3/14) or strongly disagreed 
(4/14).  

In terms of gaps, although national energy and climate plans (NECPs) and national long-
term  strategies  (LTSs)  are  subject  to  the  access  to  information  and  access  to  justice 
obligations of the Aarhus Convention, six respondents to the call for evidence underlined 
that  the  Governance  Regulation  lacks  any  reference  or  specific  provisions  on  access  to 
justice168. 

Fitness for the future 

The  Governance  Regulation's  fitness  for  the  future  came  under  scrutiny,  especially  by 
third-sector respondents. A majority expressed disagreement (7/14) or strong disagreement 
(5/14) that the Regulation is fit for the future beyond 2030 in its present form. National 
authorities voiced more varied views: 10 out of 25 agreed that the Governance Regulation 
is fit for the future, while seven disagreed. A notable portion (8/25) gave a neutral response. 

164   NGOs (8), business associations (2), environmental organisations (3), EU citizens (1), public authorities 

(2), other (1), academia (1). 

165   NGOs (1), environmental organisations (1), academia (1). 
166   NGOs (2), environmental organisations (1), academia (1). 
167   A majority responded that this was the case to some (38/94) or to a large extent (37/94). 
168   NGOs (3), environmental organisations (2), academia (1).  

83 

 
 
Readiness to respond to changes and crises 

Most  of  the  third-sector  respondents  surveyed  (10/13)  indicated  that  the  Governance 
Regulation  has  not  provided  an  effective  framework  to  respond  to  socio-economic, 
environmental, and geopolitical changes and crises. 

In the call for evidence, stakeholders underlined that recent geopolitical events, including 
the COVID-19 pandemic and Russia's war of aggression against Ukraine, make an update 
of  the  Governance  Regulation  imperative  to  ensure  it  remains  relevant  and  fit  for 
purpose169.  

Three national authorities that responded to the survey considered that biennial reporting 
on  adaptation  measures  was  too  short  a  timeframe  and  could  prove  challenging  for 
authorities to accurately complete, as these measures were updated less frequently due to 
longer  planning  cycles.  An  additional  national  authority  discussed  the  challenges  they 
experienced in reporting on how their Member State could reach adaptation targets. They 
found it difficult to identify new measures that could realistically be designed and adopted 
at national level. Two of the civil society organisations interviewed indicated that climate 
adaptation  needs  to  be  better  covered  by  the  Regulation,  with  one  arguing  that  climate 
adaptation needs to be mainstreamed into the NECPs. This resonated with one national 
authority  that  explained  during  an  interview  that  it  was  unclear  whether  adaptation 
measures  should  have  been  integrated  in  their  NECP.  The  stakeholder  emphasised  that 
practices differed across Member States on this aspect. 

Effectiveness of the Regulation 

This section summarises how effective stakeholders believe the Governance Regulation 
has been in achieving its objectives. 

Effect of the Regulation on Member States adopting national measures 

The stakeholders surveyed reported that the Governance Regulation has at least to some 
extent  contributed  to  their  Member  State  adopting  or  implementing  measures  to  meet 
national  energy  and  climate  contributions  and  the  EU’s  2030  targets  for  energy  and 
climate170. A majority also indicated that implementation of the Governance Regulation 
has at least to some extent contributed to their Member State adopting or implementing 
policies or measures to meet greenhouse gas emission commitments in line with the Paris 
Agreement171. 

169   NGOs (4), business associations (2), environmental organisations (2), EU citizens (1), public authorities 

(1). 

170   Respondents who answered ‘to some extent’ or more, including 24 out of 28 national authorities and 12 

out of 17 third-sector stakeholders.  

171   Over  half  the  third-sector  stakeholders  (10  out  of  17)  and  most  national  authorities  (23  out  of  27) 
indicated that implementing the Governance Regulation has at least to some extent contributed to their 
Member  State  adopting  or  implementing  policies  and  measures  to  meet  greenhouse  gas  emissions 
commitments  in  line  with  the  Paris  Agreement.    One  national  authority  and  five  third-sector 
organisations indicated that the Governance Regulation has not contributed at all to this objective. 

84 

 
 
Some respondents to the call for evidence raised concerns about the lack of obligations to 
ensure coherence between NECPs and national LTSs, and whether the NECPs thus put the 
Member States (and the EU) on the pathway to decarbonisation, in line with the countries’ 
LTSs and the EU’s climate-neutrality goal172. This point was also emphasised by two civil 
society organisations that participated in the stakeholder event. 

Information contained in national plans and reports 

When  asked  about  the  impact  of  the  Regulation  on  the  completeness,  reliability  and 
accessibility  of  data  contained  in  national  plans  and  reports,  the  stakeholders  surveyed 
tended  to  indicate  that  the  Governance  Regulation  has  contributed  to  some  extent.173 
National  authorities  represented  the  large  majority  of  respondents  who  considered  the 
Regulation  to  have  contributed  to  better  information  at  least  ‘to  a  large  extent’.  The 
stakeholders  surveyed  generally  found  the  indicators  included  in  national  reports,  in 
accordance with the Regulation, to be helpful at least to some extent in tracking Member 
States’ progress across the five dimensions of the Energy Union174. 

172   NGOs (4), environmental organisations (2), academia (1).  
173   More than half (55%) of all respondent groups replied with ‘to some extent’. 
174   Three  quarters  of  respondents  (49/64)  answered  with  ‘to  some  extent’  or  more,  with  responses  not 

varying significantly between stakeholder groups. 

85 

 
 
 
 
 
Completeness, reliability, and accessibility of reported information 

Source: ICF online surveys, Evaluation of the Governance Regulation 

Survey respondents provided slightly positive views regarding the public accessibility of 
data contained in national plans and reports175. Most national authorities reported that the 
Regulation has had a positive impact in this regard176. About a third of respondents (19/65) 
across all stakeholder groups reported that the Regulation has contributed to greater public 
accessibility ‘only to a small extent’ or ‘not at all’. 

All stakeholder groups were critical of the extent to which the Regulation had contributed 
to Member States meeting their obligations on time and making information accessible in 
a timely manner. National authorities were evenly divided, with one third (10 out of 30) 
finding the Regulation had a rather positive impact, while another third (9 out of 30) felt it 
had not significantly improved timeliness or had done so only marginally. Two of the latter 
group specified that elements beyond the Regulation’s reach played a greater role (namely 
political  priorities  and  pre-existing  national  frameworks),  but  two  also  thought  that  the 
additional  reporting  obligations  had  put  a  strain  on  (notably  smaller)  public 
administrations. Just under half of industry and third-sector stakeholders indicated that the 
Regulation had helped with timeliness ‘only to a small extent’ or ‘not at all’177.  

Three  national  authorities  that  participated  in  the  stakeholder  event  also  emphasised 
obstacles impeding the timely submission of reports and data, such as the large amount of 
data to be collected, analysed, and reported, and the need to regularly update submitted 
data for progress reports. 

Some of the stakeholders interviewed remarked that the introduction of the Governance 
Regulation and accompanying plans and reports had noticeably improved the availability 
of  information  in  their  Member  State178.  Several  pointed  out  the  differing  levels  of 

175   More than a third of respondents (24/65) thought the Regulation had contributed to greater accessibility 

for the public ‘to some extent’, an additional 16 'to a large extent' and 4 'to a very large extent'. 

176   Three quarters (23/30) reported the Regulation had contributed to greater accessibility at least ‘to some 

extent’.  

177   6 of 15 industry stakeholders and 8 out of 19 third-sector respondents chose one of these answers. 
178   Interviews with two national authorities, one research organisation, seven civil society organisations. 

86 

 
 
 
information and completeness of reports between Member States, however, highlighting 
that  certain  reports  do  not  contain  the  expected  data179.  Several  interviewed  national 
authorities emphasised issues with timeliness and timeframes of reporting and updates180. 
Some  also  remarked  that  certain  data  required  by  the  European  Commission  were 
unavailable in their Member State181. By contrast, several of the stakeholders interviewed 
recognised improvements since the first NECPs were published182. 

Usefulness of national plans and reports 

The national authorities surveyed indicated that information contained in NECPs, national 
LTSs and Member States’ progress reports had been used for decision-making at a national 
level183. The opinions voiced by respondents from the third sector and industry were more 
varied, with close to half of industry representatives (8/17) considering that such data was 
only marginally used for decision-making, if at all. 

Some respondents to the call for evidence indicated that the preparation of NECPs was 
sometimes  viewed  as  a  bureaucratic  tool/check-boxing  exercise,  rather  than  a  political 
priority184. One stakeholder added that NECPs often comprised 'a compilation of existing 
plans',  rather  than  a  standalone  plan  with  new  information.  Moreover,  this  had 
consequences for the obligations provided in Article 10 of the Governance Regulation on 
public participation: when the NECP is based on existing plans, 'there is no new content to 
consult the public on'185. 

According  to  eight  respondents  to  the  call  for  evidence,  LTSs  were  not  given  enough 
prominence  in  the  Governance  Regulation,  nor  by  Member  States,  with  some  Member 
States submitting their LTS with substantial delay186. The absence of a binding template 
for  the  LTSs  was  also  mentioned  as  contributing  to  this  issue.  One  stakeholder  also 
explained  that  the  five-year  timeframe  might  be  insufficient  to  include  updated 
information187. 

Interviews with national authorities revealed that while some Member States viewed the 
NECPs and LTSs as strategic and policy-setting documents, others tended to perceive them 
as a compendium of existing data and current or planned measures, with varying levels of 
usefulness depending on whether similar documents were already drawn up nationally188. 
Several  third-sector  stakeholders  highlighted  shortcomings  in  internal  coherence  and 
usefulness  resulting  from  the  fact  that  the  first  NECPs  were  submitted  before  LTSs, 

179   Interviews  with  three  EU  bodies,  one  industry  association,  three  research  organisations,  three  civil 

society organisations. 

180   Interviews with three national authorities. 
181   Interviews with two national authorities. 
182   Interviews with one research organisation, two civil society organisations. 
183   More than two thirds (19/27) answered with ‘to some extent’ or more. 
184   NGOs (1), environmental organisation (1), academia (1). 
185   Public authority (1). 
186   NGOs (6), environmental organisations (1), academia (1). 
187   Public authority (1). 
188   Interviews with five national authorities, two civil society organisations. 

87 

 
 
meaning  that  they  lack  the  long-term  political  vision  and  impetus  which  would  govern 
policy and goal attainment189. 

Streamlining 

Six respondents to the call for evidence highlighted that the Governance Regulation is a 
key  pillar  of  the  EU's  energy  and  climate  legislative  framework,  as  it  streamlined  the 
different climate and energy planning and reporting requirements, particularly through the 
introduction of NECPs190.  

Some respondents to the call for evidence found the design of NECPs to be ineffective or 
insufficient to bridge the gap between measures and objectives191. Specifically, according 
to  eight  respondents,  the  NECP  template  provided  in  Annex  I  to  the  Governance 
Regulation no longer reflects the latest scientific progress or developments in EU climate 
and energy policies192.  

Some of the stakeholders interviewed agreed that the Governance Regulation has helped 
integrate  and  streamline  previously  scattered  obligations193.  By  contrast,  several 
interviewees argued that the Governance Regulation had also made their Member State’s 
planning  and  reporting  processes  more  complex194.  Some  stakeholders  highlighted 
turnover challenges encountered by national authorities, leading to a loss of institutional 
memory  and  in-house  expertise,  thereby  affecting  their  ability  to  fulfil  obligations 
effectively and efficiently (as they often have to rely on consultancies to complete tasks) 
and on time195. Changing political priorities was also highlighted as a barrier for medium 
and long-term consistency196. 

Several  interviewed  national  authorities  mentioned  that  the  guidance  shared  by  the 
European Commission had proved relevant and useful197. 

Effective enforcement 

The stakeholders surveyed held differing views on whether the Regulation’s enforcement 
mechanisms (to tackle insufficient national contributions or implementation of EU energy 
and  climate  objectives)  are  sufficient  and  fit  for  purpose.  Just  over  half  the  responding 
national authorities (14/26) thought the enforcement mechanisms are sufficient and fit for 
purpose, while a clear majority of third-sector respondents (14/16) disagreed or strongly 
disagreed.  Most  national  authorities  (15/26)  also  reported  that  the  Regulation’s 
enforcement  mechanisms  were  effectively  deployed  when  needed,  whereas  third-sector 

189   Interviews with one individual expert, two research organisations, three civil society organisations. 
190   NGOs (2), business associations (2), academia (1), other (1).  
191   NGOs (1), business associations (1), environmental organisations (2). 
192   NGOs (3), business associations (4), environmental organisation (1). 
193   Interview with one EU body, three national authorities, two research organisations, two civil society 

organisations. 

194   Interview with two national authorities. 
195   Interview with one national authority, one individual expert, two research organisations, one civil society 

organisation. 

196   Interview with one national authority, two research organisations. 
197   Interviews with three national authorities. 

88 

 
 
respondents were evenly divided between those that agreed and those that disagreed (5/16 
for each answer).  

Respondents to the call for evidence indicated that Articles 29 to 34 of the Governance 
Regulation had not been effective in ensuing a strong enforcement framework for climate 
and energy targets198. They highlighted that the current rules are insufficient to ensure that 
Member States meet their targets. Specifically, they considered that the current delivery 
gap  mechanism  (Article  32)  does  not  function  effectively,  and  that  there  is  a  need  for 
quicker  intervention  and  greater  transparency  in  discussions  between  the  European 
Commission and Member States on the measures taken. 

Several of the stakeholders interviewed underlined that Member State compliance with the 
Regulation’s  obligations  was  sometimes  limited.  However,  limited  compliance  did  not 
always  pertain  to  the  Regulation  itself  but  to  political  considerations  and  the  need  to 
acquire  buy-in  from  Member  States  in  light  of  growing  obligations  and  administrative 
burden199. Nonetheless, several third-sector stakeholders considered that the Regulation’s 
enforcement  procedure  could  be  made  more  transparent  and  that  the  enforcement 
mechanism should be strengthened to more effectively tackle non-compliance200. 

Effective contribution to greater predictability and certainty 

Survey  participants  were  asked  whether  the  Governance  Regulation  has  created  more 
predictability and certainty for public and private investors. While national authorities had 
mixed views, industry and third-sector stakeholders tended to indicate that the Governance 
Regulation has only marginally contributed to improving the predictability and certainty 
for investors, if at all201. 

During the stakeholder event, one industry participant highlighted the importance of the 
Governance Regulation as a common reference point for Member States to set ambitions 
and investment levels. They mentioned that, in this respect, the Governance Regulation 
helps provide regulatory certainty, which stakeholders should make greater use of. They 
also  highlighted  how  uncertainty  can  be  detrimental  to  investment  levels  and  markets, 
especially  in  sectors  vulnerable  to  external  crises  (e.g.,  political  and  geopolitical).  By 
providing  regulatory  certainty,  the  Governance  Regulation  may  have  helped  stimulate 
investment and ensure market stability. 

Although  several  stakeholders  thought  that  the  Regulation’s  plans  and  reports  should 
contribute to greater predictability and certainty for public and private investors202, they 
found it generally unclear whether this had materialised in  higher  levels of investment. 
One national authority highlighted that the timeline of NECPs and of their update was not 

198   NGOs (10), business associations (1), environmental organisations (3), academia (2). 
199   Interviews  with  two  EU  bodies,  one  national  authority,  one  research  organisation,  two  civil  society 

organisations. 

200   Interview with one individual expert, one research organisation, seven civil society organisations. 
201   Half of third-sector respondents (9/18) and just under half of industry respondents (7/16) answered with 

‘only to a small extent’ or ‘not at all’. 

202   Interviews with two EU bodies, three national authorities, two civil society organisations. 

89 

 
 
set up to inform the EU budget, with no way of reprogramming funds before 2027 (e.g., 
structural funds, the Just Transition Fund or common agricultural policy) to support the 
implementation of the NECPs. Four industry representatives thought that national plans 
and  reports  had  not  played  a  major  role  in  private  investors’  decision-making.  Several 
third-sector interviewees thought that national plans and reports had not offered sufficient 
clarity or tangible projections to guide public or private investment203. 

Regional cooperation 

A majority of surveyed national authorities thought that the Governance Regulation has 
led  Member  States  to  increase  or  take  more  advantage  of  mutual  cooperation204. 
Nevertheless, most participants responding to the live poll during the stakeholder event 
thought  that  the  Governance  Regulation  has  only  promoted  regional  cooperation  to  a 
limited extent (19/49) or to some extent (15/49). 

Several interviewed national authorities reported fruitful examples of regional cooperation 
for the purpose of implementing the Governance Regulation205, although one indicated that 
such  cooperation  would  probably  have  taken  place  even  without  the  Governance 
Regulation.  One  EU  official  interviewed  considered  that  regional  cooperation  remains 
underutilised at EU level. 

Multi-level dialogues and public consultation 

Most national authorities that responded to the online survey indicated that their Member 
State had conducted multi-level climate and energy dialogues involving local authorities, 
civil  society organisations and other relevant  stakeholders206. They also  tended to  think 
that their country had involved the public and taken due account of public feedback when 
drafting and updating national plans, at least to some extent207. Third-sector stakeholders 
were more critical: more than half believed that Member States had not set up sufficient 
multi-level  dialogue  enabling  stakeholders  to  discuss  policy  scenarios  and  review 
progress208, and half also  thought  that Member States had not  provided the public with 
effective  and  timely  opportunities  to  comment  and  engage  in  the  NECP  and  LTS 
process209.  

For several  respondents  to  the  call for  evidence,  Article 10 (public  consultation) of the 
Regulation  was  not  effective  in  ensuring  public  consultation  in  the  preparation  of 
NECPs210. They indicated that public participation had varied significantly across Member 

203   Interview with three research organisations, seven civil society organisations. 
204   According to 15 out of 24 respondents, most of whom (11) believed this had been done by their Member 
State ‘to some extent’. A third of respondents (8/24) answered that this has been the case ‘only to a small 
extent’. 

205   Interview with four national authorities. 
206   A majority (16/24) considered this was done ‘to a large extent’ or ‘to a very large extent’. 
207   A majority (13/25) selected either ‘to a large extent’ or ‘to a very large extent’ while the rest (11/25) 

answered with ‘To some extent’. 

208   Most (9/17) said this had been done ‘only to a small extent’, if ‘not at all’. 
209   Half (7/14) said Member States did so ‘only to a small extent’ or ‘not at all’. 
210   NGOs (8), business associations (1), environmental organisations (3), Academia (1).  

90 

 
 
States and had frequently not been very meaningful. Some respondents also mentioned that 
Article  11  (multi-level  climate  and  energy  dialogue)  of  the  Regulation  had  not  been 
effective  in  ensuring  that  Member  States  implement  multi-level  governance  processes 
when  designing,  implementing,  and  monitoring  national  energy  and  climate  policy211. 
They found that setting up and holding regular meetings of multi-level climate and energy 
dialogues  had  not  happened  in  a  structured  or  systematic  way,  and  that  the  feedback 
periods were too short to assess proposals and suggest potential amendments.  

Several of the stakeholders interviewed underlined that multi-level dialogues and public 
consultations had been insufficiently conducted by Member States212. Several interviewees 
welcomed the addition of Articles 10 and 11 in the Governance Regulation, noting that the 
language left large leeway for Member States to take action213. Nevertheless, some third-
sector  interviewees  found  that,  when  conducted,  multi-level  dialogues  and  public 
consultations had not always been substantial or influential enough to feed into planning 
and reporting214. One civil society organisation indicated that they had conducted their own 
research on application of Article 11 and found that the language in the Regulation lacked 
clarity and that implementation was not sufficiently transparent.  

Interviewees highlighted significant variations between Member States in implementing 
Articles 10 and 11. Some national authorities argued that such consultations were complex 
and often suffered from a lack of time to prepare and conduct them meaningfully215. Three 
national  authorities  remarked  on  the  positive  results  that  multi-level  dialogue  and  /  or 
public consultations had yielded in their Member States. However, two national authorities 
noted that similar dialogues and consultations were already in place before adoption of the 
Governance Regulation. 

Participants  responding  to  the  live  poll  during  the  stakeholder  event  generally  agreed 
(35/58)  that  a  combination  of  insufficient  provisions  within  and  implementation  of  the 
Governance Regulation had led to varying levels of public participation across Member 
States. Seven third-sector organisations highlighted the need for public consultations to be 
better implemented and stakeholder feedback more valued. 

Cost-effectiveness  

Overall impacts on costs, time, and administrative burden 

Compared to the situation before the Governance Regulation was adopted, a number of 
surveyed national authorities reported that: 

- 

the Regulation had had a negative impact on costs linked to energy and climate 
planning and reporting (11/29); 

211   NGOs (8), business associations (1), environmental organisations (1), Other (1). 
212   Interview with one EU body, two industry organisations, six civil society organisations. 
213   Interview with one individual expert, two research organisations, two civil society organisations. 
214   Interview with one research organisation, five civil society organisations. 
215   Interviews with three national authorities. 

91 

 
 
- 

- 

the Regulation had had a negative impact on time allocated to energy and climate 
planning and reporting (15/29); 

the Regulation had had a negative impact on the administrative burden linked to 
energy and climate planning and reporting (14/29). 

Some respondents to the call for evidence noted the administrative burden created by the 
Governance  Regulation,  with  its  multiple  planning  and  reporting  processes  and 
requirements216.  One  public  authority  added  that  the  Governance  Regulation  had  not 
replaced  reporting  obligations  in  other  areas,  but  had  instead  added  a  new  layer  of 
reporting, increasing the administrative burden. 

Just  over  half  the  participants  in  the  stakeholder  event  (42/80)  considered  that  the 
Governance Regulation generally strikes the right balance between the need for granular 
information in national plans and reports on the one hand and keeping the administrative 
burden proportional on the other. 

Most  of  the  national  authorities  interviewed  indicated  that  the  time  and  administrative 
burden  linked  to  their  planning  and  reporting  had  increased  since  the  Governance 
Regulation entered into force, although one indicated that it had led to cost savings in their 
Member State217. 

Costs 

National  authorities  generally  observed  that  costs  had  risen  for  most  of  the  cost  items 
presented,  with  only  a  few  exceptions  where  respondents  noted  that  costs  remained 
unchanged since the Governance Regulation was implemented. In most cases, respondents 
indicated that the Regulation had not  generated  any cost savings for their authority and 
only a small minority identified any cost saving at all. The highest number of respondents 
indicated an increase in costs associated with implementing the Regulation in the following 
areas: 

-  Human resources needed to fulfil obligations (according to 16 out of 18 national 
authorities  providing  an  answer,  with  16  replying  that  this  item  had  led  to  cost 
increases and two replying that associated costs had remained the same). Overall 
costs of preparing and submitting reports (14 out of 17 reported that this item had 
led to cost increases, with a further two respondents reporting that associated costs 
had remained the same and one noting a decrease in costs). 

-  Preparation  and  cross-service  coordination  for  national  plans  and  reports 
(according to 13 out of 16 respondents, with another three reporting that associated 
costs had remained the same). 

216   NGOs (1), public authority (2). 
217   Interviews with four national authorities. 

92 

 
 
-  Running costs for coordination and data compilation (13 out of 16 reporting cost 
increases,  with  a  further  two  respondents  reporting  that  costs  had  remained  the 
same and one reporting a decrease in costs). 

-  External  costs such as  consulting and support (13 out  of 16 respondents, with  a 

further three reporting that associated costs had remained the same). 

One difficulty  was  the limited human resources  available in  national  administrations to 
meet  reporting  and  planning  obligations,  linked  to  a  considerable  level  of  turnover  – 
meaning that national authorities lost expertise and institutional memory. Some therefore 
had to rely on external contractors to support this work218. 

Efficiencies and cost savings 

At the same time, the national authorities surveyed generally found that the Regulation had 
led to some cost savings and more efficient planning and reporting in certain aspects, such 
as: 

-  Greater coherence of planning and reporting timelines and procedures (according 
to  15  out  of  21  national  authorities  providing  an  answer  on  this  item,  with  15 
considering that this item led to cost savings and more efficient planning, while 
three respondents disagreed). 

-  Greater coordination of different competent authorities (according to 14 out of 21 

respondents. A further three respondents disagreed with that statement). 

-  Better-established processes, policies, and procedures (according to 13 out of 21 

respondents, with another three disagreeing). 

-  Better quality and timeliness of information produced (according to 12 out of 21 

respondents, while a further five national authorities disagreed). 

Reporting via the EU electronic platform(s) 

Overall, the national authorities surveyed had mixed views on the impacts that electronic 
reporting to the e-platform had on their services’ costs, time, and administrative burden. 
Although  several  respondents  agreed  than  (12/28)  that  the  e-platform  had  made  their 
reporting  to  the  Commission  easier,  most  disagreed  or  strongly  disagreed  (15/28)  that 
having a common reporting platform had saved their Member State the cost of having to 
create or maintain a similar reporting platform at national level. Several national authorities 
found  (12/28)  that  submitting  information  via  the  e-platform  had  led  to  more  costly, 
complex, and time-consuming reporting in their Member State than would otherwise have 
been the case. 

218   Interviews with two national authorities, one individual expert. 

93 

 
 
 
 
Timing of planning and reporting obligations 

The national authorities surveyed had mixed views on whether the timing of obligations 
under the Governance Regulation are internally consistent and reasonable219, and whether 
they are consistent with the timing of national obligations220 and other EU obligations221. 
A  majority  of  respondents  (13/24)  thought  that  the  timing  of  planning  and  reporting 
obligations  under  the  Governance  Regulation  align  well  with  international  obligations, 
although a third (8/24) disagreed.  

Two public authorities that responded to the  call for  evidence argued that the reporting 
platforms  used  for  Member  States’  submissions  were  not  efficient222.  One  stakeholder 
explained  that  having  to  use  two  different  platforms  was  suboptimal  and  hindered  the 
efficient transfer of the necessary information. Another indicated that EU and international 
reporting tools should be interoperable in order to support Member States and reduce the 
reporting burden.  

Several  interviewed national  authorities considered that the two reporting platforms are 
quite burdensome to use. Some national authorities highlighted issues with uploading data 
and  some  remarked  that  data  was  not  transparent,  easily  accessible,  or  readable  once 
uploaded223. Several stakeholders were confused about the existence of two different e-
reporting platforms224. Third-sector interviewees generally had more positive views and 
experiences with these platforms and their usefulness, as well as of the data they include225. 
Some still highlighted issues with user-friendliness and readability226.  

Coherence 

Internal coherence 

The national authorities surveyed generally thought that the obligations contained in the 
Governance Regulation are coherent (16/29). Although answers were not always clear-cut, 
the  most  common  view  was  that  the  obligations  of  the  Regulation  do  not  overlap  or 
duplicate each other (13/28) and are not internally contradictory (12/28). Of the surveyed 
national authorities noting the obligations are not internally coherent (6/29), overlap (9/28) 
or are contradictory (6/28), respondents pointed to possible inconsistencies between: 

- 

reporting  on  greenhouse  gas  policies  and  measures  (Article  18a)  and  provisions 
related to national energy and climate progress reports (NECPRs), notably Article 
17(3) on greenhouse policies and measures (three surveyed national authorities); 

219   Eleven out of 25 respondents disagreed (6/25) or strongly disagreed (5/25) with that statement, against 

nine who agreed. 

220   Twelve out of 26 respondents disagreed (8/26) or strongly disagreed (4) with that statement, against ten 

who agreed. 

221   Ten out of 26 respondents agreed with that statement, against nine who disagreed. 
222   Public authority (2). 
223   Interviews with four national authorities. 
224   Interviews with three national authorities, one research organisation. 
225   Interviews with one individual expert, one research organisation, three civil society organisations. 
226   Interviews with two research organisations, three civil society organisations. 

94 

 
 
-  overlaps in the elements included in Sections 2, 3, 4 and 5 under each dimension 
of  the  NECP  template,  as  included  in  Annex  I  to  the  Regulation  (one  surveyed 
national authority). 

Eight  respondents  to  the  call  for  evidence  reported  a  lack  of  consistency  between  the 
different planning instruments set out in the Governance Regulation227. Some argued that 
the sequencing of NECPs and LTSs was not coherent, as the first LTSs are submitted after 
the NECPs, although the former should inform the latter228. Since there is no mandatory 
revision of LTSs in the Governance Regulation, one respondent found this resulted in a 
situation  in  which  the  LTSs,  although  manifestly  outdated,  were  not  being  reviewed, 
resulting in the long-term direction remaining unclear and misaligned with the short-term 
action expressed in the updated NECPs229.  

Some  third-sector  interviewees  similarly  highlighted  that  not  having  a  direct  alignment 
between  the  NECPs  and  longer-term  objectives  and  policy  strategies  of  the  LTSs 
undermined the internal coherence of the Governance Regulation230. This issue was also 
raised by two third-sector respondents to the online surveys, who believed the Governance 
Regulation  lacks  a  provision  requiring  Member  States  to  guarantee  coherence  between 
their NECPs and LTSs. Alignment between the two documents is perceived as too weak 
to ensure the Member States adopt national measures to reach climate neutrality by 2050. 

Coherence with other EU and international instruments 

Depending on their stated expertise, national authorities and third-sector stakeholders were 
asked targeted questions about the coherence of the Governance Regulation with external 
EU and international instruments in the climate and energy domains. The most common 
view  was  that  the  Regulation  is  coherent  with  the  legislation  underlying  the  Fit-for-55 
package231 and the European Climate Law232. Views were slightly more divided on EU 
initiatives with climate and energy implications, such as REPowerEU, the Recovery and 
Resilience Facility and the European Semester233. Most national  authorities thought the 
Regulation is coherent with the United Nations Framework Agreement on Climate Change 
(UNFCCC) and the Paris Agreement234, with only one respondent disagreeing.  

Half the responding national authorities (12/23) thought the Governance Regulation is at 
least somewhat  coherent with the Aarhus Convention235, although a large minority said 

227   NGOs (5), environmental organisations (2), academia (1). 
228   NGOs (1), academia (1). 
229   NGOs (1). 
230   Interviews with two research organisations, four civil society organisations. 
231   Twenty out of 24 national authorities and nine out of ten third-sector respondents answered ‘to some 

extent’ or more. 

232   Twenty out of 23 national authorities and seven out of ten third-sector respondents answered ‘to some 

extent’ or more. 

233   A majority of national authorities found them coherent at least to some extent (14/24) but a third also 

answered with ‘do not know / not applicable’ (8/24). 

234   Thirteen out of 24 responded ‘to a large extent’ or more, and seven responded ‘to some extent’. 
235   UNECE Convention on Access to information, Public Participation in Decision-making and Access to 
Justice  in  Environmental  Matters  (Aarhus  Convention),  available  at:  https://unece.org/environment-
policy/public-participation/aarhus-convention/text 

95 

 
 
they did not know or found the statement not applicable (11/23). In contrast, most third-
sector  stakeholders  thought  the  Regulation  is  not  coherent  with  the  Aarhus  Convention 
(5/7). For example, one third-sector stakeholder argued that the Governance Regulation 
does not guarantee access to information and to justice under the Aarhus Convention. 

Some respondents to the call for evidence identified inconsistencies between timings in 
the Governance Regulation and other related EU pieces of legislation, such as between the 
planning process of the NECPs on the one hand, and REPowerEU chapters and the social 
climate plans on the other236. It was also argued that the sequencing and timing of the main 
governance processes under the Governance Regulation and the EU Climate Law are not 
coherent  because information (e.g.,  from  assessments under Articles 6 and 7 of the EU 
Climate  Law)  was  not  available  in  time  to  feed  into  the  planning  processes  under  the 
Governance Regulation – and vice versa237.  

Respondents  to  the  call  for  evidence  argued  that  the  Governance  Regulation  lacks 
coherence with newer pieces of EU legislation. They mentioned in particular the new EU 
targets for renewable energy and energy efficiency238. 

Several of the stakeholders interviewed noted that the Governance Regulation needs to be 
updated  to  be  coherent  with  newly  adopted  EU  legislation239.  By  contrast,  some 
interviewees  found  the  Regulation  coherent  with  the  overarching  EU  framework  and 
should not seek to be too prescriptive, lest it falls behind future initiatives240. Some timing 
inconsistencies between other EU or international obligations were identified as limiting 
coherence and creating additional burden241. 

As regards coherence with international processes, six respondents to the call for evidence 
indicated that the alignment between the five-year common timeframe of the EU climate 
policy cycle and the UNFCCC should be strengthened242.  

Three national authorities responding to the survey reported issues linked to the separate 
reporting timelines for NECPRs (due during odd years) and Biennial Transparency Reports 
(due during even years) carried out under the UNFCCC, highlighting that this cycle forced 
Member  States  to  collect  and  report  data  annually,  rather  than  every  two  years.  One 
interviewed  national  authority  identified  the  same  issue  in  the  context  of  reporting  on 
greenhouse gas projections and adaptation. Another national authority mentioned different 
timelines  on  greenhouse  gas  inventories,  which  are  reported  under  the  Governance 
Regulation up to 15 March, and up to 15 April under the UNFCCC.  

One  national  authority  commented  that  interoperability  between  EU  and  UNFCCC 
reporting tools would help ease the administrative burden.  

236   NGOs (1). 
237   Academia (1). 
238   NGOs (2), business associations (2), public authority (1), company / business (1), other (1). 
239   Interviews with one EU body, two research organisations, five civil society organisations. 
240   Interviews with one EU body, one national authority. 
241   Interviews with one EU body, two national authorities, two civil society organisations. 
242   NGOs (3), environmental organisations (2), public authority (1).  

96 

 
 
EU added value 

Scenario without the Regulation 

A slight majority of the national authorities surveyed (14/27) thought their Member State 
would not have achieved the same level of planning and reporting without the Governance 
Regulation  (although a large minority (10/27) argued otherwise). Similarly, most third-
sector respondents (10/14) concurred that the same level of planning and reporting would 
not have occurred in the absence of the Governance Regulation. Half  of the responding 
national  authorities  (14/28)  and  most  third-sector  respondents  (8/14)  agreed  that  the 
Governance  Regulation  had  made  available  information  that  would  not  otherwise  have 
been accessible to the public in their Member State. 

Several interviewees commented that the Governance Regulation had enabled a degree of 
data  availability,  accessibility  and  comparability  at  EU  level  that  would  not  have  been 
achieved  by  Member  States  on  their  own243.  Several  stakeholders  thought  that  the 
Governance  Regulation  had  improved  the  consistency  of  national  energy  and  climate 
strategies  across  EU  Member  States244,  and  enhanced  streamlining  and  coordination  of 
national planning and reporting processes245. However, some interviewees noted that there 
remains scope to improve the consistency of adopted policies, and the comparability of 
reports and data246. All interviewees, even those from Member States with stronger pre-
existing frameworks, reported that the Governance Regulation provides added value. 

Harmonisation and predictability of national policies 

Survey  respondents  had  mixed  views  on  whether  the  Governance  Regulation  has 
contributed  to  EU  Member  States  adopting  more  coordinated  and  consistent  national 
energy  and  climate  policies.  Just  under  half  the  responding  national  authorities  (11/25) 
thought the Governance  Regulation  has contributed to  more  coordinated  and consistent 
national energy and climate policies across the EU, while half the third-sector respondents 
(7/14) disagreed.  Industry respondents  were evenly  split  between those that  agreed  and 
those that disagreed. National  authorities and third-sector stakeholders generally agreed 
that the Governance Regulation  has contributed to national  energy and climate policies 
becoming  more  transparent  and  predictable247.  Industry  respondents  were  evenly  split 
between those that agreed and those that disagreed.  

The  stakeholders  interviewed  provided  mixed  views  on  whether  the  Governance 
Regulation has enhanced transparency and predictability248. Some reported that it has only 

243   Interviews with two EU bodies, two national authorities, one research organisation, four civil society 

organisations. 

244   Interview with one EU body, one national authority, two civil society organisations. 
245   Interviews with one EU body, one national authority, two civil society organisations. 
246   Interviews with two EU bodies, one national authority, one  research organisation, three civil society 

organisations. 

247   Thirteen  out  of  25  national  authorities  agreed  or  strongly  agreed,  and  seven  out  of  14  third-sector 

respondents agreed or strongly agreed. 

248   Interviews  with  one  EU  body,  two  national  authorities,  one  research  organisation,  four  civil  society 

organisations. 

97 

 
 
had a limited effect and that much remains to be done to improve in this regard249. Overall, 
interviewees tended to have reservations, show uncertainty or scepticism on this point, not 
least due to the large effort required to substantially review national reports across the EU 
(interviewees usually acknowledged only having consulted one or a few national reports). 
Reflecting on the technicality and amount of data contained in national plans and reports, 
several interviewees doubted whether most EU citizens or organisations would have the 
time and skills needed to digest the information250. 

Access to justice and accountability 

Survey  respondents  had  mixed  views  on  the  effects  of  the  Governance  Regulation  on 
enhancing  access  to  justice  and  on  enabling  public  and  private-sector  bodies  to  hold 
Member  States  and  the  EU  accountable  for  their  obligations.  Most  (17/25)  responding 
national  authorities  thought  this  had  been  achieved  at  least  ‘to  some  extent’,  but  third-
sector (7/14) and industry stakeholders (6/14) tended to think that this had happened ‘only 
to small extent’ or ‘not at all’. A majority of third-sector respondents (11/14) reported that 
the Governance Regulation lacks sufficient mechanisms to hold Member States and the 
EU accountable for their obligations. A majority (8/14) also indicated that the Regulation 
does  not  support  access  to  justice  for  public  and  private  stakeholders.  They  expressed 
mixed views when asked whether private and public bodies in their Member State are able 
to  access  justice  and  hold  governments  accountable  for  their  obligations  under  the 
Governance Regulation251. 

While  two  national  authorities  thought  the  framework  of  the  Governance  Regulation 
allows access to justice in their Member State, several third-sector interviewees contended 
that  this  aspect  of  the  Regulation  is  lacking  and  emphasised  that,  in  practice,  access  to 
justice  and  holding  Member  States  accountable  for  their  obligations  is  not  always 
ensured252. They notably referred to the lack of clarity in the procedures for ensuring access 
to justice and limited enforcement mechanisms to make plans and reports binding. They 
also considered that the provisions of the Governance Regulation on access to justice are 
not strong enough. 

249   Interviews with one national authority, one industry organisation, two civil society organisations. 
250   Interviews with two industry organisations, one research organisation, two civil society organisations. 
251   Out of 17 respondents, six disagreed and three agreed. The majority of respondents did not choose either 

option or said they did not know. 

252   Interview with two research organisations and four civil society organisations. 

98 

 
 
 
ANNEX VI. ADDITIONAL EVIDENCE  

Table 3: Overview of planning and reporting obligations in the Governance Regulation 

Planning  and 
obligations 

reporting 

Related 
articles 

NECP 

MS LTS 

EU LTS  
EU methane strategy 

NECPR 

3, 9, 14 

15 

15 

16 
17-25 

17 

Does  the  obligation 
pre-date 
the 
Governance 
Regulation? 
No, but many elements 
previous 
from 
planning obligations 
Yes 

Yes 

No, but many elements 
from 
previous 
reporting obligations 
Yes 

and 

reporting 

UNFCCC reporting (Biennial 
report 
National 
Communication) 
Integrated 
on 
greenhouse  gas  policies  and 
measures and projections 
National 
adaptation 
strategies 

change 
and 

planning 

climate 

18 

Yes 

19(1) 

Partial 

Notes 

Both original & updates, draft and final 

Under  Article  4  MMR,  Member  States  had  to  prepare  low-carbon  development 
strategies. Those strategies did not have the same structure as LTSs. 
Article 4 (1) MMR: Commission on behalf of the Union to prepare a low-carbon 
development  strategy.  Obligation  not  in  Commission  proposal,  added  in  co-
decision 

There are new provisions under the Paris Agreement for the Biennial Report. Under 
decision 18/CMA.1 and 5/CMA.3, the EU and its Member States must submit a 
Biennial Transparency Report starting in 2024. National Communications continue 
to be submitted as before (decision 2/CP.17). (Article 18 MMR, biennial reports, 
and national communications). 
Reporting of GHG projections and PaMs is established under UNFCCC and was to 
be one under the MMR, Articles 13, 14. 

Under the MMR, reporting took place every 4 years (article 15) as established in 
the UNFCCC. 

99 

 
 
 
 
 
to 

use 

of  ETS 

developing 

sustainability 

Reporting 
revenues 
Support 
countries 
Oil stocks 
Offshore safety 
Article 26 CLIMA 
Reporting on 2020 targets 
SOEUR 
NECPR assessment report 
Carbon market report 
Bioenergy 
report 
Voluntary schemes report 
Gas internal market report 
Electricity 
report 
EEOS report 
Renovation report 
NZEB report 
Internal market report 
Fuel quality report 
Competitiveness report 
Subsidies report 
CCS report 
CAPR 
E-platform 
Union and national inventory 
systems, inventory review 
Union  and  national  systems 
for policies and measures and 
projections 

internal  market 

19(2) 

19(3) 

26 
26 
26 
27 
35 

29 
28 
37, 38 

39 

Yes 

Yes 

Yes 
Yes 
Yes 
Yes 

Yes 

Yes 
Yes 

Yes 
Yes 
Yes 
Yes 
Yes 

Yes 
Yes 

Yes 

Yes 

Reporting on ETS revenues – Article 19(2)- is established in Directive 2009/29/EC. 
MMR Article 17 (Reporting on the use of auctioning revenues) 
Under MMR obligations (Article 16) 

Articles 7-9 MMR  

Obligation not in Commission proposal, added in co-decision 
Obligation not in Commission proposal, added in co-decision 
Article 38 under CCS is repealed with Governance 
Under MMR, Article 21 

Art. 5 and 6 MMR, Art. 9 MMR, Art. 19 MMR  

Art. 12 MMR 

100 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Establishment  and  operation 
of registries 

40 

Yes 

Art. 10 MMR predecessor (updated in view of international developments) 

101 

 
 
 
 
 
 
 
Table 4. Information on timeliness of major planning and reporting obligations 

Article 
NECPs 

LTS  

NECPRs 

So far, there have been significant delays in the submissions of (updated) NECPs each time a plan had to be 
submitted. For the draft NECPs (due 31-12-2018), 24 were notified before or shortly after the deadline. For 
the final NECPs (due 31-12-2019), 18 were notified before or shortly after the deadline. For the draft NECP 
updates (due 30-6-2023) 13 were notified before or shortly after the deadline.  6 infringements have been 
opened  for  late  submission  of  the  draft  NECP  updates.  Late  submission  resulted  in  inefficiencies  in  the 
process of producing an EU-wide assessment of the draft NECP updates by the Commission. It is unclear to 
what extent this problem is directly linked to the Regulation or whether it results from practices and/or procedural 
bottlenecks occurring at Member State level. According to some stakeholders, one factor that may have hampered 
the timely submission of NECPs was the lack of alignment between the Regulation timeframe and other national-
level  cycles  for  adopting  local/national  plans.  Some  national  authorities  underlined  problems  with  the  short 
timeframe between the progress reports and the draft update NECPs, and constraints in terms of administrative 
capacity, which also makes it challenging to incorporate lessons learned between rounds of reporting. 
Most  LTSs  were  submitted  late  (only  9  out  of  27  LTS  were  submitted  on  time),  resulting  in  delays  and 
inefficiencies in the process of producing an EU-wide assessment of the LTSs by the Commission. There are 
indications  that  the  lack  of  timeliness  in  the  submission  of  LTSs  derives  both  from  insufficient  administrative 
capacity at  national level  to  fulfil all the reporting obligations under the  Regulation  and the sequencing  of the 
planning and reporting obligations (e.g., NECP deadline before the LTS deadline). A lack of strong enforcement 
and  administrative  burden  at  Member  State  level  seem  to  have  mainly  caused  the  late  submission  of  LTSs. 
Notwithstanding this, there is only limited evidence that the Regulation, as such, was ineffective in ensuring that 
LTSs were submitted in a timely manner. 
The biennial integrated progress reports were submitted either on time (8 MS) or with a small delay, with 
minor implications on the Commission assessment. At a stakeholder event in early 2024, two national authorities 
mentioned that a large volume of information must be provided to fulfil the requirements of Article 17, which can 
impose a significant administrative burden on national authorities. 

102 

 
 
Integrated  reporting  on  greenhouse 
gas  policies  and  measures  and  on 
projections 

The timeliness of submissions of Policies and Measures (PaMs) substantially improved from 2019 (9 out of 
28 MS met the deadline) to 2021 (15 out of 27 MS met the deadline), before deteriorating in 2023 (11 out of 27 
MS met the deadline).  

Information reported on projections of anthropogenic greenhouse gas emissions by sources and removals by 
sinks improved in 2019 (16 out of 28 MS met the deadline) compared to 2017 (13 out 28), while it deteriorated in 
2021.  

Notwithstanding these late submissions, the evaluation does not find a lack of effectiveness that can be attributed 
to the Regulation. 
The timeliness of this reporting substantially improved from 2019 (16 out of 27 MS met the deadline) to 2021 
(17 out of 27 MS met the deadline) to 2023 (22 out of 27 MS met the deadline).  

The timeliness of this reporting improved substantially from 2017 (16 out of 27 MS met the deadline) to 2019 
(24 out of 27 MS met the deadline), but then deteriorated in 2021 and 2023 (16 out of 27 MS met the deadline).  

Integrated  reporting  on  national 
adaptation action 

Integrated  reporting  on  financial 
and technology support provided to 
developing countries 

Integrated  reporting  on  auctioning 
revenue 

The timeliness of this report varied, in 2017 (20 out of 27 MS met the deadline) in 2019 (23 out of 27 MS met 
the deadline), in 2021 (18 out of 27 MS met the deadline), in 2023 (20 out of 27 MS met the deadline). 

Reporting on offshore safety 

Reporting on oil stocks 

Reporting on the 2020 targets 

The reports were submitted either on time or with a small delay, with minor implications on the Commission's 
assessment. 
The reports were submitted either on time or with a small delay, with minor implications on the Commission's 
assessment. 
Of  the  reports  on  the  achievement  of  the  2020  renewable  energy  and  energy  efficiency  targets  (due 
30 April 2022), 21 were submitted before or shortly after the deadline. 3 infringements were opened for late 
submission. Late submissions had minor impacts on the Commission's assessment of the target achievement. 

103 

 
 
 
 
 
  
  
 
 
Table 5: Information on public accessibility of plans and reports under the Governance Regulation 

As 
required 
under 
article  
3, 9, 14 

15 

17 

18 

19 

NECP (2018, 2019, 2023) 

LTS 

NECPR (2023), including 
integrated policies and 
measures 

Projections (2023) 

Integrated reporting on national 
adaptation action, financial and 
technology support provided to 
developing countries and 
auctioning revenue (2023) 

Accessible at 

Notes 

National energy and climate plans (europa.eu) 

National long-term strategies (europa.eu) 

Reportnet 3 (europa.eu) 

https://circabc.europa.eu/ui/group/da8e36ea-9d6e-47fd-bc85-a485cf354922 

Reportnet 3 (europa.eu) 

Reportnet 3 (europa.eu) 

All submitted 
iterations of the 
NECPs and all 
Commission 
assessments publicly 
accessible. 
All 26 submitted LTS 
publicly accessible. 
163 out of 189 
dataflows made 
publicly available by 
MS. 

All submitted 
dataflows publicly 
accessible. 
All publicly 
accessible. 
Adaptation action: 

All publicly available 

Support: 

All accessible 

104 

 
 
 
 
 
 
 
 
 
 
GHG inventories (2023) 

Oil stocks 

Offshore safety 

2020 target reports 

State of the Energy Union, 
including its accompanying 
reports 

26 

26 

26 

27 

35 

Reportnet 3 (europa.eu) 

- 

Safety of offshore oil and gas operations (europa.eu) 

https://circabc.europa.eu/ui/group/da8e36ea-9d6e-47fd-bc85-a485cf354922 

Energy union (europa.eu) 

The State of the Energy Union is accompanied by a series of reports covering 
different aspects of energy and climate policy, including the annual Climate 
Action Progress Report. The latest (2023) version of this report can be 
accessed here: 60a04592-cf1f-4e31-865b-2b5b51b9d09f_en (europa.eu) 

ETS auctioning 
revenue: 

24 out of 27 submitted 
publicly available. 
20 out of 25 submitted 
publicly available. 
Not publicly available 
as it contains sensitive 
data for MS. 
Commission report 
based on national 
submissions. 
All submitted reports 
publicly accessible. 
All published reports 
are publicly 
accessible. 

105